Response to interpellation 2025/26:543 on possibilities to appeal decisions on hunting
Translated from Swedish by AI; the translation may contain errors. The Swedish text is the original.
Summary AI, written in advance
The debate concerns the possibility for hunting organizations to appeal decisions on hunting. L argues that the right to appeal according to the Environmental Code follows from practice regarding ownership rights or usufructuary rights 1. L emphasizes that it is a routine administrative measure to ask hunting organizations to demonstrate their right to appeal 1 2. L explains that the main purpose of an environmental organization is to safeguard nature conservation or environmental protection interests 1 3. L believes that the process shows conflicts of interest that must be weighed collectively 4 and that the minister should not anticipate a decision in an ongoing administrative case 4. S argues that the government has not delivered policy in the hunting area 5. S wants the government to listen to hunters and examine whether a hunting organization with a state mandate is allowed to appeal decisions 5. S believes that the restrictions in Korpimäki are too harsh 5 and that the government has not answered questions regarding expanded hunting opportunities 6 7.
Written by AI in advance and may contain errors. The numbers lead to the speech a statement builds on; check against the text below.
Arbetsmarknadsminister och vikarierande klimat- och miljöministern Johan Britz (L)
Madam Speaker! Marie Olsson has asked me if I have conducted an analysis of the hunters' role when it comes to safeguarding nature conservation and environmental protection interests and if I can, in that case, report on the results. Furthermore, Marie Olsson has asked if I have conducted an analysis of the hunting organizations' possibilities to appeal decisions concerning hunting opportunities and if I can, in that case, report on the results. Finally, Marie Olsson has asked if I am prepared to take the initiative to review the legislation to ensure that hunting organizations have the possibility to appeal decisions concerning hunting opportunities in nature reserves and clarify when they hold ownership, usufructuary rights, or other special rights to property.
I would like to begin by thanking Marie Olsson for the questions. They have been posed because Jägareförbundet Dalarna 2023 requested that the County Administrative Board in Dalarna County should revoke a regulation that restricted hunting in the Korpimäki nature reserve in Orsa municipality.
The request led to the County Administrative Board deciding to repeal the current hunting regulation. This decision was appealed to the government, which overturned the decision and returned the matter to the County Administrative Board for continued processing. After the continued review, the County Administrative Board decided to reject Jägareförbundet Dalarnas request. The decision has been appealed to the government by Jägareförbundet Dalarna, and this is therefore the overall background as to why we are here today.
Regarding the questions that Marie Olsson has asked, I note that they have been asked because the Government Offices have now given Jägareförbundet Dalarna an opportunity to substantiate their right to appeal the County Administrative Board's decision, which is a routine administrative measure based on the Environmental Code's regulatory framework.
I must commend Marie Olsson for how well-informed she is regarding the Ministry of Climate and Enterprise's ongoing handling of this matter.
The right to appeal a decision according to the Environmental Code follows from Chapter 16, Section 12 of the Environmental Code. The provision states, among other things, that a decision may be appealed by the person to whom the decision concerns. When it concerns decisions on nature reserves, it follows from practice that a decision concerns the person who has ownership, a right of use, or another special right to a property covered by the appealed decision. An additional requirement is that the decision also impairs the possibility of utilizing the relevant right.
When it concerns the right of non-profit associations and other legal entities to appeal decisions according to the Environmental Code, it appears from Chapter 16, Section 13 that such entities shall, among other things, have as their primary purpose to safeguard nature conservation or environmental protection interests. From the same provision, it appears which decisions these organizations can appeal.
In other respects, I cannot anticipate a decision in the current matter through statements on the issue, as it is an ongoing administrative matter that is still being prepared in the Government Offices and is awaiting the government's decision.
Marie Olsson (S)
Madam Speaker! I would like to begin by thanking the Minister for the answer to my interpellation, even though I can state that I have not received an answer to any of my three questions.
I have on two occasions had an interpellation debate here in the chamber with Minister for the Environment Romina Pourmokhtari regarding the possibilities for expanded hunting in nature reserves, and I believe it is good to go over the background again.
In Orsa, there is a nature reserve called Korpimäki, and Korpimäki serves as an example of what the management looks like today. Hunting has been and still is restricted in this nature reserve based on the regulations that Länsstyrelsen Dalarna decided on a long time ago. One may hunt moose, roe deer, fox, and hare in the reserve, but no other game, such as for example bear and bird.
In order to achieve a change and expand hunting opportunities in the Drev nature reserve, among others, the Orsa hunting management district lobbied for Länsstyrelsen Dalarna to develop new regulations for the reserve. Länsstyrelsen Dalarna then developed new regulations to increase the opportunities for hunting in the area. Länsstyrelsen's decision on the regulations was, however, appealed by the organization Birdlife Sverige, and the issue therefore landed on the government's desk for a decision.
