Voicing interests and concerns

Voicing interests and concerns

Forest Policy and Economics 1 Ž2000. 357᎐366 VOicing Interests and Conc Erns: NATURA 2000: An ecological network in conflict with people Contribution...

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Forest Policy and Economics 1 Ž2000. 357᎐366

VOicing Interests and Conc Erns: NATURA 2000: An ecological network in conflict with people Contributions from: Bruno Julien, European Community Ž EU. Michael Lammertz, German Forestry Council Ž DFWR. Jean-Marie Barbier, Federation National des Syndicts de Proprietaires ´´ ´ Forestiers Sylviculteurs Ž France. Sandra Jen and Marta Ballesteros, World Wide Found of Nature Ž WWF. Caroline de Bovis, Feeration des Associations de Chasseurs de I’U.E ´´ Ž FACE. Coordinated by: M. Krott, Institute for Forest Policy and Nature Conservation, Georg-August University of Gottingen, Germany ¨

1. European Community policy for conservation issues in forests (Bruno Julien) The Community Nature Protection policy is intended to support EU forests and their owners to continue to play the important role of the safeguarding of Europe’s natural heritage and the maintenance of the environmental quality for all EU citizens. 1.1. Background Forestry, which is one of the major land use practices in Europe, has a key influence on environmental quality, not only through the well known functions of climate regulation, catchment protection and safeguard against erosion, but also by its contribution to nature protection and conservation of biodiversity. It is clear that the impact of forestry practice

on biodiversity has always been much lower than in the agricultural sector, resulting in a European forest patrimonium of which the largest part can be qualified as ‘semi-natural’. Yet there are few natural undisturbed forest areas remaining in the EU. Most European forests have either been planted or have been managed over long periods of time and ‘virgin’ or ‘old growth’ forest areas are limited to small patches in culture landscapes or to less accessible locations in larger forests. The Treaty of the European Communities does not provide for a comprehensive common forestry policy, but it does call for a high level of environmental protection and it requires environmental considerations to be integrated into the definition and implementation of other policies with a view to promoting sustainable development. Such environmental considerations include EU legislation for biodiversity and nature conservation, which require giving full consideration to measures for

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the protection and management of the remaining areas of native forests of high conservation value. For this reason, forests play an important role in the work of the European Commission.



1.2. EU Nature Conser¨ ation Legislation The principal EU laws for the conservation of forests of high nature value are the Birds and the Habitats Directives, adopted in 1979 and 1992. A key objective of these directives is the establishment of the NATURA 2000 ecological network of protected areas, resulting from scientific evaluation of lists of sites of Community importance proposed by Member States ŽMS.. Fifty-nine forest habitat types of European conservation interest are listed in Annex I of the Habitats Directive because they are rare or residual andror hosting species of community interest. These habitat types cover all naturally occurring forest types in the EU and are grouped in the following categories: 䢇 䢇 䢇 䢇 䢇 䢇

Western Taiga Oak and Beech forests Deciduous Mediterranean forests Sclerophyllous Mediterranean forests Temperate mountain conifer forests Mediterranean and Macaronesian mountain conifer forests.

1.3. Designation process of sites for the implementation of the Natura 2000 Network





The Natura 2000 network consists of Special Protection Areas ŽSPAs. designated by MS according to the Birds Directive Ž79r409rEC. and the Sites of Community Importance for the conservation of natural habitats and species ŽSCIs., as proposed by MS in the framework of the dispositions of the Habitats Directive Ž92r43rEC.. Most member states have submitted lists of SPAs which the Commission has in many cases judged insatisfactory by comparing them with existing scientific inventories of bird populations and habitats.





