Hunting: the unitary response of the Hunting Associations to the note sent to Regions in recent days by the animal rights acronyms to "direct" the choices in the drafting of the Hunting Calendars.
A document shared and signed by Federcaccia, Anuu, Arci Caccia, Enalcaccia, Eps and Anlc which highlights and corrects the errors of the note of Enpa, Lac, Lav, Lipu and Wwf, indicating the lines that the Regions should follow for a "correct" drafting of the hunting calendars next season. With a joint note, Enpa, Lac, Lav, Lipu and WWF have sent the Regions in recent days a series of considerations and proposals relating to the hunting calendars for the next 2015/16 season and the EU PILOT 6955/14 procedure. Despite the firmness of the tones used and the wealth of details, the content of the letter, as noted by Federcaccia, ANUUMigratoristi, Arci Caccia, Enalcaccia, Eps and Liberacaccia "is completely wrong both as regards the EU PILOT procedure and in relation to drafting of hunting calendars ". Thus, to the written one, a clear attempt to force the hand of the Institutions in a strongly anti-venatorial sense, Federcaccia replied point by point in an exact, articulated and technically founded way with a document shared with the other hunting associations and sent to the Regions so that they have a correct guide is available and not ideologically vitiated by preconceived positions that have nothing to do with compliance with national and international standards and directives, and the protection of fauna.
Below we publish the text of the letter sent by the Hunting Associations united with the Presidents and the competent Departments:
Subject: EU PILOT 6955/14 / ENVI procedure. Observations for the drafting of the 2015/2016 regional hunting calendars.
On March 16, 2015, ENPA - LAC - LAV - LIPU - WWF sent a joint note in which considerations and proposals relating to the hunting calendars and the EU PILOT procedure are set out.
It should be noted that what is described in the letter of the aforementioned associations is completely wrong both as regards the EU PILOT procedure and in relation to the drafting of hunting calendars. As recognized by the EU Environment Commission, the EU PILOT procedure is a simple request for information from the Member State, which can lead to the closing of the case, after clarifications and discussions between the Commission and Government Authorities. Distinguishing according to the points cited by the aforementioned associations, the following is noted.
1. How hunting sustainability is measured:
- the Commission has requested that data be provided on the sampling carried out in the Italian regions but has NEVER requested that ".. the report must take place according to homogeneous scientific data proposed in journals equipped with an impact factor". This statement inserted in the letter is therefore a complete invention of the above-mentioned associations, which attempt a disconcerting intimidation towards the Public Administrations.
- With regard to the marking of the heads of migratory birds to be carried out immediately after killing, it is believed that this rule can be included in the hunting calendars in preparation for the hunting of the VAGANTE migratory, while for the forms of hunting from fixed stalking and temporary is to be established that the signing must take place every time you leave the stalking and in any case on the hunting spot.
- With regard to the collection of data on withdrawals made, the undersigned associations hope that the optical reading of the cards will be implemented by all Italian regions.
2. What measures are taken to ensure the conservation of wild species subject to hunting and in particular with respect to species SPEC2 and SPEC3:
- As already explained in previous years, the SPEC classification, proposed by BirdLifeInternational, is not sufficient on its own to evaluate the conservation status of a species, since, as BirdLife itself establishes, the data and conclusions proposed by this body must be evaluated in association with other sources of information on the status of populations. Consequently, all the proposals to limit hunting described in the letter are based on this erroneous assumption. Furthermore, the SPEC classification dates back to 2004 on data dating back to the year 2000 on average, decidedly dated and no longer valid. The SPEC classification is also in the process of being abandoned by the European Union, which will base the assessment of the status of the species (status of the populations and no longer conservation status) on the reports of article 12 provided by the Member States, see for example .: https://bd.eionet.europa.eu/article12/.
