The Latvian Orienteering Federation (LOF) categorically objects to the draft regulations "Price list of public paid services of the Nature Conservation Agency", put forward by the Nature Conservation Agency (DAP), which would introduce a charge for holding public sporting events in nature areas managed by the state.
Following the decision by the Ministry of Smart Administration and Regional Development to reduce funding for the Nature Conservation Agency, DAP intends to collect a participation fee for holding public outdoor events in specially protected nature areas where state property under DAP's management is used. DAP has submitted a price list to the government for approval; its Article 15 provides that an event with between 100 and 200 participants will cost 110 euros, while an event with 201 to 500 participants will cost 300 euros. An event with 501 to 1500 participants will cost 700 euros, an event with 1501 to 3000 participants is set to be charged 1600 euros, and where the number of participants exceeds 3000 the charge is set at 3030 euros. The fee will not apply to events with up to 99 participants, nor to large families, nursery school children, schoolchildren and students.
Although the areas to which the participation fee will apply amount to just under 1% of the whole of Latvia (DAP has calculated that in 2025 there were 45 events in these areas that the price list would have covered), it will affect orienteering most of all, because it is precisely in these areas, with their natural forests, exciting terrain and established infrastructure, that orienteering competitions take place. It will particularly affect Gauja National Park – one of orienteers' favourite areas, and the venue of the 2018 World Orienteering Championships. It is in the ancient Gauja valley that Latvia's largest orienteering centres have historically grown up, as the statistics show – the orienteering series run by the Sigulda, Cēsis and Valmiera orienteering clubs are the best attended, with more than 150 orienteers taking part in competitions there on weekday evenings each week.
These orienteering series are not commercial events; their organisers make no profit, and the participation fee covers the organisational costs of the competitions (fuel, map printing, technical equipment). The participation fee is symbolic (from 2 to 7 euros, and free for children in many places) because the aim of these series' organisers and of the LOF as a whole is to promote a healthy lifestyle, to draw the public towards physical activity, to introduce people to nature and also to educate the public about nature conservation. And it is orienteers in particular who have an interest in preserving natural diversity, because nature is the very environment in which orienteers pursue their sport.
Now there are plans to collect a participation fee for holding public outdoor events in specially protected nature areas. The Latvian Orienteering Federation is at a loss over such a plan, and voices concern that introducing this charge would to some extent penalise precisely that part of society which promotes both the conservation of nature and a healthy lifestyle.
"At present DAP plans to impose a charge on only a small, organised and sportingly active part of society, completely ignoring mechanisms for collecting an infrastructure maintenance fee from other visitors to these areas on an equitable basis. There are thousands of anglers who actively use the resources of the river Gauja, there are individual hiking enthusiasts, there are the many hundreds of spectators at car rallies, berry and mushroom pickers, as well as the huge flows of canoeists in summer, not counting foreign tourists. Visits by these and many other parts of society together amount to hundreds of times more visitors than the participants in orienteering competitions, and leave an incomparably greater impact on natural assets and on DAP infrastructure, and this does nothing to foster equitable fairness in society regarding the use of DAP infrastructure. We are in favour of nature conservation, but we object to this DAP plan, because this charge will be a new kind of tax on a healthy lifestyle. That is to say, the fee is applied to the organisers and participants of an event who are in effect 'caught red-handed', because they are taking part in officially organised competitions. The organisers of orienteering competitions are to some extent being penalised for using these areas, and moreover for tidying them up both before and after the competitions," stresses LOF president Juris Žilko, adding: "If a charge is collected as a 'service', it must be clear what service is being provided. The organisers of orienteering competitions do not receive any special infrastructure, cleaning work or additional service. This raises the question of whether this charge is not in fact a new kind of levy on moving about in nature?"
In objecting to this DAP plan, the LOF has sent a public letter to the Ministry of Smart Administration and Regional Development (VARAM), the Ministry of Education and Science (IZM), the Ministry of Health, the Ministry of Justice, the State Chancellery and the Sports Subcommittee of the Education, Culture and Science Committee of the Saeima of the Republic of Latvia.
The letter stresses that the LOF represents more than 40 sports organisations and tens of thousands of orienteering participants throughout Latvia – children, young people, adults and seniors who regularly take part in sport outdoors. The LOF considers that the proposed regulation is legally unfounded, contrary to the state's strategic priorities in public health and the development of sport, and also creates risks for the state budget and for the sustainability of European Union fund projects.
In this letter the LOF stresses that the proposed charge runs counter to the law on the Public Health Guidelines for 2021-2027, whose priority is to increase the number of people who take part in physical activity regularly. "The guidelines point to a critically high level of inactivity among the population of Latvia – only 9.5% of people take part in sport to a sufficient extent. Popular sporting events organised by associations are the main instrument for improving this figure. By introducing an additional charge for holding events in nature, the state creates a new financial barrier that directly makes participation in sporting activities more expensive, thereby deepening potential health problems in society," the LOF points out, taking the view that a charge for holding public sporting events in effect restricts the rights to a favourable environment and to the protection of health enshrined in the Constitution.
The LOF voices concern that restricting rights of public access through a price list sets a dangerous precedent for restricting other public rights. "If the state allows an 'entry fee' to be charged for a group of people to move about on state land, this could lead to the gradual commercialisation of all the state's natural resources. That would be in flagrant contradiction with the interests of the people of Latvia and with a legal order in which nature is regarded as a resource available to all for ensuring health and physical and mental wellbeing, and not as a chargeable object for the upkeep of the state apparatus," the LOF stresses in its letter, adding: "It is ethically and legally unacceptable to penalise the country's regions and their local communities for the fact that national natural assets have been preserved and are protected there. The state should support sports organisations that link their activity to nature education, popular sport and a healthy lifestyle in these areas, rather than using the status of specially protected nature area as an instrument for collecting additional funds from local community activists."
The LOF therefore calls for Article 15 to be deleted from this draft DAP price list as legally unfounded and economically ineffective, and also proposes setting up a permanent cooperation platform between DAP, VARAM, IZM and popular sports organisations, in order jointly to ensure constructive dialogue and a balanced solution in the interests of nature conservation and public health. "The LOF fully understands that funds are also needed for maintaining the infrastructure of specially protected nature areas. However, so that the public interest does not suffer, the LOF proposes that this DAP draft should provide for the number of participants at which events and competitions begin to be charged to be raised to 250 participants. This means that the DAP price list would not apply to competitions with 249 participants or fewer. We propose that the charge should not apply to popular sporting events organised by local communities (associations), but instead we call for the draft to include a regulation that replaces the principle of payment with a transfer of responsibility. For example, by inviting agreement with these associations on a different form of involvement – taking over the maintenance of one of the sections of trail in a specially protected nature area, and also providing that any competition organiser is responsible for maintaining infrastructure during their competition. The principle being: leave the footbridge, the steps, the fence and any other item of infrastructure in the same or better condition than before the competition," proposes LOF president Juris Žilko.