Most member states have started to submit the national lists of sites from which the selection of Special Areas of Conservation ŽSACs. will be made after their scientific evaluation and taking into account socio-economic consideration. The original deadline for the submission of these lists was June 1995. The evolution of the designation process for SPAs and SCIs in the 15 MS of the EU can be followed by the ‘Naturabarometer’, which is a graphical representation in DG Environment’s bi-monthly Nature Newsletter Žhttp:rrwww. europa.eu.intrcommr environmentrnaturer natura.htm.. After having consistently promoted dialogue with the member states about their failure to respect the deadlines laid down in both Nature Protection Directives and about the quality of the proposed lists, the Commission decided from June 1996 to make applications to the European Court of Justice against those Member States having failed to communicate to the Commission a complete national list of SCIs. Currently, 4 cases have been taken up by the European Court of Justice concerning Germany, France, Ireland and Finland. DG-Environment monitors the progress of Member States in designation of sites and completion of national lists through a process of peer review in specific scientific seminars at which experts from public and private bodies from all MS participate. According to the latest data available, progress still has to be made by Belgium, Austria, Denmark, Sweden, Ireland and the UK, as their lists were valued as ‘insufficient’. Germany has only recently started to transmit information in the required format, which held up evaluation of its data.

All relevant information concerning Natura 2000 is available on the Nature Website of DG ENV http:rreuropa.eu.intrcommrenvironmentrnaturerhome.htm. 1.4. Management of Natura 2000 sites Some of the NATURA 2000 sites will be unex-

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ploited nature reserves, but most of them will be located in areas where significant human activities have always existed and may even have contributed very much of to the creation of certain habitats of conservation value. Therefore, designation of NATURA 2000 forest areas is not intended as a block on economic activities in and around forests. Rather, the emphasis is laid on ensuring that such activities are compatible with the conservation requirements of the habitats and species for which the sites are designated. This is best achieved within the framework of management planning, the success of which will frequently depend upon the full involvement and support of forest owners and users. The NATURA 2000 network should ultimately present a sample of habitat types and species of Community interest, covering an estimated 15% of the territory of the EU. Forestry can also have an indirect impact on NATURA 2000. Therefore, afforestation and forest harvesting must be carried out in such a way that they do not negatively affect NATURA 2000 areas or other ecologically important sites in the Member States. 1.5. Instruments to promote en¨ ironmentally conscious forestry: 1.5.1. The LIFE nature fund The LIFE nature fund is a strategic tool for demonstration projects in Natura 2000 sites. Since 1992 there have been more than 180 LIFE projects involving forest and woodland habitats and species, covering a wide range of activities Žsee LIFE webpage http:rreuropa.eu.intrcommr lifer.. Many of these projects have involved partnerships between forest and nature conservation authorities, as well as NGOs and private landowners. As a result there is emerging a broad base of expertise and best practice in relation to the conservation and sustainable use of Natura 2000 forest sites. The following types of actions take place in forest projects under the LIFE programme: 䢇

Conservation andror restoration of relicts of natural forest habitats which have become





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rare in certain regions or are under special threats, such as swamp forests, alluvial forests and some specific mountain forest habitats. Biotope management targeted at maintaining or improving the conservation status of priority flora and fauna species occurring in managed forests. Reintroduction of extinct species, accompanied by compensation schemes for land owners and users, such as is the case for large carnivores.

The selection of acti¨ ities to be funded by the LIFE budget takes places once a year, after a public call for proposals. The project proposals are sent to Brussels by the national administrations and are then screened exclusively for their technical and scientific value. After this screening, the Commission submits a proposal for a joint financing decision to a Member States Committee 1.5.2. The Rural De¨ elopment Programmes The Rural Development Programmes under the new regulation 1257r99, give Member States the possibility to use continued Community support for the development of the economic, ecological and social functions of forestry and enable the Community to support the implementation of national and subnational forest programmes or equivalent tools. According to this Rural Development Regulation, Member States are required to have prepared National Forestry Plans or similar instruments which fully take into account existing international environmental commitments, especially regarding sustainability in the management of forests. The Rural Development Regulation gives MS the opportunity to make use of the Community budget for realizing their National Forest Plans, which will provide the instruments for forest development in each member state according to local requirements. It is up to the MS to decide how they will use the means of this Regulation to their advantage, for the promotion of forest functions and for the fulfilment of international obligations and treaties. Under the Rural Development Regulation, support may be granted to pri-

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vate forest owners or municipalities for the sustainable management and development of forests, the preservation of natural resources and the extension of woodland areas, with a view to maintaining the economic, ecological and social functions of forests in rural areas.