- Recent scientific findings, see attached articles, show that the causes of the decline of some species of migratory birds are not due to hunting but rather to the loss of soil and the consequent transformation and loss of habitat. Species hunted, water birds in particular, are often among those with a favorable demographics in Europe. The maintenance of the habitats put in place by hunters, and their interest in the conservation of these environments, therefore translates into an increase in the populations of these species. From this acquisition it is understood that hunting is a tool for improving the status of a population and not a problem. It follows that the simplistic assumption proposed hunting = population reduction is contradicted by scientific evidence. It therefore follows that the statement "... it (the hunting activity) is therefore such as to further deteriorate the status and therefore, pursuant to state and community legislation, it cannot be authorized ..." present in the letter of the LIPU associations etc. it does not correspond to the truth and is a further attempt to intimidate the Public Administrations. As described below, there are numerous judgments and orders of the Italian Administrative Justice that have rejected the appeals against the regional hunting calendars, among whose arguments there were precisely the SPEC species (eg: TAR Liguria, Section II, 28.7.2014 no. 1206; TAR Liguria, Section II, 16.5.2014 no. 772; CDS on CV Liguria 27.11.2013 no. 4683; TAR Lazio, Section I ter, 17.2.2014 no. 1845; TAR Tuscany, Section II , order 17.10.2013 n. 523; TAR Calabria, Section II, 25.7.2013 no. 835; TAR Veneto section I, order no. 700 of 30/11/2012, TAR Veneto section I, order no. 478 of 20.09.2013).
- As already communicated by the undersigned Associations, the European Union has drawn up several Management Plans which for huntable species in Italy are now 5, after the exclusion of Woodcock from the list of species in need of the Management Plan tool. These plans today concern Allodola, Tortora, Quaglia, Codone, and Pavoncella. None of the Management Plans propose a ban on hunting these species. The European Union requires that ACTIONS be implemented in the Member States to restore the species to a favorable state, and that the hunting is implemented in compliance with Directive 147/2009 / EC.
- The Italian State and Regions have already for many years implemented the ACTIONS proposed in the Plans, through the establishment of various types of protected areas (oases, protection areas, nature reserves, regional parks, national parks) which constitute, together with Natura2000 sites, a network of areas that allow migratory birds to take advantage of thousands of hectares for stopping, feeding and nesting. In many cases the Regions and Provinces have allowed through the ATCs, the Wildlife Hunting Companies and the fixed hunting stalks, the implementation of favorable interventions on the habitats that today allow Italy to present a favorable situation for many species of birds. wild birds in particular that can be hunted, for example see the new report on the winter censuses of water birds: https://www.isprambiente.gov.it/it/pubblicazioni/rapporti/risultati-dei-censimenti-degli-uccelliacquatici-svernanti-in-italia and in the European Union: https://www.wetlands.org/WatchRead/Currentpublications/tabid/56/mod/1570/articleType/ArticleView/articleId/3711/Default.aspx or for terrestrial species: https: // mito2000. it / species-target /, or again see the Article 12 report presented by Italy: https://bd.eionet.europa.eu/article12/report?period=1&country=IT.
- From the above it follows that if for some species the preparation of National Management Plans is desirable and indispensable, the assertion that hunting should be prohibited in the absence of national PDGs is unfounded, as in Italy there are multiple established ACTIONS in the European PDGs envisaged for the species covered by the PDGs and from which other species also benefit. A good part of these ACTIONS are carried out thanks to the economic and labor resources of the hunters.
- Due to the above, precisely because numerous conservation and restoration measures for natural habitats are in place in Italy, often thanks to the hunting world, it is NOT necessary to suspend the hunting of any of the species mentioned by the associations signing the letter (LIPU LAC ENPA LAV WWF), both for the technical-legal reasons mentioned, and because this proposal would result in the possible further loss of habitat that would damage the conservation of the same species.
- For the 5 species covered by the PDG and for those that each region, as part of its institutional role of managing body of the fauna, can establish conservation limits for daily and seasonal collection.
3. How is it intended to ensure that hunting is not exercised during breeding and pre-nuptial migration
- As already explained in previous years, and as confirmed by the Ministry of the Environment and Territory in the case on the use of substitute power, today THERE ARE ONLY THREE species of migratory birds (Beccaccia, Cesena, Tordo bottaccio) for which an institutional comparison is underway REGIONS-MINISTRY-COMMISSION EU on the closing date of the hunt. This means that the closing date of January 31st IS IMMEDIATELY APPLICABLE BY ALL ITALIAN REGIONS to ALL OTHER huntable SPECIES on January 31st according to law 157/92. This means that for Teal, Mallard, Garganey, Wigeon, Codon, Shoveler, Gadwall, Pochard, Tufted Duck, Coot, Moorhen, Water Rail, Snipe, Frullino, Combattente, Colombaccio, the closure of the hunt on 31 January is correct according to the EU and the Ministry of the Environment.
