Decemmber 7,
2004 Our NGO
have been involved in different aspects of nature conservation (with
special regard to the Hostýnské vrchy) for more than 10 years and we
dispose of high number of data on resident biodiversity. Based on above
mentioned facts as well as comments and experiences of those experts
that participated on NATURA 2000 mapping project, together with our
best knowledge of the state of particular sites, we call for subvention
to European Commission, Environment Policy. Concerning
first site (including of Hostýnské vrchy-Kelčský
Javorník) Our attitude:
If only the state of documentation completion, instead of habitat quality,
should play a crucial role in proposing a natural habitats as SACs,
the whole NATURA 2000 would lost a substantial part of its sense. The
network would thus exclusively consisted of the sites that had complete
required documentation to particular date. Nevertheless, the above-mentioned
situation is in direct conflict with Habitat Directive (92/43/EEC). Concerning
second site (expansion of Rusava-Hořansko site) Our attitude:
Indeed, the discussion with owners of the proposed site have not been
conducted so far, but this only reason should not prevent the very important
site from possibility of being included into SACs. Since the priority
habitat (unique in the whole region) type occurs within the site, it
has to be included into NATURA 2000 sites. The above-mentioned disjunction
is absolutely irrelevant with respect to any legislation. Although there
is an accepted SACs in close proximity of by-us -proposed site, it does
not include this site. Thus, the proposed action would involve only
extension of existing pSCI. Setting different conservation statute via
different institutions is at odds with logic or even common sense, since
two separate areas of (different - level of) special protection would
exist in very close proximity. 1. Hostýnské vrchy-Kelčský Javorník (the name according to pilot mapping), not included in Czech National list of pSCI (SACs). Nature habitats occuring at the site (cca 70-80 % of total area) are listed in tab. 1. Tab.1: Main habitat types
"*"
indicates priority habitat types. The site fulfills all national criteria (i.e. sufficient size for preserving autoregulation ecosystems' function, highly representative with respect to structure and function and perspective from the conservation point of view) to be listed as a SAC in Czech National List of SACs of NATURA 2000 network (according to Annex I of Habitat Directive). When compared with other existing (proposed) SACs in the region (such as Ondřejovsko- CZ0720029, 1305.94ha in size), regarding local specifics, the site is comparable or even of higher quality. Precisely the same summaries may be inferred when comparison with other (putatively more important) sites, e.g. Chřiby - CZ0724091 (size 19 226.40 ha, including extensive spruce monocultures) are made. We propose three solution variants (first one regarding as optimal one): a) from the point
of integrity view, we propose single site "Hostýnské vrchy-Kelčský
Javorník" to be included in SACs national list and to set a conservation
priorities with respect to natural habitats (see tab. 1). Proposed conservation
status: nature reserve, area of the site is about 2500 ha (see map appendix
P1-HV-KJ-varA). Tab. 2:
"*" indicates priority habitat types. In the proposed site occur following species: Annex II. Lesser
horseshoe bat (Rhinolophus hipposideros) Annex IV. Carabus
variolosus Another at least 60 species of vascular plants listed as endangered according to Czech Red and Black Books, respectively, are known to occur in the site. Note: Whole area is listed as a Bird Area according to Bird Directive (79/409/EHS) for the protection of bird species fixed on beech forests. Other species of Annex I-IV are also known to occur in the area. Summary If the proposed site(s) are not included into SACs (or at least its substantial part), considerable threat of diminishing of particular natural habitats (mostly 9130 Asperulo-Fagetum beech forests and 9110 Luzulo-Fagetum beech forests) is very probable via replacing them with spruce plantations (X9A) or mixed extensive forest plantations. All known consequences on local biodiversity are inevitable, even when existing restrictions are taken into account. The main goal of the protection should be prevention from such trend by setting of conservation priorities that enable forest management sensitive to local natural habitats. Existing legislative tools in the Czech republic do not facilitate these needs (except small-scale reserves). Thus, proposed solution represents the only acceptable way. 2. Rusava-Hořansko site (CZ0720185) expansion The site
is in national list of pSCI. Nevertheless, the complex of meadows in
close proximity including priority habitat type 6230, T2.3 Species-rich
Nardus grasslands on siliceous substrates in mountain areas (and submontane
in continental Europe), (Annex I) was not included. Moreover, vital
population of Juniper (Juniperus communis) is present. The above- mentioned
habitat represents if not the most valuable, then at least one of the
most valuables natural habitats within proposed site proposed by us
(after expansion of existing pSCI). The proposed expansion is depicted
in map appendix (P3-Rusava).
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