Recently, we have seen NGO denunciation letters being published on social media, the content of which affects the way Public Services or collective administrative bodies operate that are formed with the participation of expert scientists and handle requests that they have submitted and that concern the activities of caring for wildlife species.
A typical example is the case of an NGO that has submitted a request to the Ministry of Environment for the creation of a Centre for the Care of Marine Mammals (cetaceans, seals) and turtles on the island of Lipsi. This case in recent months has aroused public interest because of the publicity that the issue has received, not only because of the letters that have been circulated between the relevant departments on the substance of this request, but also because of the involvement of animal welfare associations, environmental organisations and active citizens, both Greek and foreign, but which (as it turns out) refer to something completely different from the creation of a care centre, but in the creation on the island of Lipsi of an open marine park (Cetacean Sanctuary – Dolphin Sanctuary) by closing a bay with the aim of permanently housing dolphins there which are currently housed in Aquariums and Zoological Parks in Greece and mainly abroad.
This issue, unfortunately with its negative side, was linked to accusations of administrative delays in the relevant licensing of the NGO and has concerned both the Prime Minister’s office and the competent Ministries, as well as opposition political bodies that have submitted relevant questions in the parliamentary control process and animal welfare organizations of a pan-Hellenic scope.
We hope that the competent service and political leadership of the Ministry of National Education will respond to the substance of the allegations raised by the NGO in question, which concern the clarity of the request and the real nature of the infrastructure it intends to create. To publicly disclose the scientific and technical evaluation of the proposal submitted by this body and the findings – conclusions reached by the Central Advisory Committee that examined the proposal in order to understand the real problems that exist. To see the feasibility and even the elements of financial viability of the project, but also the other problems that existed and are known to the administration and related to either the building used for the purpose of the request after it was first granted to the M.C.O. by the Ministry, or the concession of the use of the surrounding forest land, and the elements of the case file, before drawing easy conclusions about the functioning of the administration and decide as citizens if we want a service that functions positively
For all these reasons, we believe that the competent (according to the publications) Ministry of Environment and Energy should respond not only to the validity of the publications, but also to the procedure on the following issues:
- Does the Ministry of Environment exercise any competence that goes beyond the institutional framework for the care centres that it has created, i.e. competence that goes beyond the provisions of the Ministry of Environment/ΔΔΔ/88658/2929/02-09-2022 “Criteria and procedure for the recognition and supervision of care centres (KE. P.E.E.A.P.) and Wildlife First Aid Stations (W.E.A.P.)’ (B4744)?
- Does the Ministry of the Environment exercise, and on the basis of which institutional framework, powers relating to the creation of zoological parks, aquarium gardens or marine parks for the permanent accommodation of marine species (Dolphin Sanctuaries)?
- What are the relevant competences of the relevant regional authorities in this area?
- Has the Ministry or the Government’s willingness to create Dolphin Sanctuaries in our country (in any place) been expressed institutionally and responsibly and on the basis of which EU Directive or Regulation for the accommodation of dolphins and cetaceans in general, which are currently housed in aquariums or zoos or parks in EU countries?
- Has the cost of setting up, operating and maintaining such a marine park and the cost of housing and veterinary care for these species been calculated and has a decision been taken to cover it from public funds (and that of a bankrupt country)?
- Has any public or private law body declared its willingness and ability to provide viable (financial and technical) support for such a project?
- In case the Ministry of Environment and Energy or the Government is considering this possibility, do they have examples of successful operation of similar type of parks in Europe or anywhere else?
- If there is indeed interest from other European countries in creating Dolphin Sanctuaries in our country, it would be useful to explain why they avoid creating such infrastructures on their own territory, given that marine mammals are currently housed in zoological parks operating in these countries.
- What is the scientific opinion of the Scientific Committee of the ACCOBAMS Intergovernmental Agreement on this matter?
- Is there a current legislative framework for the creation of such infrastructure by closing sea bays or developing them on the coastal zone, any construction intervention of which is the responsibility of other ministries?
The Ministry of Environment must evaluate the above-mentioned questions, but in any case it cannot remain indifferent to this barrage of targeted publications that are indirectly and unfairly directed against it on the occasion of the development of this case. The political leadership must support its own work on the major issue of wildlife care and the work of its services, which is remarkably important and is recognised by all the NGOs involved in institutional care.
On the same basis, the political leadership of the Ministry of the Environment should support in practice with a public statement the work of its thematic services, of its colleagues and of the expert scientists who participate in a non-profit and impartial manner in the collective bodies that it has set up for the evaluation in a scientific and fair manner of the requests submitted by the various environmental bodies.
We note that the members of the Central Advisory Committee for the establishment and operation of Wildlife Care Centres (KE.P.E.A.P.) who are unethically and unfairly criticized for doing the work they have been assigned to do, are eminent scientists and fellow geotechnicians representing Ministries (Ministry of Environment and Ministry of Agriculture), University Departments (Veterinary Medicine and Forestry) of the faculties of the Ministry of Agriculture and Forestry. The University of Thessaloniki, Organizations (ELGO Dimitra) and the Geotechnical Chamber of Greece and any negative reference to the way the natural persons who form the committee operate indirectly affects the aforementioned bodies that appointed their representatives to the committee.
The unjustified and publicly formulated reports of an NGO representative against the work of the public administration and, by extension, the established procedures for the implementation of the current legal framework, should trigger the reaction of the Ministry of Environment and Natural Resources in order to fully safeguard the uninterrupted operation, prestige and dignity of its services and its representatives and, on the other hand, to ensure the trust of the governed in the services and the advisory bodies set up by the Ministry of Environment and Natural Resources in order to achieve the desired results.
With regard to the issue of “Marine Mammal Sanctuaries” from captivity, we believe that the Ministry of Environment should proceed on its own initiative to organize a broad inter-ministerial technical meeting with officials, renowned scientists, representatives of countries in International Conventions and scientific bodies in Greece and abroad, in order to discuss and clarify this issue, which in recent years has been of great concern to the scientific community and society.
With the final assessment that the response of the Ministry of Environment and Natural Resources has already been delayed for what has been mentioned above, we should follow the developments while waiting for the relevant official and political responses, supporting in any case our colleagues, geotechnical experts who participate in the advisory bodies of the Ministry and the forestry services that have undertaken the task of supporting these procedures without being provided with the necessary means and specialized personnel and yet they are being attacked unjustly.
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