Why a hunting moratorium?

The situation in the area of hunting in Montenegro has long been described as alarming, to the extent that the killing of non-game and even protected species has become our daily routine. A few days ago we witnessed a case of a female bear being killed, while the fate of the cubs is still uncertain. Also, there were two more cases of birds being shot, an Eurasian eagle-owl and a hawk, which we can add to the long list of known acts of poaching that have happened over the past few years. The latest events are the last straw and invite the competent institutions to act radically and strongly as soon as possible in order to tackle this problem.

The initiative for establishing a five-year hunting moratorium, signed by more than 60 organizations, was handed over to the Ministry of Agriculture, Forestry and Water Management and to the line minister Aleksandar Stijović personally. The prohibition of hunting, which we insist on, is the only way to allow enough time for implementation of an effective legislative and institutional reform of hunting, as well as to review the list of protected species and the duration of hunting seasons.

First of all, the problem lies in the very organization in the field of hunting. The Hunting Association and hunting organizations are mainly NGOs (38 NGOs and 3 public companies) that are affiliated with the Ministry of Agriculture. They have been entrusted with the management of the hunting grounds without the obligation to pay compensation to the state. Hunting organizations monitor wildlife by themselves according to poor protocols or even without any protocols, as evidenced by the differences and inconsistencies in wildlife data that are displayed every year. It is on the basis of such unreliable data that management and hunting plans are made. Also, the external mechanism of control of their work is completely absent, as it is performed exclusively internally, within the organizations themselves. In view of all the above, it can only be concluded that the system is ripe for complete reform.

Furthermore, the problem is reflected in the insufficient capacity to carry out regular activities of the hunting guard service, but also of the inspectors tasked with control. There are generally too few employed gamekeepers in each hunting ground, and there is often a lack of appropriate equipment for their smooth operation. On the other hand, the Forestry and Hunting Inspectorate employs 11 inspectors, based mainly in Podgorica. Most of them cover multiple areas, and are out in the field rarely or never. Insufficient capacities for inspection supervision and the lack of will to solve the problem of poaching within the hunting organizations themselves is evidenced by the fact that the inspection service filed only 39 misdemeanour complaints in the period between 2013 and 2018. There are no controls in the early morning hours, when game activity is at its peak and when poaching mainly occurs; instead, inspection services are active exclusively during working hours from 7 am to 3 pm.

Education and raising awareness of the consequences of poaching is not necessary for the general public only, but also for those who are in the gatekeeping services, inspection services, prosecutor’s office and all other levels within the system. For example, the gamekeepers in Lake Skadar National Park first encountered a game call in September 2020, when they went out in the field at our invitation, claiming that their part of the job should only concern fish poaching, unaware that the control of hunting and poaching of all groups of organisms must also be within their responsibility.

The situation is further complicated by the increasingly intensive development of hunting tourism, which is flourishing without any reports, registrations, bringing income directly to local hunters who organize it, while on the other hand, the killed game is being smuggled. A concrete example is the case from Ulcinj, when the shooting of 100 quails was planned for foreign hunters three years ago in line with the hunting plan: in just one day in 3 hours we reported 3 game calls around Ulcinj Salina and counted over 360 shots. On this occasion, we were told that 5 Italian hunters were visiting, and according to our records that year, a similar visit was organized at least 4 more times. It is clear how quickly the quota is fulfilled, but it remains unclear: who is monitors, who controls and who allows this?

Also, illicit means are intensively used in hunting. Specific data from the field are: 49 sound baits (game calls), 38 plastic baits and 15 hunting baits have been registered by CZIP in the last 3 years!

Attempts to amend the Law on Hunting and Wildlife were made in an extremely non-transparent manner, both in terms of drafting the document and in terms of public consultation, considering that Coalition 27 – a network of NGOs monitoring Chapter 27 – was not informed or involved in the process, despite the fact that this was the implementation of the measure from the National Strategy for Transposition, Implementation and Enforcement of the EU Acquis on Environment and Climate Change. These changes have been suspended as a result of our timely notice to the European Commission about their non-compliance with the EU acquis.

Last July, Montenegro adopted the Rome Strategic Plan, based on the Bern Convention, under which it committed to reduce the rate of poaching in the country by 50% by 2030. Due to our commitments to the conventions we are party to, to the European Union, and above all to ourselves, our nature and the abundance of biodiversity that we have, it is necessary to introduce a hunting moratorium in order to:

– carry out the reform of hunting and perform a thorough restructuring of hunting associations and societies, whose gamekeepers are not up to the task and are not able to control the hunting grounds;

– create a sustainable system that will not function on the principle of someone being the judge and the jury at the same time;

– organize appropriate monitoring, and above all establish a baseline record of game in the hunting grounds by professional and credible institutions with the aim of obtaining data on the actual numbers of populations;

– strengthen the capacities of the hunting inspectorate, rangers of hunting organizations and the National Parks of Montenegro, police, customs, prosecutor’s office and the judiciary;

– tighten up the criteria for issuing new hunting permits and renew the existing ones, which would renew the knowledge of all hunters and draw attention to important articles of the law;

– educate the local population in all hunting grounds.