Federcaccia: Sicily, in a letter to the regional councilor strong criticism of the new Hunting Calendar valid for the 2013-2014 hunting season, "Necessary changes".
The Regional Council of Sicily of the Italian Federation of Hunting and the Migratory Birdlife Office of the FIdC wrote to the Regional Councilor about the Sicilian Hunting Calendar 2013-2014. Below is the text of the letter
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Dear Councilor,
upon reading the 2013-2014 Hunting Calendar we are unfortunately forced to note that this contains highly penalizing elements for Sicilian and extra-regional hunters, which, first of all, were not present in the draft discussed in the Regional Committee, and this in itself is already something contrary to the administrative procedure. Furthermore, the choices of seasons and huntable species, in relation to the ISPRA opinion, do not in many cases meet the technical-scientific criteria used successfully in other regions, ie European documents and regional data. On the other hand, the CV accepts the ISPRA opinion in parts that would have been easily overcome with objective reasons, and on the other hand overcomes it in some parts without adequate motivation. In detail:
1. reduction of migration mobility for Sicilian hunters: the decision to reduce mobility to only 2 ATC, allowing only wood pigeon hunting, is an unexpected and unacceptable invention. This provision in fact limits many hunters to practice migratory hunting only in their own ATC of registered residence, since, given the consolidated possibility of hunting in 4 ATCs in mobility for migratory purposes, many Sicilian hunters, not dedicated to sedentary hunting, that is for the most part, for years they had no longer required ATCs of residence other than the one due by right. The judgment of the Constitutional Court of 2000 referred to the period in which the mobility was open after November 1 throughout the Sicilian territory without limitation of areas. So to date, the current provision of the 4 ATCs has not been the subject of any relevance by the Jurisprudence. The appeal for additional reasons produced by environmental associations in the course of this year has not yet been hesitated in the ruling so there is not a single reason to restrict the possibilities of hunting Sicilian hunters in such a penalizing way. We would like to point out that many Italian regions allow mobility for migratory hunting on the regional territory with various methods (e.g. remote booking in Emilia Romagna, limit of 20 days from temporary stalking in Tuscany, 10 days with prior request to ATC in Lombardy. etc. etc.). This is certainly not the place to establish whether the choice of the 4 ATCs made at the time by Sicily is correct or not, however he will agree with FEDERCACCIA that it certainly cannot be the hunters who pay duty now for a choice made 12 years ago by the region, still never object of censorship by any judicial body. We ask you to review this provision by allowing mobility for all species of migratory birdlife in at least 2 ATCs other than that of residence.
2. Prohibition of hunting for extra-regional hunters in pre-opening: this limitation denies a right to hunt to hunters regularly registered in the ATC (only one without any type of mobility) who live outside the region. These hunters are admitted to a single Sicilian ATC in a percentage established in relation to the hunting density, therefore their presence on the territory fully meets the criteria of the legislator. Therefore, the reason for depriving an acquired right is not understood. In various Italian regions, hunters registered with ATC located in regions other than that of residence can practice pre-opening (Lazio, Veneto, Tuscany, Piedmont, Umbria, Marche etc.) with the sole constraint, and only in some of these Regions , of reciprocity agreements between the various administrations. We have also often read your words in favor of hunting as an economic resource, and we guarantee that this provision actually takes several thousand euros out of the pockets of many Sicilian entrepreneurs. In fact, many extra-regional hunters (many of them natives of Sicily or originally) moved to Sicily days before the opening of September 1st, staying in farmhouses, attending restaurants, etc. Obviously the attraction was the pre-opening to the dove and the wood pigeon, especially particularly present in Sicily. We ask you to review this provision allowing extra-regional hunters regularly enrolled in the ATC to be able to pre-open.
3. Wood pigeon species hunting season: as we have already had the opportunity to tell you, the species on the calendar today undergoes a suspension of a whole month of hunting in January and then reopens for the first ten days of February. All this when it has already been kicked out even in pre-opening. We ask you: what is the meaning of this provision? Maybe someone say that for the first time in Sicily you go hunting in February? We would like to point out that, in respect of the time frame, and in compliance with the principles of good management of the species, either the pre-opening hunt is chosen and in the month of September, or it opens on 1 October and closes on 10. February. Given the strong presence of breeding and resident populations in Sicily, the wood pigeon has taken on an ever greater hunting interest in recent years, particularly at the beginning of the hunting season; therefore our proposal is to hunt it in September both in pre-opening and from the 15th, without doing the 10 days of February. In fact, the species has a hunting interest even in winter, (a period in which several species are no longer huntable), therefore the suspension of a whole month in January is highly penalizing as well as senseless. We ask you to review this provision by allowing hunting in three or four fixed days from 1 September to 14 September, and subsequently from 15 September to 26 December with reopening from 1 January to 30 January.
