Public Consultation for the inclusion of all Spanish populations of Iberian Wolf (canis lupus signatus) in the List of Royal Decree 139/2011. ClientEarth Written Allegations
DOCX | 77 kb
DOCX | 77 kb
This report contains ClientEarth's allegations for the public consultation initiated on May 19, 2021 by the Ministry of Ecological Transition and Demographic Challenge on the Draft Order amending the Annex to Royal Decree 139/2011, of February 4, for the inclusion of the Iberian wolf in the List of Wild Species under Special Protection Regime and the Spanish Catalogue of Threatened Species, regulated in Title III of Law 42/2007.
ClientEarth already submitted its allegations to the previous public consultation on this draft Ministerial Order on February 25, 2021, and we hereby refer to them in full.
ClientEarth has requested:
1. That this Ministerial Order be processed and approved, modifying the annex of Royal Decree 139/2011 to include all Spanish populations of the wolf (Canis lupus) in the List of Wildlife Species under Special Protection Regime.
2. Given the possibility that the criteria for the cataloguing as "Vulnerable" are already fulfilled, as indicated by the Scientific Committee, and based on the precautionary principle of article 191 TFUE, we additionally request that the Ministry compiles the technical and scientific information necessary to initiate the process of Cataloguing as Vulnerable, and if necessary, that the necessary studies and investigations on these aspects indicated by the Scientific Committee are commissioned by the Ministry.
3. That a state conservation plan/strategy be approved as soon as possible that includes all the necessary measures to guarantee the favorable conservation status of the Spanish populations of the species, and that in any case this order establishes a date for its approval.
4. That the single additional provision "Compatibility of existing measures" in its current wording be deleted from the order, as it is not in accordance with national and EU law.
5. That the inclusion of the whole Spanish wolf population in the List will take effect from the publication of the present order in the Official Gazette of the State.