We publish an extensive excerpt from the letter sent by the regional president of Federcaccia Lombardy lawyer Lorenzo Bertacchi to Councilor Fabio Rolfi on the very serious situation that is looming on the horizon after the publication of the Incidence Study at Regional Wildlife Plan:
Dear Sirs Councilor Rolfi, the examination of the documentation published in the SIVAS and inherent to the Wildlife Plan raises many concerns for the future of hunting in Lombardy. The (well-founded) feeling is that the observations could be completely useless: this plan, due to the Incidence Study that accompanies and accompanies it, does not need so much technical observations and requests for changes (which we will produce anyway), but it should do so. reflect on the real opportunity to move forward with the procedure. In itself, the proposed plan stands as a plan for coordinating the provincial plans, and there would be few things to fix / integrate so that it can present itself as a substitute for the Vinca on the calendars of the coming years. The problem is the Incidence Study.
As you well know, the Incidence Study is the document with which those who propose a plan or project that could affect the conservation of Natura 2000 Network Sites it must demonstrate that it has assessed the possible repercussions (the impact, in fact) of the planning and that it has taken sufficient measures to mitigate the impacts if deemed necessary. It is the responsibility of the person who submits a plan or project. It is obvious that the study of impact is strategically fundamental: it is the document with which your office alleges the compatibility of the plan and the activity it contemplates and governs with the conservation needs of the Natura 2000 network sites. Incidence study DG Environment will adopt the VINCA, after having collected the opinions of the Management Bodies of the Sites (which can propose the prescriptions deemed appropriate).
The outcome has already been taken for granted. After all, how could it be otherwise if the proponent of the Plan himself believes that his work is inadequate? Forgive me, but because the most delicate part of the whole procedure was entrusted to researchers who are known to have a lifelong purpose to ban hunting? An Incidence Study has emerged which translates into a clear cut of the hunting activity, seen as an absolute evil, and with reference not only to the Natura 2000 sites, but to the entire regional territory. The SDI in fact clearly rejects the plan, and dictates a road that will soon lead to the end of hunting in Lombardy. Nothing is good for the editors of the SDI.
The dimensions of the ATCs and CACs are not good, the existing oases are not good, the ZRCs are not good, lead must be banned everywhere (other than a ban on lead from wetlands in 2023), the crossings are not good, it is not not even close the passes with a radius of 1000 meters (it would be necessary to identify the entire crest of the pass affected by the migration and therefore the area of a thousand meters downstream on the 4 sides it would be only the minimum area to be closed to all hunting, rather having to close as far as the route of the pass could be disturbed by hunting). We are not talking about fixed postings, which should be made to disappear from the migration routes, and for which it is proposed to prohibit their renewal upon expiry, once the migration routes have been identified. Saturnism is rampant: it ranges from the tense described expressly as "ecological traps" in which during the hunt the prey are shot and in which out hunting the maintenance in a humid area attracting ducks, waders and waders are transformed into poisoned pools due to the lead.
Even for the species to be eradicated, everything is contemplated except killing with firearms. We get to deal with the saturnism of woodcocks because they feed on earthworms that live in a territory, the Lombard one, which is now a huge expanse of lead shot, dispersed by hunters in years and years of hunting activity. Everything related to hunting is bad. The study of incidence is 600 and broken pages against hunting: which is absurd since hunting is allowed throughout Europe in the Natura 2000 sites., And the national legislation already gives conservation measures (minimum, but considered sufficient) for hunting to be compatible with the conservation of SPAs and SACs.
The study suggests a jumble of prescriptions that could well lead to an Incidence Assessment that would in fact lead to the almost total closure of hunting throughout the Lombard territory within a few years (no more than 10) and with immediate heavy repercussions. The absurd thing is that if it is true that the plan was entrusted to Oikos and the Incidence Study to FLA, both documents are in reality endorsed and presented by the same subject: by your Department and by the DG that reports to you. .
In fact, you yourself present the plan to be approved and a study in which you say that the plan is not good. I really invite you to read the Incidence Study, and to keep these observations in mind. Even the Incidence Study is not limited to accompanying the Plan, but actually replaces it: it concerns the whole territory, even in the areas furthest away from the Natura 2000 Network Sites, to which the study should indeed be limited. It is clear and obvious that the procedure has short-circuited and in these cases the only feasible thing is to disconnect the power and redo the system. At least this is what a good construction manager would do. Of course he will realize the gravity of the situation and that he will want to take the necessary decisions as a matter of urgency. Best regards. (Source FEDERCACCIA LOMBARDIA - HUNTERS)
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