Grundet den helt uacceptable situation omkring generelle reguleringstilladelser som SGAV har tilladt private lodsejere i Oksbølområdet, som planer om at give husdyrholdere og jægere en generel tilladelse til at skyde ulve, uden myndighedernes tilladelse i de enkelt tilfælde, har Ulvetid dels sendt en klage til EU-kommissionen, og dels skrevet en henvendelse til kommissionen om med en forespørgsel om at få et møde hurtigst muligt.

Dear Mr. Cyril Ritter

I am the chairman of a wolf conservation association Ulvetid, in Denmark. We are facing an urgent problem, which is why I contacted my Swedish colleague, Magnus Orrebrand, to ask whether he had any contacts in the European Commission whom I could approach. He suggested that I try to contact you.

The following management measures, which are incompatible with the Habitats Directive and a ruling of the Court of Justice of the European Union (CJEU), pose a direct threat to the Danish wolf population. I therefore hope that you can help arrange a meeting between the European Commission and the association Ulvetid as soon as possible in order to discuss these issues.

First, derogation permits are being issued for wolves in Denmark even though the number of wolves needed to achieve a Favorable Reference Population (FRP) has never been calculated. Danish researchers state that wolves are in a strongly unfavorable conservation status. Nevertheless, a large number of derogation permits are issued in cases where the authorities’ reasoning does not meet the requirements of the Habitats Directive and the relevant CJEU case-law.

The authorities have decided the following:

1.   All livestock keepers who have wolf-proof fencing may apply for a general permit to kill a wolf if it is found inside the enclosure with their animals. This means that wolves may be shot without the authorities assessing whether the specific circumstances in each individual case actually justify lethal control.

2.   Hunters are also granted a general permit to kill a wolf if, in the hunter’s own assessment, it comes too close to their hunting dog, or if the hunter considers the wolf to be a danger to the dog. In practice, the hunter’s subjective assessment is the only basis for deciding whether the conditions for killing a wolf are fulfilled. The authorities thereby grant hunters a general permit to kill wolves without having assessed the individual situation, which is incompatible with CJEU case-law.

3.   A wolf pack in an area of Jutland has apparently been habituated through feeding. Danish specialists have concluded that two pups from the 2025 litter have become unusually bold. One pup has been shot. The authorities have now authorized private individuals to shoot a wolf encountered in their field if it is closer than 30 meters and, in some cases, even if the wolf is further away than 30 meters. This is a general permit issued without any professional assessment of wolf behavior, and wolves may be shot solely on the decision of landowners with hunting licenses. This is particularly problematic because the wolves currently have small pups. If one of the parents (which have not themselves caused any problems) is shot, the consequences for the pack could be catastrophic. This is a realistic risk, as the problems have so far been caused by the one-year-old offspring that are now leaving their parents’ territory.

Best regards

Ole Pedersen

Chairman

The association Ulvetid