4. Closure of the hunting of woodcock and cesena species: for some years this FEDERATION has chosen to contrast the limitations to hunting, proposed by ISPRA and by environmentalists, with the data and documents that regulate hunting in the European Union, or document "ORNIS Key Concepts" and "Guide to the discipline of hunting under the Birds Directive". Unfortunately, for the two woodcock and Cesena species, the Italian Key Concepts data provides that the pre-nuptial migration begins in the second decade of January, therefore, using the overlapping decade provided for by the Guide and by the ISPRA as a faculty of the regions, it is possible to reach a maximum to January 20. Unfortunately, there are no regional data available for Sicily that demonstrate a difference in migration times, which could allow us to deviate from the national Key Concepts data (as is possible for the song thrush). For this reason, the closing date for the two suitable species according to EU documents is January 20, and having brought it to January 30 in the CV you proposed is an offer on the silver platter to environmentalists for appeal, which in the case of the woodcock, could then lead to the closure proposed by ISPRA on 31 December. We ask you to review this provision by bringing the closure of the two species to January 19. We are available to provide your offices with the necessary reasons.
5. Opening of the hunt for teal, pintail, wigeon, shoveler, gargane, mallard, gadwall, coot, moorhen, water rail, snipe, whisk, blackbird from 2 October instead of 15 September: all these species are huntable according to national and regional legislation from the third Sunday of September and not from the beginning of October. The opening two weeks later is an unjustified penalty for Sicilian hunters, since many of the species listed above are already present in Sicily with good densities, either because they are resident populations or have nested in Sicily (coot, mallard, gurnard of water, blackbird) and because for some the post-nuptial migration has already begun (garganey, shoveler, pintail, snipe). The evaluation of the ISPRA which proposes the opening on 2 October is easily overcome as the alleged disturbance in the wetlands is irrelevant in Sicily given the number of protected areas (argument present in the introduction to the calendar), and because the reproductive period of all the species ended on September 15th according to the European Key Concepts document. In particular, we would like to point out that the blackbird is even allowed in pre-opening in some regions with a favorable opinion from ISPRA. Furthermore, the opening on the third Sunday of September is taking place in numerous Italian regions, such as Calabria, Lombardy, Marche, Umbria, Tuscany, Emilia Romagna, Friuli. We ask you to change the opening date of the species listed above by moving it to September 15th. We are available to provide your offices with the necessary reasons.
6. Prohibition of hunting fighters: this species can be hunted in Italy by European, national and regional laws. Last season it was huntable in Calabria, Marche, Tuscany, Veneto and Friuli. There are strong and incontrovertible arguments for departing from the ISPRA opinion, which allowed to pass the scrutiny of the Veneto Regional Administrative Court which, with a sentence (see attachment) established in 2011 that the reasons brought by the region were sufficient to depart from the ISPRA opinion. In the course of these 2 years, the scientific evidence supporting hunting has increased with other works on the demography of the species. We ask you to review this provision by inserting the species in your CV from 15 September to 30 October with a limitation of daily and seasonal items. We are available to provide your offices with the necessary reasons again.
7. Ban on hunting teal in ATC SR2, RG2 and TP2: the teal species is the most common anatid in Sicily, and for this reason it is the species most killed by Sicilian hunters among the anatids (see data taken from the Sicily region). The total ban on hunting in the aforementioned ATCs is therefore absolutely unacceptable and scientifically unfounded. The ISPRA ban proposal is based on possible confusion with the marbled duck. We would like to point out that the marbled duck settled for the first time in Sicily in wetlands that were then open to hunting (Pantano Leone in 2001 and marshes of south-eastern Sicily in 2006), returning in subsequent years, always in which hunting it was open. In particular in the Leone quagmire, the closure of the hunt coincided with the disappearance of the marbled duck. These scientific data based on the experimental method are already a good argument for departing from the ISPRA opinion, but prudential regulations can be added that welcome the requests for caution without total hunting bans. We ask you to review this provision by re-admitting teal hunting in the TP2, SR2 and RG2 ATCs. We are available to provide your offices with the necessary reasons
8. Daily and seasonal meatballs: the approved CV adapts slavishly to the ISPRA opinion as regards the allowed daily and seasonal meatballs and in some cases even the Hunting Calendar introduces game bag limits that not even ISPRA has proposed (Alzavola, Coot , Mallard and others). We would like to point out that these quantities have been increased in the calendars of many Italian regions, and the appeals to the TAR against the measures have been won (Lazio, Veneto) by the administrations that had motivated the departure from the ISPRA opinion. In particular, for some species with a particular hunting tradition in Sicily, the allowed withdrawals are ridiculous in relation to the abundance of the species (turtledove 5 head per day, skylark 10 head per day). For both these species there are excellent reasons that have led for example in Lazio to double the game bag for the skylark, and the TAR has rejected the appeal. Similarly, in Veneto the CV allowed 10 turtle doves to be killed instead of 5 per day and the Regional Administrative Court rejected the appeal. We ask you, at least for these two species, to review the measure adopted by doubling the allowed daily and seasonal game bags. We are available to provide your offices with the necessary reasons.
The FIdC Regional President, Giuseppe La Russa
The National Head of the Uff. Birdlife Dr. Michele Sorrenti
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Hunting Federation
(June 21, 2013)