What happened
The undersigned National Associations (Federcaccia, Enalcaccia, AnuuMigratoristi, Associazione Nazionale Libera Caccia, Italcaccia) and the National Hunting and Nature Committee (CNCN) gathered in the Unitary CONTROL CABIN of the Hunting World wish to bring to your attention the fact that in recent days the animalist and environmentalist acronyms LIPU-ENPA-LAC-LAV-Legambiente-WWF declared that they had sent a complaint to the European Commission DG ENVI with a request for infringement procedure against the Italian State for violation of directive 147/2009/EC.
In particular, this complaint would concern:
– closing dates of the season foreseen in the hunting calendars, as they would involve the
prenuptial migration;
– management plans for the lark, turtle dove and partridge species
– anti-poaching plan,
– recently produced interpretative circular on the use of lead in wetlands
jointly by MASE and MASAF.
Too much ideology
Given this, it should be noted, first of all, that the acronyms LIPU, ENPA, LAV, LAC have in their statute the objective of abolishing or combating hunting, therefore these are associations ideologically against hunting, whose arguments they are, therefore, flawed from the outset. Also, Legambiente and WWF, although they do not envisage the total abolition of hunting, have always been associations aligned with fundamentalist positions against hunting activity which they try to limit with requests that are not based on scientific data.
It also seems appropriate to recall that in Italy the revision of the Key Concepts document, published in 2021, did not take place according to the Commission's recommendations both as regards the need to establish a participatory and shared process, and for the scale of priorities to be used for scientific references. This has in fact determined that the Italian Regions and the Ministry of Agriculture have not been listened to in their requests, not even for a verification of the data before sending them. It follows that the KC 2021 data, in any case not legally valid, are not shared by the bodies that deal with fauna management according to the provisions of the Italian Constitution.
Specific considerations
Having said that, specific considerations are formulated below regarding the arguments put forward by the group of animal-environmentalist associations:
DATES OF THE HUNTING SEASONS AND PRE-NUTRITIONAL MIGRATION.
The species of migratory birds that can be hunted in Italy have for the most part a Key Concept datum which is placed in the month of February. For those species, on the other hand, which have KC in the third ten days of January, the hunt can close at the end of the same month through the use of the overlapping decade, provided for by paragraphs 2.7.2 and 2.7.9 of the EU Guide to the Rules of Hunting and from this year also considered legitimate by ISPRA. These are the coot, moorhen, gadwall and pintail species. Then there are some species that have been the subject of debate during the revision process of the Key concepts document, whose KC datum is today placed, in a completely different way from the other EU States, in the first or second ten days of January, yes it deals with song thrush, redwing, fieldfare, woodcock, and teal.
As is known, on these species there had been a request for modification by the Italian Regions and hunting associations during the revision of the KC document, but the then MITE and ISPRA rejected the proposals, acting autonomously, as already mentioned . It is no coincidence that the Key concepts document recognizes the discrepancy of the Italian KC data for all these species and for some of them points out that there may have been confusions between non-migratory winter movements and the beginning of the actual migration. Indeed, for the woodcock and the pintail the text of the new KC document officially states that the prenuptial migration begins in February in the trans-national geographical regions that include Italy.
With regard to the species of woodcock, song thrush, redwing, fieldfare and teal, it should be noted that the EU Hunting Rules Guide provides in paragraphs 2.7.3 and 2.7.10 for the possibility for the regions of the Member States to derogate from the KC figure national, if in possession of studies that support a prenuptial migration start date different from the national one. This is exactly what the Italian Regions have done, in particular the Veneto Region and the Puglia Region, mentioned in the LIPU press releases, using recent scientific publications, relating to their own region or to macro-areas with several neighboring regions, which demonstrate an onset of migration in February and not in january. From the foregoing it is demonstrated that no Italian region has authorized hunting during the pre-nuptial migration.
Management plans
There are three species for which management plans have been approved: the lark, the partridge and the wild dove. For the skylark, the withdrawals have been drastically reduced from 2018 to today in all regions to 10 heads per day and 50 per year. Only in two regions, always in accordance with the provisions of the national plan, was it allowed to increase the levy, only for specialist hunters, to 20 animals per day and 100 per year. However, this possibility remains linked to ISPRA's verification that the total regional withdrawal obtained in the years prior to 2018 has not been exceeded. During the last meetings of the National Technical Table on management plans, effective data collection of both withdrawals and environmental improvements in place or planned for the three species.
It should be remembered that environmental associations have always participated in the drafting of the plans, and have always had the opportunity to propose additions and modifications. Even the dove is subject to very strict daily and seasonal withdrawal limits (5-15) as well as a maximum limit for each region corresponding to 50% of the average withdrawals for the 2013-2018 seasons. This led to a more than 70% reduction in the levy compared to previous years in Italy. In many regions there are environmental improvement programs financed by the CAP and partly by the ATC which are favorable to the species. The rock partridge is historically a properly managed species throughout the Alps. Hunters participate in the censuses, the Alpine districts carry out environmental improvements and guarantee compliance with the sampling plans, always with ISPRA's opinion on the matter. In view of the above, it is not true to say that the management plans for declining species are not applied.
Anti-poaching plan
Contrary to what was stated by the associations proposing the complaint, over the last few years in Italy the control over crimes against fauna has increased significantly, above all by a nucleus of the Forestry Carabinieri called SOARDA, an acronym which means Anti-poaching and Crimes Operational Section to the detriment of the Animals, which has carried out shipments to various areas of the country identified as "Black spots" in the approved Anti-Poaching Plan. These include the area of the Brescia and Bergamo hills, the Po Valley during the migration of the skylark, the Po delta and the Venice Lagoon, the Caserta area, etc. Added to this is the progressive reorganization of the provincial police forces , after the Del Rio law which brought the management of the fish-hunting guards back to the regions. Therefore, the statement according to which the National Anti-Poaching Plan is not applied is not true.
INTERPRETATIVE CIRCULAR ON THE EUROPEAN REGULATION CONCERNING THE PROHIBITION OF THE USE OF
LEAD AMMUNITION IN WETLANDS.
It should be noted that the undersigned Cabina has already highlighted to the competent Ministries the need to implement the contents of the European Regulation on the prohibition of lead ammunition in wetlands. However, the circular issued by the joint Ministries MASE and MASAF only clarifies that ephemeral flooding due to rains are not included in wetlands, according to what has already been established by the European Court. The same circular clearly states that all wetlands classifiable as Ramsar areas are included in the areas where lead is prohibited, in complete analogy with the provisions of the European Regulation; therefore, it is not clear how this circular would have "strongly reduced the scope of the ban through a limited and incorrect definition of wetlands". Again, this is an untruthful statement.
PROJECTED IMPACT
From the foregoing, the speciousness of the request by animal-environmental associations, which in reality pursue an ideological aim of restriction or abolition of hunting, is demonstrated through statements that do not comply with the regulatory framework of Directive 148/2009/EC and its interpretative documents. The undersigned control room hopes that the European Commission and the national authorities objectively evaluate the contents of the request and the resolutions of the regional calendars, which demonstrate total adherence to the principles of protection and "wise use" of European bird populations.
Unified control room of the hunting world
(Federcaccia, Enalcaccia, ANLC, ANUUM Migratoristi, Italcaccia, CNCN)
Massimo Buconi – FIDC President
Lamberto Cardia – President of Enalcaccia
Marco Castellani – President of Anuu Migratoristi
Gianni Corsetti – President of Italcaccia
Maurizio Zipponi – CNCN President
Paolo Sparvoli – President of the ANLC