The Latvian Hunters Association (LATMA) has reviewed the amendments to Cabinet of Ministers Regulation No. 82 of 11 February 2014, "Regulations regarding state fees for forestry and hunting activities" (21-TA-262).

LATMA emphasises that the version of the draft regulation sent to the Cabinet of Ministers was not coordinated with the non-governmental organisations representing hunters; therefore, LATMA categorically objects to the further progress of the draft regulation, citing the following objections:

1. Given that the Ministry of Agriculture has not taken into account the conditions agreed upon in the working group within the draft regulation, LATMA categorically objects to the amounts mentioned in sub-paragraphs 3.7.1 and 3.7.3. Taking into account the increasing scale of damage caused by game ungulates and the fact that hunting collectives are granted up to 200 hunting permits, raising the fee for elk and red deer hunting permits will lead to hunters not collecting all the allocated permits and failing to fulfil the set hunting quotas, simply because a hunting collective that has the status of an association does not have such funds. Unfortunately, in certain cases, this will also lead to poaching.

2. LATMA expresses its objection to the wording of sub-paragraph 3.8.1. Firstly, by introducing such a fee for foreigners' right to hunt in Latvia, our country becomes one of the most expensive European Union countries in this field, which will not promote tourism or the desire to come to Latvia for hunting. If there is a choice, hunting tourists will go to hunt in Lithuania and Estonia, as in the former there is no fee at all for the right to hunt in the country, and in the latter, a foreign hunter pays the same fee as Estonian citizens.

Secondly, we point out that Article 9 of the Treaty on European Union stipulates that in all its activities, the EU shall observe the principle of the equality of its citizens, who shall receive equal attention from its institutions and bodies. Therefore, it is discriminatory to set a higher fee for a hunter's seasonal card for European Union citizens than for Latvian citizens.

We point out that when drafting this regulation, there were practically no consultations with the sector's non-governmental organisations. The Ministry of Agriculture invited us to only one working group meeting, where the agreement reached was ignored when submitting the draft regulation to the Cabinet of Ministers. Such action is contrary to the Memorandum of Cooperation between Non-Governmental Organisations and the Cabinet of Ministers, the goals of which are to promote the operation of public administration that is efficient and corresponds to the public interest by ensuring the involvement of civil society in decision-making processes.