2. Participation and compensation as basic requirements for nature conservation (Michael Lammertz) The DFWR agrees in principle with the goals of the Directive as long as they do not lead to a limitation of property rights. The entrepreneurial freedom in forest management has to stay untouched. In case the management of FFH areas requires restriction to forest owner’s financial compensation has to be guaranteed. Priority has to be given to contractual agreements. Without participation of forest owners the goal of the Directive will not be implemented. The ‘Deutsche Forstwirtschaftsrat’, DFWR ŽGerman Forestry Council., was founded in 1950 to represent the interests of the forestry sector in Germany Žwww.dfwr.de.. The DFWR disagrees with the implementation of the Directive 92r43rEWG in Germany. 2.1. Danger for the freedom and responsibility of the forest owners Since more than 200 years sustainability is the guiding principle for forest management in Germany, forest owners in Germany manage their forests in a wise and responsible way respecting the dynamics of the natural resources and biodiversity of fauna, flora and habitat. The forest management in the past contributed to the biodiversity of our forests of today. In principle, forest owners agree with the goals of the Directive as it underlines a responsible management of natural resources. To achieve these goals the entrepreneurial freedom of forest owners has to be respected. Cooperation instead of regulation should be the rule. Forest owners missed the participation during the last few years. The designation of areas with

ᎏ and sometimes without ᎏ FFH-criteria was pursued in a ‘top-down approach’ partly without means of participation for the people who finally have the responsibility to manage these areas. The DFWR will pay great attention to the process of establishing management measures for the designated and accepted areas by the European Commission. It has to be assured that the forest owners participate in choosing the adequate management measures to avoid an unbalanced interpretation of the concept of sustainability. The DFWR is of the opinion that sustainable forest management ŽSFM. ensures in a balanced way the implementation of the objectives of FFH Directive and SFM has to continue without any restrictions. If nevertheless restrictions to SFM are unavoidable contractual agreements with forest owners has to be given priority. The European Commission and the national governments have to guarantee sufficient financial means and reliable programmes to meet the contractual agreements. In state forests restrictions must be considered in the economical balance of the state forest budget. Lack of participation for forest owners is the major deficit by the implementation of the FFH Directive. There are in addition a number of unclear definitions and wordings in the Directive that create confusion and pander to legal uncertainty and insecurity. No exact definition is for example given for ‘avoid disturbance’. The FFH Directive does not consider dynamics in the development and management of natural resources. The traditional attitude of nature conservationists and environmentalists is to keep the Status quo. This is slowly going to change as they begin to understand the reality of nature dynamics. The FFH Directive does not incorporate a proactive approach in that respect but supports obsolete Status quo theory. 2.2. Subsidiarity and compensation by the implementation The sound and balanced implementation of the

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FFH Directive requires clear definitions and wordings. In June 2000 the European Commission issued an official interpretation guide of Article 6 of the Directive. To some respect this guide helps to get a clearer picture about some definitions in the Directive. But it is only a non-binding document. The European Commission has to review the Directive 92r43rEWG in co-operation with the Member States. The publication of shadow lists by non-governmental environmental organizations tend to destroy the good relation between forest owners and ENGOs. Forest owners do not share this one sided approach to nature conservation. There is not justified argument to demand a certain percentage of protected areas in each country as the nature prerequisites are completely different. Quality has priority over quantity. Germany has listed the qualitative best areas to fulfil the objectives of the FFH Directive. The European Commission should in that respect not question the reliability of the official list handed in by the German government. The Directive clearly refers to the principle of subsidiarity. Each Member state has the responsibility to transpose the FFH Directive into national law. In a strict federal state like Germany this happens to be a difficult task. Each federal state in Germany has its own legislative rules. Each federal government needs to incorporate in their laws, regulations that foresee: 䢇 䢇 䢇 䢇 䢇



Consequences of the FFH-status. Participation of forest owners. Priority of contractual agreements. Means for financial compensation. Involvement of Forestry Commissions and Forest Owners Associations. Monitoring and report system.

