VII. The supervision content of the central ecological environment protection shall cover the management of wild animals and implement "lifelong accountability"

As a key component of the ecosystem, wildlife is vital to maintaining biodiversity and China's ecological security. Since the central ecological environmental supervision work started in 2016, by controlling the “key minority” of leading cadres, significant achievements have been made in promoting pollution control, energy conservation and emission reduction, and achieving high-quality development, which have fundamentally changed the once neglected environmental management in the short term.

However, at present, the scope of the central ecological environmental protection inspections rarely involves the management of wildlife. It is suggested that the current revision of the "Wildlife Protection Law" clearly stipulates that a central ecological environmental protection inspector should be implemented for the management of wild animals, and a lifelong accountability system should be implemented for administrative permits.

VIII. Scientific dynamic adjustments to the scope and list of wildlife protection

China's existing National Key Protected Wildlife Directory has been criticized for not changing for a long time. Although the "Wildlife Protection Law" requires a time limit for the adjustment of the inventory, from the current point of view, it is disconnected from the current practice of wildlife protection in China.

It is suggested that the amendment of the Wildlife Protection Law should be based on the scientific spirit of seeking truth from facts, shorten the evaluation cycle, and make scientific adjustments to the scope of protection and the list in a timely manner. In particular, the classification and management of China's wild animal catalogs should be in line with international conventions and appendices such as CITES and CBD, reflecting the international level of China's wildlife management.

IX. Set up a special chapter on information disclosure and public participation

The existing "Wildlife Protection Law" basically lacks information disclosure and public participation. The administrative supervision of wild animal protection and the use of enterprises fail to obtain effective social supervision, resulting in chaos and a chain of interests. In particular, the abuse of wild animal licenses has become an "open" secret, and even steel companies and cultural companies can easily obtain licenses.

It is suggested that the amendment of the Wildlife Protection Law should establish a special chapter on information disclosure and public participation, implement information disclosure throughout the entire process of wildlife management, widely mobilize the participation of the whole society, and ensure management law enforcement under the sun.

It is particularly important that in the special chapter on information disclosure and public participation, the civil public interest litigation system for the destruction of wildlife should be clearly stipulated, and relevant authorities and social organizations that meet the conditions should be able to sue as plaintiffs to allow illegal offenders who infringe on wildlife bear high legal and economic costs.

X. Establish an administrative public interest litigation system for social organizations

The current chaotic nature of wildlife management shows that there is a major problem with administrative supervision. Although the procuratorial organs can carry out administrative public interest litigation, as a supervision within the system, the procuratorial organs have insufficient motivation and enthusiasm to carry out administrative public interest litigation.

It is recommended that this amendment to the Wildlife Protection Law establish an administrative public interest litigation system with social organizations as the plaintiffs, conduct comprehensive social supervision of administrative violations involving wildlife, and prevent out-of-control at the source.

The above recommendations are for your reference.

China Biodiversity Conservation and Green Development Foundation

By / Maggie