DEBATE • In Sweden, all major industries and environmentally hazardous operations are supposed to undergo environmental assessment according to the Environmental Code. Now, hydropower is being reassessed to reduce its environmental damage. It is strange that an operation as environmentally harmful as reindeer husbandry, which covers such a large part of Sweden and is funded by taxpayers, has not been subjected to environmental assessment.
Presumably, the reason is that all experts know that reindeer husbandry would not pass the assessment under the provisions of the Environmental Code, and therefore it has been given an exemption. This is evident as reindeer husbandry is protected in several paragraphs of the Environmental Code, even though the activity violates Chapter 1, Section 1 (the umbrella section) and many subsequent applicable paragraphs.
Therefore, it should be subjected to environmental assessment. Here, logic and equality before the law are lacking. According to Chapter 3, Section 5 (regarding trade-offs), reindeer husbandry gains tremendous influence as a national interest, even though, after a serious environmental assessment, it would reasonably not be permitted as operated today.
The Connection Between Reindeer Husbandry and the Environmental Code.
The following parts of the Environmental Code may apply to reindeer husbandry:
Chapter 1. Objectives and Scope of the Environmental Code
Section 1 The provisions of this Code aim to promote sustainable development whereby current and future generations are assured a healthy and good environment. Such development is based on the understanding that nature has intrinsic value and that humanity’s right to alter and utilize nature comes with a responsibility to manage it well.
The fact that reindeer husbandry is gradually depleting the mountain region of phosphorus and base cations (cations of calcium, magnesium, potassium, and sodium) is not sustainable and is therefore not managing nature responsibly.
The Environmental Code shall be applied so that
1. human health and the environment are protected against damage and nuisances, regardless of whether these arise from pollution or other impacts,
2. valuable natural and cultural environments are protected and managed,
3. biological diversity is preserved,
4. land, water, and the physical environment in general are used so as to secure a long-term good management from ecological, social, cultural, and socioeconomic perspectives, and
5. reuse and recycling as well as other conservation of materials, raw materials, and energy are promoted to close the loop.
Reindeer husbandry violates this in multiple ways. “Other impacts” refers here to the growing nutrient deficiency negatively affecting entire ecosystems. Limiting predator populations of wolves, lynx, and wolverines — which also complicates the food supply for arctic fox, gyrfalcon, golden eagle, and others — is not preserving biological diversity. Grouse hunting has the same negative effect. The arctic fox now only survives thanks to human supplemental feeding.
Reindeer husbandry has also eradicated wild mountain reindeer and forest reindeer and likely negatively impacted the musk ox’s development. All this limits biological diversity. Reindeer husbandry and hunting also negatively impact evolution and genetics, with long-term effects. Removing reindeer carcasses, grouse, and fish on a large scale from the mountain environment breaks the nutrient cycle in the mountains. Driving motor vehicles in these sensitive environments is not protecting or caring for it.
Consideration Rules
Chapter 2. General Rules of Consideration, etc.
Section 2 Anyone pursuing or intending to pursue an operation or take an action shall acquire the knowledge required by the nature and scope of the operation or action to protect human health and the environment from harm or inconvenience.
Here, those engaged in reindeer husbandry are obligated to acquire the same knowledge as any farmer. If you remove nutrients by exporting carcasses, grouse, and fish from an area, a corresponding amount of nutrients must be returned. This is completely ignored. The greed and irresponsibility are total.
Section 3 Anyone pursuing or intending to pursue an operation or take an action shall take the safeguards, observe the limitations, and take other precautionary measures necessary to prevent, impede, or counteract the operation or action causing harm or inconvenience to human health or the environment. In the same interest, the best available technology shall be used in professional operations.
These precautions must be taken as soon as there is reason to suspect that an operation or an action may cause harm or inconvenience to human health or the environment.
Thus, reindeer husbandry is obliged to either return the nutrients removed or cease the harmful activity.
Choice of Location
Section 6 For an operation or action that takes up a land or water area, a site should be chosen that is suitable considering the purpose can be achieved with the least intrusion and inconvenience to human health and the environment.
There is no area in Sweden where reindeer husbandry can be carried out as it is today.