2.3. Analysis of ecological and economic efficiency of FFH-areas There is an urgent need to analyze the costs of nature conservation. Research could play a major role in this aspect.

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Research needs to take the dynamics of nature conservation into account and develop sound and balanced visions for possible management measures to ‘avoid disturbance’ in the FFH areas.

3. Lack of means and participation within Natura 2000 (Jean-Marie Barbier) 3.1. Comprehensible goals The goals of the FFH directive are important for the sustainable development of the forests. There is no protest, or just little, concerning such goals in France. The public and the landowners agree on the general necessity of nature conservation as part of the wise use of the forests. The dangerous problems start with the insufficient means of the FFH program. There is complete lack of understanding and much protest against the means used on the European as well as on the French level. 3.2. Ignorance of landowners’ acti¨ ities The European level deliberately ignores landowners and land users Žfor example in the first part of article 4, inventory of sites.. It also ignores the fact that in Europe, a large number of ecosystems depend on human intervention concerning their conservation. Even though most of them may exist without any human intervention, the existence of such ecosystems or habitats in some places includes human intervention. So, in our countries, conservation of habitats means to intervene in human behaviour, which is impossible, if the persons concerned are not involved in the process right from the beginning. The FFH directive directly excludes such an involvement. With regard to the principle of subsidiarity the directive refers to the responsibility of each state to organize the participation and the implementation process on its own. This shortcoming of the program is a mistake which will endanger the success in practice.

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3.3. Insufficient national implementation The French level made the same mistake and added one more: Everybody in France claims that nature conservation will be reached by contract. This is a good idea and we agree on that, but not a single person in any place is ready to pay for nature conservation. There is no budget, no funds specifically assigned for the FFH directive. So under such circumstances, who is going to pay for it? Only the owners and the users will do so who, on the other hand, suffer from the economic situation concerning their own production. The economic burden for the landowners is not recognised by the program. That is why in France, a big opposition will develop due to the implementation of the FFH directive. Today, the situation is calm. Owners and users wait for an FFH law, which will be discussed in the beginning of 2001. But this conflict may start again, if there are no funds specifically assigned for the FFH directive and for specific actions demanded by the owners and the users during the implementation. The point of view of the latter groups is the feeling of a looming big mistake and waste. They are ready to contribute to the implementation of the directive. But the FFH policy does not offer sufficient incentives yet. The landowners do not only have to agree on constraints only. Nature conservation should not mean constraints for the users of the forests. Sustainable conservation must offer a way of life for the landowners, too. 3.4. Economic analysis by research The help of research should be to analyse the costs of nature conservation. The costs of specific treatments for nature conservation are already known. But the economic analysis has to include all productions, methods and practices which in the present economic situation cannot be achieved due to nature conservation. Looking at it from the other side, there is a deep gap in the economic situation between the land users situated within special conservation areas and those in other areas. Estimating this gap and developing new strategies to fill it and to secure sustainable

forestry in all areas is a big challenge for research.

