May 7, 2016
my Complaint Letter about excessive lynx & wolf killing in Latvia.
best, Mareks Vilkins
Latvia and its government (Cabinet of Ministers, The Ministry of Environmental
Protection and Regional Development, The Ministry of Agriculture, The State
Forest Service, and Nature Conservation Agency) have breached the Habitats
Directive (Council Directive 92/43/EEC of 21 May 1992 on the conservation of
natural habitats and of wild fauna and flora) as they allow wolf hunting at 43%
of its population annually. The wolf (Canis lupus) is a protected species in the
European Union's member state; Article 16 of the Habitats Directive states:
1. Provided that there is no satisfactory alternative and the derogation is not
detrimental to the maintenance of the populations of the species concerned at
favorable conservation status in their natural range, member states may derogate
from the provisions of Articles 12, 13,14 and 15 (a) and (b);
b) to prevent serious damage to crops, livestock, forests, fisheries,
water and other types of property;
c) in the interests of public health and public safety, or for other imperative
reasons of overriding public interest, including those of a social or economic
nature and beneficial consequences of primary importance for the environment;
e) to allow, under strictly supervised conditions, on a selective basis and to a
limited extent, the taking or keeping of certain specimens of the species listed
in Annex IV in limited numbers specified by the competent national authorities.
None of these conditions have been met by Latvia's authorities.
Latvia is one of the few European Union member states where hunters regularly
kill not only local wolves but also those who are coming in from Estonia,
Lithuania and Russia. The hunting season in Latvia goes on for almost nine
months (July 15 – March 31) and hunters are killing two months old pups and
pregnant females. The killing of wolf pups was a dominant feature of the
2013/2014 hunting season – from July through September hunters killed 113 wolves
and 74 of them were pups (in total 292 wolves were killed).
It is well known in wolf biology and ecological literature that wolf populations
start to decrease as annual wolf killing exceeds 30-35% of population size.
For 17 consecutive years 43 percent of the wolf population is killed each year.
Therefore, it is suspected the reason Latvia still has a population of 200-300
wolves post-hunting season is due to migration from the neighbouring countries
of Estonia, Lithuania, and the Pskov region of Russia. In the last two seasons
the wolf quota was set at 300 and this did not account for wolves killed by
The total length of Latvia’s shared border with Estonia, Lithuania and Russia is
1200 km. To ensure a population of 200-300 wolves after the hunting season
harvest of 300, Latvia needs 60-95 breeding pairs. Assuming the average wolf
dispersal distance of approximately 100 km, it follows that Latvia will
regularly receive migrating wolves from 120 000 square kilometers of bordering
countries. It is likely that every year 20 breeding pairs migrate into Latvia
from neighbouring countries; an average litter size of six pups would result in
120 pups (this is without compensating for the average pup losses of new
litters). The number of pups from new litters are used to compensate for the
excess to Latvia’s harvest quotas, and Latvia’s officials are then able to claim
to the European Commission that they have a sustainable wolf policy and adequate
In the 2013-2014 hunting season 70% of wolves were killed in a 50-60
kilometer-wide border zone. This accounted for 204 out of the total harvest of
292 wolves. Ninety-five wolves (or 33%) were killed along the Lithuanian border,
79 wolves (27%) were killed along the Estonian border, 20 wolves (7%) along the
Russian border and 10 wolves (3%) along the Belarus border.
In the 2014-2015 season 88% of wolves were killed in a 50-60 kilometer-wide
border zone. This accounted for 236 out of the total harvest of 267 wolves. One
hundred and twenty-two wolves (or 46%) were killed along the Lithuanian border,
55 wolves (21%) were killed along the Estonian border, 48 wolves (18%) along the
Russian border and 11 wolves (4%) along the Belarus border.
In brief, 200-300 wolves can be easily secured by 15-30 incoming / breeding
pairs from Lithuania, Estonia, and the Pskov region in Russia after the nine
month wolf hunting season is closed on 31st March. On average, every pack has
3-5 dispersing wolves; those 15-30 breeding pairs can be recruited from 12-20
packs along the border in neighbouring countries.
Note that the wolf killing quota increased only when populations in Estonia,
Lithuania and Russia's Pskov region increased. Prior to that, Latvia's hunters
were unable to kill 150 wolves in nine months. Now they kill 250-290 in nine
months, but that increase of an additional 100-140 wolves can be 'compensated'
by the additional / extra 30 breeding pairs (if 3 pups per litter survive then
30 x 3= 90 ; if 5 pups survive then 30 x 5 = 150).
Dr. Janis Ozolins, who is monitoring wolf population in Latvia, cannot
scientifically prove that there are no migrating wolves from Estonia, Lithuania
and Russia. And his sample of 80-100 wolves is too small to be scientifically
robust especially in regard to the breeding females subset. His sample size of
about 10 females is too small to be statistically significant.
Public input on wolf management was not allowed when Latvia was admitted to
European Union in 2004. No alternatives to extreme wolf killing were considered.
A few officials, including Dr. J. Ozolins, made the decision unilaterally, and
now wolves are hunted with old Soviet-style ferocity. There is no change
,whatsoever, because April through mid-July, when hunting is not occurring, pup
morality is at its highest at approximately 50% of the litter.
The European Commission should demand that Latvia's authorities scientifically
validate that 200-300 wolves are maintained only due to migrating wolves from
Estonia, Lithuania and Russia. If they cannot provide supporting research that
wolf populations are maintained for reasons other than migration, then the
European Commission should deny 'favourable status' to Latvia's wolf population.
The burden of proof is on Latvia's authorities.
It should be noted that 200-300 wolves are not enough to fulfil ecological
functions in a forest ecosystem. The minimal number is 16 wolves per 1000 km2,
amounting to at least 480-640 wolves throughout the whole year.
