The Swedish Environmental Protection Agency's consultation input to the new regulation on damage reduction

The Swedish Environmental Protection Association is not unanimously positive about the proposed changes to the game regulations.

The Swedish Environmental Protection Agency's consultation input to new regulations on the reduction of damage, on dead game and on the use of game in farming, research and zoos (the Game Regulations)

This summer, the Norwegian Environment Agency submitted for consultation new regulations on the reduction of damage, on dead game and on the use of game in farming, research and zoos (the Game Regulations). The consultation version of the game regulations can be read here: The Norwegian Environment Agency - The Game Regulations

The Danish Environmental Protection Association does not unanimity agree that the proposed regulatory change will be a good thing, neither for fauna, hunters nor Norwegian game management.

The consultation note from the Norwegian Environment Agency, which had a deadline for input only on 1 October 2019, was extended to 15 October 2019 and can be read here: The Directorate of the Environment - Consultation note wildlife regulation

The regulations are intended to be a compilation of four existing regulations that regulate the capture, removal, keeping and releasing of game, and the handling of dead game. In addition, the regulation regulates the taking of game that has been delegated from the Norwegian Environment Agency to municipalities and county officials. This point is probably what the NMF reacted to the most, where the damage removal requirements are relaxed and open for damage reduction of a number of new species. The regulations bring together all the provisions that deal with the management of game, except the provisions on harvesting (hunting and trapping), on the management of wild game and on alien organisms.

The starting point is that the provisions and principles in wildlife management are continued in the new regulations, and that the gain from bringing the regulations together is primarily a more systematic, harmonized and modern regulation. A distinction has also been incorporated between game that occurs naturally in Norway and game of foreign species. The provisions on the keeping of foreign game species are moved to regulations on foreign organisms.

The Swedish Environmental Protection Agency's consultation statement can be read here: NMF Hearing statement

1. 1. The NMF cannot accept that game is used for branding hunting dogs.
   2. Catching game for display or breeding is not acceptable.
   3. Hunting of small game as proposed is not acceptable, NMF requires a separate felling permit for each case.
   4. Releasing game for hunting purposes is not acceptable.

1. Capture of game and holding for display.
   The NMF cannot accept that it is opened for the capture of game for display in zoos.
   Animals and birds in the Norwegian fauna have an intrinsic value and function in our fauna which must be respected. Putting game in cages or enclosures will be very stressful for the game, and far more stressful for wild animals and birds than for animals born and raised in captivity.

   The exception may be game that has been injured and through its convalescence has become used to people, foreign species, such as e.g. mink, raccoon and Canada goose, where the game can be used for research purposes and to increase people's knowledge of the species. These species are very damaging to our fauna, and increased knowledge about the species will be positive for our fauna. Studying an alien species in real life is better than only seeing them on photos or film.

2. Keep fox for dog training
   The purpose of the proposal is to train hunting dogs, for use in searching for damaged foxes and in other hunting/removal of foxes. The NMF suggests that foxes from fox farms or other breeding be used to the extent that there is a need to train hunting and search dogs on live animals, which should be avoided as much as possible for animal welfare reasons. The NMF cannot see that such training corresponds to the high ethical focus achieved by Norwegian hunters and game authorities. Such a practice to an extensive extent could damage the reputation of everyone who hunts in Norway, something that should be taken seriously at a time when hunting is constantly losing ground to an increasingly urban population.

3. Felling and other taking of game
   The case opens up the possibility of killing a number of species in our fauna. Ola and Kari Nordmann, whether they are farmers, fishermen or A4 people, must accept that they have a living and often loud fauna around them, You should be satisfied that you get as close to animals and birds as you do in this country. Norway today has a rich fauna, but here at home we are also beginning to see the consequences of human activities. Climate change, destroyed habitats, poor access to food and e.g. unintentional bycatch in the fisheries has led to a decline in a number of Norwegian species, including a number of bird species. Very many of the small bird populations have shown a decline in their populations in recent years. Is it then right to allow hunting and/or free felling of these proposed species? The boundaries for the intrinsic value of animals and birds are constantly being pushed, and society is paying less and less attention to the nature around us. Every time human interests collide with nature, birds, animals or other fauna, it is the human interests that are trumped through. What is damage? When can one rightfully claim that small birds cause so much damage that there is an absolute need to shoot them? NMF believes that everyone must be able to have a high enough threshold in relation to our fauna, to accept the fauna that may be found in the local environment. Facilitating the shooting of hungry seagulls or hungry animals and birds is unacceptable. The NMF is terribly afraid that there will be sport in hunting these species. There are still some who like to practice shooting at anything that moves, opening up hunting/killing as proposed will make it both easier and more accepted to kill our fellow creatures for their own amusement.