After a full 18 months, the government took a decision on October 9 last year. To the great disappointment of many, the government decided to revoke the County Administrative Board of Dalarna's decision to expand the hunt in the Korpimäki nature reserve. The reason for the government's decision was that the County Administrative Board of Dalarna had not made an assessment of the consequences of the decision for this specific nature area.
According to the government, and according to the legislation, there are requirements to investigate the consequences of a decision on revocation, so it is not strange in itself. This is also connected to the fact that Korpimäki is not only a nature reserve but also a Natura 2000 area. The government wrote that the County Administrative Board's decision should therefore be revoked in its entirety and referred back to Länsstyrelsen Dalarna for reconsideration.
The County Administrative Board of Dalarna presented new underlying documents to strengthen the possibilities that exist to expand the hunt and presented a new proposal for a decision which also maintained that the hunt could be expanded. The proposal was sent out for consultation, and the consultation period expired on January 22 this year.
To many's great surprise, the County Administrative Board decided, after the consultation period had expired, to change its previous decision and maintain the restrictions for hunting in the Korpimäki nature reserve and thus not allow the hunting to be expanded. The Hunters' Association Dalarna then chose to appeal the County Administrative Board of Dalarna's new decision and submitted an appeal to the government.
The response from the Minister's department is a questioning of whether the hunting organizations should be allowed to appeal decisions regarding hunting opportunities. The department questions whether hunting organizations are organizations that represent nature conservation or environmental protection interests. It also questions whether the County Administrative Board of Dalarna's decision concerns hunting organizations specifically based on what the Minister also said in his response, i.e., whether they have ownership rights, usage rights, or other special rights to the property covered by the appealed decision.
I am aware that the minister, just as he said in his answer, cannot anticipate a decision in a current case. Therefore, my questions in the interpellation are generally posed so that the minister can answer. The questions are not posed based on a specific case, but that specific case is actually an example. The minister chooses, nevertheless, not to answer my questions.
Based on this, I would like to ask the Minister how the Minister generally views the possibilities of expanding hunting opportunities in nature reserves and Natura 2000 areas at all.
Arbetsmarknadsminister och vikarierande klimat- och miljöministern Johan Britz (L)
Madam Speaker! Let me clarify one thing regarding the questions that have been asked concerning that Jägareförbundet Dalarna has been given an opportunity to strengthen its right to appeal the county administrative board's decision. This is a routine administrative measure based on the Environmental Code's regulatory framework.
In the answer, I also accounted for what the legislation looks like. There is no reason to draw any conclusions from this answer as to whether Jägareförbundet Dalarna has the right to appeal the county administrative board's decision or not, but I simply wanted to account for the current law.
It is not I as Minister who carry out analyses of the hunters' role in safeguarding nature conservation and environmental interests, and even though the questions the member has asked are somewhat general, they are strongly linked to an ongoing matter – which is an administrative matter, I should point out. The preparation and investigation of that is carried out by the Government Offices' officials according to standard routines and regulations within the framework of the appealed matter.
I will not anticipate the continued processing of this matter. I therefore have no such analyses as the member requests for me to share with her.
Marie Olsson (S)
Madam Speaker! I note that I did not receive an answer to my general question, as it actually concerns how the Minister generally views the possibilities of expanding hunting opportunities in nature reserves and Natura 2000 areas, regardless of where in Sweden they are located.
Some may wonder why I am raising this issue and why I see it as so important. They may also wonder why the minister, in his answer – perhaps with a bit of irony – praised me for how well-versed I am in the matter.
It is because the County Administrative Board in Dalarna initially wanted to test this to establish a precedent so that they could then review the possibility of expanding the hunt in more nature reserves in Dalarna. This could then also constitute a basis for more County Administrative Boards in Sweden in their assessments of hunting opportunities in nature reserves. This question is therefore more general, even though it stems from a specific case.
Hunting is already permitted in many nature reserves, and in recent years, the county administrative boards' regulations have not been as restrictive as before regarding hunting opportunities in nature reserves.
Environment Minister Romina Pourmokhtari stood here in the chamber during our last interpellation debate and assured of the government's great interest in hunting issues and the hunters' opportunities to conduct wildlife management. According to the minister, the government stood on the hunters' side.
The hunters' state mandate in Sweden revolves around responsible wildlife management and administration. The overarching mandate is to preserve biodiversity, keep wildlife populations at a healthy level, reduce the risk of traffic accidents, and ensure that hunting is conducted ethically and sustainably. The hunters are aware of what boundaries exist for hunting and that they must not cull so many animals that the ecosystem and the forest are affected. They are fundamentally wildlife managers. The entire system is built on trust, and the hunters have a responsibility to follow laws and regulations.
