Natura 2000

The letter to European Commission


Decemmber 7, 2004

Request for inclusion of important Natura 2000 sites (in a sense of 92/43/EEC directive) in Hostýnské vrchy (Zlín district) into national list of SACs of Czech Republic.

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.
The subvention concerns two important NATURA 2000 sites that have not been listed in pSCI (potencial Sites of Community Interest) or SAC (Special Areas of Conservation) of Czech Republic. To be specific, the sites in concern are "Hostýnské vrchy-Kelčský Javorník" and "Rusava-Hořansko".
Since no plausible resolution has been obtained when attempting on national level via Czech Ministry of Environment, our request to your institution represents a final possibility. The last reaction (dated Aug 6, 2004) of Czech Ministry of Environment (numbered OMOB630/1915/04) contains following declaration:

Concerning first site (including of Hostýnské vrchy-Kelčský Javorník)
"…there is no doubt on validity of your proposal in the case of Hostýnské vrchy-Kelčský Javorník, its uniqueness has been also proved by Agency for Nature Conservation of Czech Republic in Brno. Nevertheless, the list of special areas of conservation pSCI in Czech Republic have been prepared on the basis of the data gathered to Sept 30, 2003. Unfortunately, to this date, data documentation on Hostýnské vrchy-Kelčský Javorník had not been completed and thus the site had not been proposed and included into national list. Nowadays, additional inclusion of the site is not possible without relevant involvement of European Commission.."

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).
Moreover, the proposed site includes priority habitats in the sense of Annex I . Since the data documentation on proposed site have been already completed to date, we request European Commission to decree a supplementation of Czech national list of NATURA2000 sites with the proposed site.

Concerning second site (expansion of Rusava-Hořansko site)
"…your proposal concerning expansion of pSCI Rusava-Hořansko was solved on July 15, 2004. Since situation of particular meadow have not been discussed with the owners and, moreover, the potential pSCI would become disjunctive, your proposal have been rejected. Nevertheless, your proposal was transferred to relevant district authorities for consideration of setting local protection statute."

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.

Detail information on particular sites:

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

Code Code (CZ) Name
9130 L5.1 Asperulo-Fagetum beech forests
9180 L4 * Tilio-Acerion forests of slopes, screes and ravines
9110 L5.4 Luzulo-Fagetum beech forests
91E0 L2.2 * Alluvial forests with Alnus glutinosa and Fraxinus excelsior (Alno-Padion, Alnion incanae, Salicion albae)

"*" 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).
b) expansion of existing proposed pSCI (SAC) Tesák, CZ0723428, size 1103.07 ha, that is listed in order to protect a single species, the carabid beetle Carabus variolosus (in this case, only above mentioned target species, not particular habitats are of conservation priorities). The proposed area of the site after expansion is 2500 ha (see map appendix P1-HV-KJ-varA). Proposed conservation status: nature reserve. Proposed name after expansion: Hostýnské vchy-Kelčský Javorník or Hostýnské vchy-Kelčský Javorník, Tesák. Of course, changing of conservation priorities (not only a target beetle species, but also all its natural habitats) must to be done in a particular edict,
c) in order to reach higher representation of natural habitats (but at the expense of integrity) use fragmentation of the complex proposed in b - alternative. The proposed best way is in tab. 2 (map appendix P2-HV-KJ-varB).

Tab. 2:

Name (Habitat types) CZ code Estimate of agency of natural habitats (%) Area (ha)
HV-Kelčský Javorník (9130, 9180*,9110 + 91E0*) L5.1, L4*, L5.4 + L2.2* 90 250 90 250
HV-střed (9130, 9180*,9110 + 6510,-, -)L5.1, L4*, L5.4 + T1.1, T1.5, R1.4 75 1150
HV- Obřany (9130, 9180*,9110 + 6510,-,) L5.1, L5.4, L4 + T1.1, T1.5, R1.4 70% (after separation of the north part is possible % increase) 350
HV-Čerňava2 (9130, 9180*,9110) L5.1, L5.4, L4 95 42
HV-Vičanov (9130, 9110,-) L5.1, L5.4, R1.4 nearly 100 160
Altogether 1952

"*" indicates priority habitat types.

In the proposed site occur following species:

Annex II.

Lesser horseshoe bat (Rhinolophus hipposideros)
Barbastelle (Barbastella barbastellus)
Bechstein's bat (Myotis bechsteinii)
Geoffroy's bat (Myotis emarginatus)
Greater mouse-eared bat (Myotis myotis)
Crested newt (Triturus cristatus)
Yellow-belied toad (Bombina variegata)

Annex IV.

Carabus variolosus
Bats (Microchiroptera) except above-mentioned species another 12 species
Sand lizard (Lacerta agilis)
Montandon's newt (Triturus montandonii)
Crested newt (Triturus cristatus)
Yellow-belied toad (Bombina variegata)
Agile frog (Rana dalmatina)
Green toad (Bufo viridis)
European tree frog (Hyla arborea)

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.


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).

Thank you for accepting this request, evaluating the possibilities and sending us your perspectives. We do believe, that proposed sites will be additionally included into national list of special areas of conservation of NATURA 2000 network.In the case of your interest we are able to provide you with GIS version of all the maps attached in the appendix. The possible participation of our organization on the proposed process is self-evident.If the proposed sites will not be included into national list of special areas of conservation, there is, beside the conflict with Habitat Directive 92/43/EEC, the evident threat of change of so far positive attitude of local citizens and NGO's to the sense and importance of NATURA 2000 in our region.

Map appendix.