4. A crucial program for Europe’s natural heritage (Sandra Jen and Marta Ballesteros) 4.1. Are the goals and the means of the FFH policy justified and effecti¨ e? The Habitats Directive is potentially the most significant initiative for nature conservation at European scale. By adopting this Directive in 1992, Member States committed themselves to protect Europe’s most threatened species and habitats. This is to be achieved through the establishment of Natura 2000, a European ecological network covering areas on land and at sea, and by promoting the sustainable management of the wider land and seascapes. The Habitats Directive is also the European Community legislation to implement the 1979 Bern Convention on the Conservation of European Wildlife and Natural Habitats. The importance of the Habitats Directive lies in the fact that it aims to ensure biodiversity conservation but also to promote sustainable activity supporting the conservation objectives of the Natura 2000 areas, rather than ruling out economic activities. Economic activities are not systematically excluded from the Natura 2000 network. Article 3 of the Directive provides for a network of sites enabling the natural habitat types and species habitats concerned to be maintained or where appropriate restored at a favourable conservation status in their natural range and paragraph 2.3 specifies that measures taken pursuant to the Directive shall take account of economic, social and cultural requirements and regional and local characteristics. The Habitats Directive should be seen as a tool to promote land use planning integrating nature conservation requirements. Management plans to be adopted for each Natura 2000 site in accordance with Article 6 of the Directive are particularly interesting tools to integrate biodiversity conservation objectives and local economic and social sustainable development. Outside of Natura 2000 areas,

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biodiversity conservation should be achieved by the sustainable management of natural resources, the establishment of systems for the strict protection of threatened species listed in Annex IV of the Directive and regulation of exploitation of Annex V species. The goals of the Habitats Directive are crucial if European countries want to secure their precious but ever-decreasing natural heritage. The European Environment Agency ‘Turn of the Century’ report ranks loss of nature as one of the big four global environmental challenges along with climate change, ozone hole depletion and desertification. The Habitats Directive is the comprehensive and effective tool needed to address this challenge on a European wide scale. It has had a strong impact on modernising and improving national legislation over the last 10 years. 4.2. How could the slow and conflicting implementation be impro¨ ed? However, 8 years after the Directive came into force, no Member State has fully met the requirements of the Habitats Directive, let alone within the legally binding timetable. The directive has been breached in many ways by not having properly transposed the provisions in the national legislation, by undertaking projects threatening important sites for listed species or by not notifying sufficient Sites of Community Importance for Natura 2000. But the Habitats Directive should not be seen only under this unfavourable light or as a too stringent instrument for nature conservation. Delays in implementation of the Habitats Directive are a result of the low priority given to this legal instrument since its entry into force both at Community and National level. This also resulted in an insufficient allocation by Member States of financial resources and staff for the implementation of this Directive within the legally binding schedule. WWF is acting to ensure that adequate priority is given to the implementation of the Directive in the member states as well as in the enlargement process. Different sectors opposed the Habitats Directive on the basis of misunderstanding of its objec-

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tives and implications. Many delays, and opposition, to the implementation of the Directive result from the lack of information about the Directive among the general public, stakeholders and decision makers. Europe’s citizens need to be better informed about Natura 2000 and its unique role in saving our natural heritage. They must also be convinced that designation of sites will not lead to a total ban on development. Instead, Natura 2000 should be seen as an opportunity for promoting new models of development, in particular in some of the EU’s most marginal regions. There can be synergies between nature conservation and economic and social aims. The sensitive management of natural resources to protect and sustain biodiversity requires labour and skills, including the experience and knowledge of local people. WWF with the Institute for European Environmental Policy carried out a series of case studies and prepared information dossiers on how to use the new generation of Structural Funds 2000᎐2006 for nature conservation. Consensus building and participation of local people will be particularly important when we come to the establishment of management plans for Natura 2000. The conservation measures to be taken in Natura 200 sites will depend on the site in question. Natura 2000 sites are selected for their existing rich biodiversity, therefore, in many sites relatively small adjustments in land use and farming, forestry, fishing or hunting practice may be enough to secure the ‘favourable conservation status’ of habitats and species. In particular cases, a fundamental reassessment of existing models of resources use is required, with important socioeconomic implications. Another important aspect to achieve the objectives of the Habitats Directive is the integration of nature conservation goals and biodiversity concerns in all aspects of land planning policies. Nature conservation requirements have been too often ignored when not actually sacrificed for the development of other policies such as the Common Agriculture and Fisheries Policies and transport and regional infrastructure developments. The effective integration of environmental considerations in all EU policies through the implementation of Article 6 of the Amsterdam