The Minister for the Environment's assurances in the previous debate fall rather flat when the Swedish Hunters' Association, even though the minister says that this is a normal procedure, is met with a questioning of whether they are even allowed to appeal at all. When Birdlife Sverige appealed, that appeal was accepted, and in this case, it is nevertheless the case that the County Administrative Board has changed its previous decision to expand the hunting. A decision was made to expand the hunting, the government overturned that decision, and now a decision has been made not to expand the hunting. The County Administrative Board has thus changed its decision.
In its response, the department writes that Jägareförbundet must prove that they have ownership, right of use, or another specific right to the property covered by the appealed decision and that the decision impairs the holder's ability to utilize the relevant right. Jägareförbundet has, of course, submitted a response to this, but I will return to the point that it is still a questioning. That is how it is perceived, that is to say as a questioning of the hunting organizations' ability to appeal at all. Jägareförbundet has not yet received a response to the response they submitted to the department, and I truly hope that the response will be that they are given the opportunity to appeal.
In some way, we need to address the fundamental issue regarding the possibility of changing regulations for hunting in nature reserves and Natura 2000 areas in cases where we can establish that old regulations have been too restrictive for the reserve's purpose. A county administrative board that changes its policy in its attitude towards hunting and which, when nature reserves are formed in the present, has a significantly more generous view on hunting, should also be able to change previous decisions.
I want to ask the same question as in the interpellation, because I did not receive an answer to it. Is the Minister prepared to take the initiative to review the legislation to ensure that hunting organizations generally have the opportunity to appeal decisions concerning hunting opportunities in nature reserves?
Arbetsmarknadsminister och vikarierande klimat- och miljöministern Johan Britz (L)
Madam Speaker! It appears from the preparatory works to the Environmental Code that the owner of the matter is the one concerned. A complaining party must, however, be affected by a decision in a more concrete way to be considered the owner of the matter.
Those who have ownership, usufruct, or other specific rights to a concerned property are, according to established practice, co-owners and have the right to appeal decisions regarding nature reserves. This follows from a number of court rulings from the Land and Environment Court of Appeal and the Supreme Court. According to practice, it is also possible to appeal decisions on hunting of a species covered by the Birds and Habitats Directive in accordance with the Aarhus Convention. Practice also shows that the right to appeal decisions according to the Hunting Ordinance in general should be assessed in accordance with organizations' right to appeal according to the Environmental Code.
The assessment of whether a hunting organization is an environmental protection organization is made on a case-by-case basis. Organizations that meet the requirements for being classified as an environmental organization are also considered to be such an organization. According to the requirements of the Environmental Code, an environmental organization shall have as its primary purpose to safeguard nature conservation and environmental interests.
Marie Olsson (S)
Madam Speaker! In my world, this matter should therefore be crystal clear, because that is exactly what the hunting organizations are working on.
Korpimäki is, as stated, a Natura 2000 area, and Natura 2000 areas shall be representative samples of natural environments in Sweden. The purpose of Korpimäki is not to protect species that are not threatened and where it is currently not permitted to hunt in the reserve, for example, bear and forest birds. For that very reason, the restrictions became too harsh when the decision was made.
Hunting is a large part of the local culture and tradition all around the country. Many experience nature through hunting, and one purpose of this reserve is for people to experience a dalan nature forest. One way to experience a dalan nature forest is actually precisely through hunting.
Now we need a government that listens to the population so that we can counter the mistrust towards the state that unfortunately actually exists all around the country, especially in the countryside. I can only look at my home municipality Orsa, which is a rural municipality: There, unfortunately, there is a mistrust towards the state.
All the fine words from Sverigedemokrater and representatives from the government parties about how there would now be a government that would sort out all hunting issues turned out not to be true. That the wolf hunt was cancelled is just one example of that. It is not enough with a lip service, it is also a matter of delivering policy. This government has not managed to do that in the hunting area.
If the department decides that a hunting organization that has a state mandate is not allowed to appeal decisions on hunting opportunities, we will receive further evidence of the government's stance on hunting. I hope that the government this time listens to the responsible wildlife managers that the hunters actually are and that we get this tested. As I see it, it is now up to the government to prove.
In conclusion, I would like to wish the minister a pleasant summer, as this is the last debate I will have with the minister in the chamber.
Arbetsmarknadsminister och vikarierande klimat- och miljöministern Johan Britz (L)
Madam Speaker! I would like to thank Marie Olsson very much for this discussion. The process that the member has described in her statements is not only instructive in itself to follow, but it also shows different types of decision points and conflicts of objectives that can arise – and which we have the task of weighing together. That is what it is about.
Regarding the question in this specific individual case, I need to point out again that it is an ongoing administrative matter and that I should not anticipate a decision by going into more detail on the question.
I also want to say that it was completely without irony that I praised Marie Olsson for how well-informed she is. It is with respect that I say it.
In conclusion, I thank you very much for the greeting about a pleasant summer. Let me return it and say: Happy summer to you too, Marie Olsson!
Source: The Swedish Parliament. The speeches come from the open data of the Riksdag, translated into English by AI, which may contain errors.