To put the whole thing in perspective:
a) in Poland, wolf range is 61 5oo km2 and there are 1276 wolves (2014) or 20.75
wolves per 1000 km2
b) in Germany, wolf range is 12 -13 000 km2 and there are 250 wolves or
19.2 – 20.8 wolves per 1000 km2
c) in Minnesota (USA), wolf range is 70 000 km2 and there are 2221 wolves (2015)
or 32 wolves per 1000 km2
while in Latvia, wolf range is 30 000 km2 and there are 300 wolves or 10 wolves
per 1000 km2.
Regarding sheep depredation and wolf hunting in Latvia – a survey of the
regional press revealed that:
a) in 2012 out of 170 depredated sheep, at least 143 were killed by feral
b) in 2013 out of 174 depredated sheep, at least 129 were killed by dogs.
In public, officials with the Hunting Department of State Forest Service say
that all depredations are caused by wolves so that they can justify the increase
of the wolf quota.
An important criticism of the existing hunting pressure is the number of animals
injured — enough for the proportion (ratio) to be 1:1, that every wolf is either
injured or killed by hunters, or both, because 43% of wolves are killed
annually. Therefore one killed and one injured animal make ~90% of population.
Furthermore, one should weigh the few sheep taken by wolves against the damage
to the crops and forestry done by wild ungulates. It is estimated that 5% of
total crops and 10% of new tree stands are destroyed by abundant wild boar (Sus
scrofa), red deer (Cervus elaphus), moose (Alces alces), and roe deer (Capreolus
capreolus) populations. In 2015 moose have destroyed 7 000 hectares of
coniferous stands. Costs of regeneration and repellents amount to 8.5 million
euros annually. Ungulate-vehicle collisions amount to approximately 700 annually
with several people killed.
Few points about lynx hunting.
The harvest bag of shot lynxes consists of 1/3 of kittens + 2/3 adult lynx. So
if the harvest bag is 180, then on average 60 kittens and 120 adults were
killed. If the number of lynx who reach one year of age is 54, then the number
of shot adult lynx is almost two times bigger (~120). Therefore the lynx
population should be decreasing (not increasing).
Until 2012 Estonia had lynx density at carrying capacity and it is very likely
that young subadults could not establish their own territory there - so they
moved south to Latvia where they compensated Latvia's excessive killing rate of
However, Estonia's roe deer population was severely reduced due to harsh winters
in 2009 and 2010. Roe deer is the main prey species for lynx. As a
consequence, lynx numbers in Estonia dropped from 103 females with kittens in
2011 to 46 females with kittens in 2013. As a result, fewer lynx now arrive from
Estonia and if Latvia’s hunters continue to shoot 20-25% of lynx population
annually, they will reduce adult lynx numbers in a short time period.
In 2015/2016, a quota of 150 lynxes was permitted in Latvia, but only 115 lynxes
have been killed after four months of the hunting season (4/5 of all lynx are
shot in an area which has a shared border with Estonia and this winter snow has
been present for at least 3 months - snow is a necessary precondition for
successful lynx hunting as lynx are solitary animals who do not make
sounds the way wolves do).
As monitoring is lagging two years behind the actual situation on the ground,
and if Latvia will not reduce the hunting bag/quota, then it seems that Latvia
will go Estonia's way when lynx numbers dropped from 103 females with kittens in
2011 to 46 females with kittens in 2013 — as there are no more incoming
subadults from Estonia in significant numbers.
No sheep killed by lynx in Latvia.
“The Baltic lynx population” is reality only on a paper [for the EC bureaucrats]
as there is no mating and therefore genetic connectivity among Estonia’s and
Lynx harvest bag in Estonia:
2008/2009 - 150 lynx
2009/2010 - 184
2010/2011 - 181
2011/2012 - 100
2012/2013 - 87
2013/2014 - 16
2014/2015 - 2
2015/2016 - 18
Lynx harvest bag in Latvia:
2008/2009 - 117
2009/2010 - 141
2010/2011 - 133
2011/2012 - 149
2012/2013 - 150
2013/2014 - 147
2014/2015 - 172
2015/2016 - 114
The number of breeding females in Estonia:
2008/2009 - 128
2009/2010 - 126
2010/2011 - 111
2011/2012 - 103
2012/2013 - 72
2013/2014 - 46
2014/2015 - 61
To raise international awareness about this institutionalized violence
against Europe’s Protected species (wolf) in Latvia we have started
a petition: „Stop killing wolf pups and shorten wolf hunting season in Latvia”
We request that the European Commission :
1) provide a rationale for why it allowed wolf & lynx hunting in Latvia in the
first place (when Latvia entered / was admitted to the European Union in 2004).
Wolf and lynx killing is not legitimate in Latvia as 70% of the population lives
in cities, gets their food from agriculture, and rejects unnecessary violence
against wildlife. They would be shocked to learn that hunters kill kittens, pups
and pregnant females. It's possible only because they are unaware of it due to
silence from the mass media.
2) commission a Science Review of wolf and lynx monitoring in Latvia.
Currently the litter size estimate is based on placental scars which
overestimates the real reproduction and recruitment in lynx population. On the
one hand, abortions and very early mortality are not considered; on the other
hand, the very high difference between first-time breeding females and older
females indicate that older scars (scars from earlier litters) are counted too,
which leads to an overestimation of the litter size in females >3 years old.
An additional and independent data set would be most welcome to serve as a
control for the present monitoring system.
3) demand that Latvia introduce wolf and lynx monitoring based on non-lethal
Remainder of letter in MS Word documents here:
lynx hunt in Latvia and here: wolf hunt in