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Treaty is fundamental to secure a future for wildlife and their habitats in Europe. Lobbying by WWF on the issue of cross-compliance, in which access to the EU Structural Funds and CAP rural development plans is dependent upon Member States complying with the Habitats Directive, has brought about some response from governments. It is encouraging that the European Commission has selected the Habitats Directive to link it to structural funds payment out of the whole spectrum of EU environmental legislation.

and golf courses. Therefore, a strict application and monitoring of paragraph 6.2 and 6.3 provisions of the Habitats Directive is crucial as well as an integration of nature conservation goals in land use planning from the outset with the use of environmental strategic planning assessments. The socio-economic dimension of the implementation of the Habitats directive is also an important aspect for further study to ensure a consensual and effective implementation of the Directive. Management plans will properly achieve the objectives of the Directive only if they take into account these considerations.

4.3. Which contribution of research in economics and policy meets the demand of the stakeholders? The implementation of the Habitats Directive has been an opportunity to increase knowledge about the distribution of habitats and species in Europe. EU LIFE funding allowed for example to prepare inventories of habitats and species in Spain, Italy, Greece or Portugal. More research and monitoring activities need to continue in EU-15 and candidates countries to the EU. The series of expert seminars initiated in 1997 identified a high proportion of insufficiently represented habitat types and species in the proposed lists of sites for inclusion in Natura 2000. In addition, there are still important deficiencies among Member States regarding the number of sites included on the lists. If Natura 2000 is to be established without further delays, then it is critical for governments to correct any weaknesses identified in the first round of biogeographic seminars by sending their complementary list of proposed sites by the end of 2000. As a contribution to this research effort WWF carried out an initiative to identify additional sites on a representative sample of 25 habitats and 19 species. WWF together with the Irish Peatland Conservation Council, Liga para Protecc¸ao da Natureza, Mouvement Ecologique Luxembourgeois and Vogelbescherming NL identified 2326 additional sites to be proposed. It is also vital that sites included on lists of proposed sites of community interest are not damaged or degraded as a result of development projects such as dams, airport, roads, harbours

5. Sustainable wise use as a guarantee for FFHhabitats (Caroline de Bovis) The Federation of Hunters Associations of the European Union ŽFACE. was founded in September 1977 and represents today, through its national delegations from the 15 EU Member States and 11 other Council of Europe countries, some 6.5 million hunters. One of its objectives is to defend and represent the collective interests of its members at the level of the European institutions, ensuring that the hunters’ justified concerns are taken into consideration when legislation and policies are drafted. FACE wants to promote hunting, in accordance with the principle of wise and sustainable use of natural resources, as a tool for rural development, for conservation of wildlife and bio-diversity and for protection, improvement and restoration of wildlife habitats. When the ‘FFH’ Directive on the Conser¨ ation of Natural Habitats and of Wild Fauna and Flora was adopted in 1992, FACE, while welcoming the justified Directive’s aim of ensuring bio-diversity Žincluding ‘game’ species. at EU level through the conservation of natural habitats and the establishment of the Natura 2000 network, also perceived that the text has certain legal defects constituting major threats for the practice of hunting. FACE fully endorses the basic principle of this Directive, namely that wildlife conservation is best ensured by the protection of their habitats rather than by a regime of strict species protection. It

