During the 142nd session of the Senate last August 5, the Senator Francesco Bruzzone he addressed a question with a request for a written answer to Minister Costa regarding the attitude taken by Ministry of the Environment in the process of reviewing the Key concepts and on how it intends to proceed given Ispra's position in open contrast with neighboring states. Here is the text:
“To the Minister of the Environment and the Protection of the Territory and the Sea. - Given that, as far as the questioner knows: the process of amending the European document "Key Concepts", which establishes the end of reproduction and start of pre-nuptial migration dates for the bird species listed in Annexes 2A and 2B of Directive 147/2009 / EC ("Birds" directive), is underway and takes place through meetings of the NADEG committee of the European Commission and of a technical working group set up among the members of NADEG itself.
After the collection of the proposed amendments to the "Key Concepts" by the Member States, and the NADEG meetings on 21, 22 and 23 May 2019, it emerged that the proposals from Italy, prepared by ISPRA, and sent by Ministry of the Environment and Land and Sea Protection, consisting of 18 "Unpublished technical reports", are to bring the pre-nuptial migration dates forward from 2 to 6 decades, compared to those of France, Spain, Greece, Croatia and Portugal, i.e. Countries of latitude similar to Italy; on the contrary, the proposals of the Ministry of Agricultural, Food, Forestry and Tourism Policies, which are shared by most of the regions and are based on international and national scientific publications, carried out by recognized universities (for example Pisa-Padua), are the same or different for a single decade from those of the states of the European Union mentioned; this situation places the Italian State in a difficult condition before the European Commission, which hopes for homogeneous Key Concepts for "Flyway" geographical areas and in this approach the difference of one or two decades in relation to the latitude between the states is considered acceptable by the Commission.
In the course of an in-depth analysis between the parties, held at the request of the Commission in Paris, between ISPRA, French ONCFS, FACE and BirdLife and a representative of the Ministry of Agricultural Policies, ISPRA remained rigid on its positions, despite the conclusions of most of the participants, based on published studies, converge to identify the start of the migration in February of the species under discussion, we ask to know: how the Minister intends to proceed, in light of the position taken by ISPRA, to adapt the Italian "Key Concepts" to those of France, Spain, Croatia and Greece, considering that this it could lead Italy to a discrepancy with respect to the other Member States, and above all with respect to the wish of the European Commission to have Homogeneous “Key Concepts” by geographic area; what is the reason for not agreeing with the Ministry of Agricultural Policies the positions to be expressed to the European Commission, before sending the final documents, given the competence assigned to huntable species ".