Reasonableness Balance
Section 7 The requirements under sections 2–5 and section 6 first paragraph apply to the extent it cannot be deemed unreasonable to fulfill them. In this assessment, special consideration must be given to the benefit of protective measures and other precautions compared to the costs of such measures.
Introducing measures such as returning nutrients would further increase the cost of an industry that is wholly dependent on taxpayer funding. This is not reasonable.
Responsibility for Environmental Damage
Section 8 Anyone who engages in or has engaged in an operation or action that has caused damage or inconvenience to the environment is responsible, until the damage or inconvenience has ceased, to remedy it to the extent reasonable under Chapter 10. To the extent prescribed in this Code, an obligation may instead arise to compensate the damage or inconvenience.
For a long time, reindeer husbandry has accumulated a debt regarding phosphorus and base cations in the soil. Reindeer husbandry is thus obliged to restore the nutrient balance, and the debt increases every year. They are sawing off the very branch they sit on. Because reindeer husbandry is entirely dependent on public subsidies, the cost ultimately lands on the Swedish people. Why should taxpayers accept this?
Final Balance
Section 9 If an operation or action is feared to result in damage or inconvenience of substantial importance to human health or the environment, even if such protective measures and other precautions are taken as may be required under this Code, the operation may be conducted or the action taken only if the government finds there are special reasons.
What are these “special reasons” that make the government believe an operation that depends on large public subsidies should be allowed to continue despite increasing negative effects on the entire mountain environment? That it is considered a national interest is completely incomprehensible.
An operation or action may not be conducted if it entails the risk that a large number of people will have their living conditions significantly impaired or that the environment is significantly deteriorated.
Reindeer husbandry impairs people’s living conditions by demolishing mountain huts, limiting sleeping accommodations in huts, closing restaurants at mountain stations, etc., making it harder for those who want to experience the mountain environment. As shown above, the mountain environment is drastically deteriorating, negatively impacting the experience. According to the Environmental Code’s provisions, the activity should therefore be prohibited.
Land Use, Management, and National Interests
Chapter 3. Fundamental Provisions for Management of Land and Water
Good Management
Section 1 Land and water areas shall be used for purposes for which they are best suited, considering their characteristics, location, and prevailing needs. Priority shall be given to uses that, from a public perspective, constitute good management.
Conducting reindeer husbandry in the Swedish mountain region as it is today thus violates the Environmental Code’s regulations.
Special Land Use Interests
Section 2 Large land and water areas that are not at all or only insignificantly affected by development projects or other environmental interventions shall, as far as possible, be protected from actions that may significantly affect the areas’ character.
The mountain environment must thus be protected from the environmentally harmful reindeer husbandry.
Section 3 Land and water areas that are particularly sensitive from an ecological point of view shall, as far as possible, be protected from actions that may damage the natural environment.
The mountain environment is particularly sensitive ecologically. Reindeer husbandry, as it is conducted today, does not belong in the mountains.
Section 5 Land and water areas of significance for reindeer husbandry or commercial fishing or for aquaculture shall, as far as possible, be protected from actions that may significantly impede these industries.
Areas of national interest for reindeer husbandry or commercial fishing shall be protected against the actions referred to in the first paragraph.
Here, legislators and politicians have completely lost logical thinking. Allowing an operation, which would not pass an environmental assessment under the Environmental Code, which is sustained by taxpayer funds and concerns about 4% of the Sami population, to get a free pass from requirements that apply to the rest of the country is madness. In other words, double standards. Not equality before the law.
Section 6 Land and water areas and the physical environment in general which are of public interest due to their natural or cultural values or for outdoor recreation shall, as far as possible, be protected against actions that may significantly damage natural or cultural environments.
Areas nationally important for nature conservation, cultural heritage, or outdoor recreation shall be protected against the actions referred to in the first paragraph.
Reindeer husbandry restricts outdoor activities and significantly harms the natural environment.
Section 7 Land and water areas containing valuable substances or materials shall, as far as possible, be protected from actions that may significantly impede extraction.
Reindeer husbandry hinders mining activities.
Balancing Incompatible National Interests
Section 10 If an area under sections 5–8 is of national interest for several incompatible purposes, priority shall be given to the purpose or purposes that most suitably promote long-term management of land, water, and the physical environment in general.