   Instead, an application for a felling permit should be required in each case if necessary. The NMF cannot accept that it is opened for hunting/killing of several species of small game cf. proposals in the matter.

4. Release of game into the wild
   Ever since its inception in 1993, NMF has been a champion of preserving Norway's very long hunting, trapping and gathering culture. This is because we consider and recognize the harvesting of nature's surplus as the most environmentally friendly way of obtaining a dinner, of course provided that the hunting takes place on sustainable populations that can withstand taxation and that the hunting takes place as humanely and ethically as possible. We therefore have no objections to hunting wild populations that can withstand taxation and see hunting ducks and other harvestable small game under natural conditions as a good contribution to a healthy hunting culture that can be carried out by hunters from all walks of life, without necessarily having to pay for everything too much for the hunt. Duck hunting and other small game hunting is thus a good "beginner's hunt", which is and will be a valuable alternative for recruiting new generations of hunters. NMF sees the release of farmed game for shooting as a direct threat to the relatively positive attitude people in Norway have towards hunting compared to many other countries in Europe. As far as the NMF knows, there has also been talk of putting wild boar out for hunting, as we have been told this idea was stopped, but this shows that the industrial approach to hunting that can be traced elsewhere in Europe is also knocking on the door in Norway.

   NMF cannot accept the release of wild game into the wild for "hunting purposes". Any release of wild game could lead to genetic contamination in our fauna. Animals that are exposed are often farmed animals. These animals are not used to looking for food themselves and will suffer if released into the wild. Release of alien species in our fauna, e.g. pheasants for hunting purposes cannot be accepted. The fact that landowners rent out hunting is in itself completely unproblematic, it is when you become greedy and do not allow the carrying capacity of nature and the species to regulate hunting and start importing farmed game just to have something to shoot at̊ the whole thing crashes so monumentally with the Norwegian ethical platform hunting and Norwegian hunters operate from Importing game, releasing game in larger quantities than is natural for an area, conducting so-called "patent hunting for riches" that are stationed around specially made shooting ramps out in water, wetland areas and terrain and then renting this out as an exclusive hunt, is nothing less than a mockery of long traditions in Norway. The NMF recognizes that people in "higher social strata" have a busy schedule, and that traditional hunting can be time-consuming, but this form of hunting, on exposed farmed game, often frightened right into the laps of "hunters" posted on specially built shooting ramps, is so reminiscent of ordinary clay pigeon shooting that you can just as easily stand up on a shooting range and shoot clay pigeons with glued-on feathers. If this form of hunting is allowed to become established as a common practice in Norway, we are concerned that the entire hunting community in Norway will suffer, and you will quickly get a downward attitude towards hunting among the population. This means, in the long run, that there will be more active resistance to general hunting in any form, and you will quickly see declining recruitment in what has until today been a healthy, environmentally friendly, sustainable tradition that the people have helped to protect and look after. When hunting goes from being the harvesting of nature's surplus combined with nature experience and recreation, to pure shooting sports, Norwegian authorities should be vigilant and stop this development before it damages the reputation of hundreds of thousands of hunters and their practice of hunting, as in the vast majority of cases is characterized by high hunting ethics and follows good ethical guidelines.

For the NMF, it is absolutely fundamental that hunting should primarily be hunting, recreation and nature experience, as well as having a population-regulating function on well-reproducing and therefore sustainable populations. Not a pure shooting sport, where greed goes beyond the natural carrying capacity of the individual stock, and hunting is approached as a sporting exercise where the aim is to shoot as many individuals as possible. Nature should not be rich people's playground, where they can pay, manipulate stocks, breed and import individuals in the name of money and greed. Stock-increasing measures beyond normal preparation and game care do not belong in the Norwegian hunting environment, Norwegian traditions and do not correspond to the general perception of what constitutes sound hunting ethics.

NMF cannot see that the mentioned changes are of any good, either for fauna, hunters or Norwegian game management. Based on the above, NMF hopes that the Norwegian Environment Agency will turn around in time so that Norwegian animal welfare is not inadvertently weakened, contributes to weakened hunting ethics or puts Norwegian game management back in time.