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pointed out from the start that habitat conservation is a cornerstone of hunting practice and that hunters have been busy conserving and managing Žsemi-.natural habitats and species, both inside and outside officially protected areas, well before the FFH Directive came on to the scene. Hunters are no longer merely ‘users’, but also ‘managers’ of nature, as illustrated by the large number of conservation actions and initiatives they are carrying out throughout Europe ᎏ such as FACE’s action in favour of the Slender-billed curlew Ž Numenius tenuirostris., one of Europe’s most threatened and least-known birds, genuinely in danger of extinction. FACE expresses its concern as far as site designation and management procedures are concerned. FACE is of the opinion that, at the designation stage, competent authorities of the member states pay insufficient attention to consulting the different countryside representatives. In most member states, selection has been based predominantly on scientific criteria, without due for the ‘economic, social and cultural requirements and regional and local characteristics’ specified in Article 2 of the FFH Directive. As regards management, Article 6 of the FFH Directive states that Member States inter alia have to ‘take appropriate steps to avoid . . . disturbance . . . in so far as such disturbance could be significant in relation to the objectives of this directive’. This article, apparently logical and inoffensive, is a particular cause of concern for hunters; if all forms of disturbance were to be banned in the Natura 2000 areas, the future of hunting as such would be under threat. FACE is all too well aware of the ruling delivered by the Court of Justice of the European Communities on 19 January 1994 ŽPreliminary Ruling ᎏ Case C-435r92. on the interpretation of paragraph 7.4 of Directive 79r409rEEC, according to which ‘it should be noted that any hunting activity is liable to disturb wildlife and that it may in many cases affect the state of conservation of the species concerned, independently of the extent to which it depletes numbers’. That is why hunters are extremely concerned to see their activity outlawed by the setting-up of the

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Natura 2000 network, even if hunting in principle has no negative impact on habitats conservation, on the contrary. For instance, in the Owenduff᎐ Nepkin Beg Complex, one of the habitat of the Red grouse Ž Lagopus lagopus scoticus. in Ireland which has been designated under the 79r409rEEC ‘Birds’ Directive as a Special Protection Area Žnow integrated into the Natura 2000 network., it has been shown that the management of the red grouse shooting ensures the long-term conservation of its moorland ecosystems, because it allows farming and shooting to co-exist, both symbiotically and economically speaking. FACE is convinced that one way to fulfil a better implementation of the FFH Directive is that the European Commission gives as much assurances as possible that the sites of the Natura 2000 network are not to be seen as sanctuaries where human activities, including hunting, angling, rural tourism . . . , would be forbidden but that in many cases such activities, having made an essential contribution to the ecological value of such semi-natural habitats, even must continue. This message should be repeated and the subject of an EU-wide information and awareness raising effort. Another way to improve the implementation of the Directive consists in fully involving the European organisations representing the rural actors Žhunting, fisheries, agriculture, landowners, forestry, . . . . in the process of selection, designation and management of Natura 2000 sites. In particular the European hunters whom FACE represents believe they should have the possibility to bring their specific expertise and knowledge in the ongoing bio-geographical seminars. It is clear that once hunters have received confirmation that hunting is in principle not incompatible with the Natura 2000 network and that they will be involved at all stages of the setting-up of this network, they will be amongst its strongest advocates.The European Commission, in its Communication COMŽ95. 189 final of 29.05.95 on ‘Wise use and conservation of wetlands’, acknowledged the positive role played by hunters in conservation of natural areas: ‘waterfowl hunting in European wetlands is a popular leisure acti¨ ity and can be an important source of

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income for wetland owners. Rightly, hunting associations are becoming an important dri¨ ing force for wetland conser¨ ation. The principle of using the waterfowl resource in a sustainable way can substantially contribute to wetland conser¨ ation. . . ’. A similar statement referring to Natura 2000 sites would be more than helpful to improve its implementation. It is unfortunate that the European nature conservation policy has been so far largely unable

to recognise the positive contribution of hunting and of the ‘conservation through wise use’ principle. Could it be that hunters, through modesty or a misplaced feeling of guilt, have been unwilling to explain their activity? One thing is certain: these 6.5 million European citizens have an essential part to play in nature conservation, outside and inside the Natura 2000 network. Far from being part of the problem, Europe’s hunters are part of the solution.