As shown above, reindeer husbandry does not promote long-term management of land, water, or the physical environment.
Decisions under the first paragraph must not conflict with the provisions of Chapter 4.
Entire National Interest Areas
Chapter 4. Special Provisions for Management of Land and Water for Certain Areas
Areas Entirely of National Interest
Section 1 The areas specified in Sections 2–8, in view of their natural and cultural values, are in their entirety of national interest. Development projects and other environmental interventions may take place only if
1. there is no obstacle under Sections 2–8, and
2. it can be done in a way that does not significantly harm the areas’ natural and cultural values.
As shown above, reindeer husbandry harms the natural values of the mountains.
Section 2 In the following areas, the interests of tourism and outdoor recreation, mainly mobile outdoor recreation, shall be given particular consideration when assessing the admissibility of development projects or other environmental interventions:
The mountain region from the Transtrand mountains in the south to Treriksröset, excluding the areas specified in Section 5.
Reindeer husbandry restricts tourism and outdoor activities by forcing the demolition of tourist cabins, reducing the number of beds in mountain huts, closing restaurant operations at mountain stations, and so on. Therefore, it should not be allowed in the mountain region as it operates today.
Special Provisions for Certain Activities
Chapter 9. Environmentally Hazardous Activities and Protection of Health
Definitions
Section 1 Environmentally hazardous activity means
1. discharges of wastewater, solid materials, or gases from land, buildings, or installations into land, water bodies, or groundwater,
2. use of land, buildings, or installations in a way that may cause inconvenience to human health or the environment through other discharges than in (1), or through pollution of land, air, water bodies, or groundwater, or
3. use of land, buildings, or installations in a way that may create nuisance for the neighborhood through noise, vibrations, light, ionizing or non-ionizing radiation, or similar.
Creating nutrient deficiencies over large areas is such a similar adverse effect. Among other things, this makes reindeer husbandry an environmentally hazardous activity. Reindeer husbandry is increasingly depleting the mountain region of phosphorus and base cations, etc., by removing slaughtered reindeer, grouse by hunting, and fish by fishing in the lakes. This affects the entire ecosystem negatively — both flora and fauna — and the damage gets worse every year.
Review of Cases and Matters
Chapter 16. General on the Review
Review Authorities
Section 1 The government, county administrative boards and other administrative authorities, municipalities, land and environmental courts, the Land and Environment Court of Appeal, and the Supreme Court review cases and matters under this Code or according to regulations issued pursuant to the Code.
Here, the judiciary violates the Environmental Code by not subjecting an activity covering over half of Sweden’s area — which causes damage to the ecology of the mountain region and hinders people’s opportunities to hike and enjoy nature — to environmental assessment. That politicians and the legal system have made reindeer husbandry a national interest may be because they realized that reindeer husbandry violated the Code’s provisions. Or they have looked the other way or have not understood. Either way, it is madness.
Supervision, etc.
Chapter 26. Supervision
General on Supervision and Supervisory Guidance
Section 1 Supervision shall ensure the purpose of this Code and regulations issued under the Code are fulfilled.
Supervision means that the supervisory authority shall
1. on its own initiative or following notification, as necessary, check that the Environmental Code as well as regulations, judgments, and decisions issued pursuant to the Code are complied with, and take the measures needed to bring about correction.
Reindeer husbandry has been granted the privilege of being exempt from the Code’s provisions, despite serious impacts on the natural environment and restricting outdoor activities in the mountains. This is because reindeer owners are Sami, considered indigenous people. But the remaining 96% of Sami and ethnic Swedes are just as much an indigenous people, as described in my column “Swedes are just as much a native people as the Sami“. The logic fails.
How an Environmental Assessment Works
An environmental assessment consists of two documents: an application for a permit, and an environmental impact statement (EIS). This is done before an environmentally hazardous operation can start. Assessments are also made for operations that existed before the legislation was enacted. In the end, the result should be roughly the same.