- Likewise, the general opening of the hunt on the THIRD SUNDAY OF SEPTEMBER has NEVER been questioned by the European Union and is correct according to the Italian and European Authorities.
- In relation to the three species Woodcock, Tordo bottaccio and Cesena, it should be noted that the Key concepts data in force today is contradicted both by recent scientific publications and by the comparison with the KC data of neighboring countries. It is believed that the behavior of the Ministry of the Environment and Territory has not been corrected in the dialogue with the Commission in relation to the EU PILOT procedure in question, as it has not provided precise information on the legitimacy of the application of paragraph 2.7.10 provided for in the Guide to Hunting Discipline EU, nor on the contents of the sentences and orders of the Italian Administrative Justice.
- From numerous studies, data and acquisitions it is evident that for Tordo bottaccio and Cesena the pre-nuptial migration begins in February, while for the Beccaccia the satellite radio tracking data show that the first movements begin in the first ten days of March. All supporting scientific documentation is attached to this letter.
In the spirit of collaboration that has always characterized the work of the undersigned Associations, the Regions are therefore invited to accept the data attached hereto and to formally provide a copy to the European Commission pursuant to par. 2.7.10 of the Interpretative Guide of Dir. 2009/147 / EC for the dutiful and diligent updating of the Key Concepts relating to Italy.
In part, these are documents on the basis of which the Administrative Judges recognized the legitimacy in Italy of the possible closure on January 31 of the hunt for the three species in question with decisions that both ISPRA and the Ministry unreasonably elude (among others: TAR Liguria, Section II, 28.7.2014 no. 1206; TAR Liguria, Section II, 16.5.2014 no. 772; TAR Lazio, Section I ter, 17.2.2014 no. 1845; TAR Tuscany, Section II, ord. 17.10.2013 .523 n. 25.7.2013; TAR Calabria, Section II, 835 n. XNUMX).
In adopting the data attached hereto, it is hoped and requested that the Regions foresee in their 2015/2016 hunting calendars the closing on January 31st of the song thrush hunting and in Cesena and woodcock for all the regions that have regional data to support them, disregarding the unjustified requests of the so-called. "Environmental associations" and also taking into account that even ISPRA, in some of its studies duly referred to in the documents attached hereto, recognizes that the beginning of the prenuptial migration of these three species begins in Italy in February!
In fact, the pursuit of the sustainable hunting of the three migratory species in question is of primary interest, not separated from the necessary assumption, in comparison, of the hunting calendars of the neighboring Member States (to name one, the hunting calendar of Corsica which closes the hunt on 20 February).
This is due to the unfailing need to ensure, in compliance with the fourth recital of DIR 2009/147 / EC, the uniform and transnational application of the same Directive as regards the hunting of migratory birds that come from the same countries of reproduction and dependence. and which spreads, to overwinter, in the Mediterranean area (climatically and geographically homogeneous).
It is no coincidence, moreover, that the Legislative Office of the MATTM, with its own note prot. n. 0001347 / GAB of 23.1.2015, has expressly recognized that the "Key Concepts, in reporting, on the basis of the best data available, the dates of dependence and start of the pre-nuptial migration in the various countries, presents some" inconsistencies "that are difficult to explain in the comparison between neighboring countries.
This situation is believed to be adequately taken into consideration in this context and, in any case, resolved to avoid unequal treatment among European citizens ”.
Continuing to tolerate, without any serious scientific motivation, that in Spain, France, Greece the hunting of the three species in question is allowed until the third decade of February and instead expecting that in Italy it does not go beyond 10 January is resolved, moreover, in a concrete damage to all the induced national hunting.
While remaining available for any further information, we send our best regards.
The National Presidents of the AA.VV. National subscribers
For the FIdC
For the ANUU Migrators
For the ARCICACCIA
For the ENALCACCIA
For EPS
For the ANLC
(April 16, 2015)