Reindeer husbandry has been around for a long time, but to illustrate a permit application for those unfamiliar with the area, let’s reverse reality and imagine a mountain region with no reindeer husbandry and an application to start. A mountain region without reindeer husbandry could look as follows:
The mountains would have rich populations of bear, wolf, wolverine, arctic fox, golden eagle, gyrfalcon, owls, wild mountain reindeer, musk ox, and more. If no hunting takes place, as is common in nature reserves in other countries, the animals are not particularly afraid of humans. It would be attractive for people from Sweden, Europe, and other countries to visit the Swedish mountain region throughout much of the year to hike or ski and experience the rich wildlife and pristine nature.
Hotel operations could boom, and hiking trails with good accommodation and food service could be available throughout the mountains. The Sami could keep tame reindeer in captivity and, in winter, take tourists on sleigh rides, showcase their unique culture, and engage in sales or hotel ventures.
In the forested areas, the forest reindeer — a different, long-legged species — would live. In a naturally functioning mountain ecosystem, wild reindeer would become prey for predators, which in turn spread their urine and feces throughout the mountain environment, allowing nutrients to circulate locally and the natural cycles to function. The interplay between predator and prey continues evolutionary selection and favors the long-term genetics of species.
This describes a naturally functioning environment with high biological diversity, fully in line with the Environmental Code and the EC Habitats Directive. Human movement in the area, without hunting, has minimal impact.
An application to introduce reindeer husbandry would now have to describe the expected consequences in an EIS. These consequences are what we see today, as described in my earlier comments.
Removal of nutrients and the destruction of the mountain region by motor vehicles, eradication of wild mountain reindeer and forest reindeer, absence of wolves and many other species — all of this is well-known. And hunting selects the wrong animals from an evolutionary standpoint, since the hunter selects according to his own wishes, distorting the animal populations’ genetics long-term.
EU Restoration Legislation
According to new EU legislation, 20% of land and sea areas must be restored by 2030. The regulation states that member states must consistently apply the best available and up-to-date scientific knowledge. This reasonably means that 20% of the mountain region needs to be restored to more natural conditions. This cannot be achieved with continuing reindeer husbandry.
A key starting point for restoration is the so-called favorable reference areas. This is the area needed to ensure the long-term viability of the habitat types and species protected by the EU Habitats Directive. The Tidö government has decided that reference areas shall correspond to the area estimated in 1995 when Sweden joined the EU.
This deviates from the regulation’s directions on the latest, best available scientific evidence and thus violates EU law. The Tidö government has consistently resisted issues concerning the protection of Swedish nature and the promotion of biodiversity. For example, Sweden voted against the EU restoration law — but lost.
The reason so little has happened in Sweden regarding nature tourism and ecosystem restoration is that reindeer husbandry and hunting organizations have succeeded in indoctrinating Swedes with their view of nature, which springs from their own selfish interests rather than scientific facts and accountability.
Swedes ought to travel abroad to see how far behind Sweden lags in terms of biodiversity and nature tourism. It is enough to visit Norway, where one can see wild reindeer and musk ox at Dovrefjell, and in Finland, the last forest reindeer populations in Europe. But to truly open one’s eyes, one should travel to countries like India, Nepal (both banned all hunting in 1973), Costa Rica, Botswana, the USA, and others.
The growing number of tourists in the mountains will, through their urine and feces, increase the availability of nutrients and thus freely restore nutrients to the levels that existed before reindeer husbandry created a nutrient debt. Banning grouse hunting would benefit the golden eagle, gyrfalcon, and arctic fox. With reduced grazing pressure from wild mountain reindeer, balanced by predators, we might also see the return of the lemming years and the snowy owl.
An area that would be suitable as a starting point is the proposed Vålådalen Nature Reserve with mountains such as Helags and Sylarna. It is attractive for tourism due to its beautiful nature and proximity to major cities and the rest of Europe.
By slaughtering all domestic reindeer in the area and bringing in wild reindeer from Dovre in Norway for release, the transformation into a fantastic nature reserve can begin. There may also be better conditions here for musk oxen than north of the Rogen lakes. There is also an opportunity to introduce forest reindeer below the mountain area.
And a new Gåsen cabin can be built, and food service provided at Blåhammaren, Sylarna, and Helags, creating real local jobs. This would also support other hotels and businesses in the area. It’s time to slaughter sacred cows!
Ulf Blomquist
Academic degree in biology, ecology, limnology, chemistry, environmental law, among others
My previous column on the subject: “Reindeer Husbandry is Unsustainable”