The hunters' federation is proposing to double the number of birds that can be shot over Malta in its position document on a "limited" spring hunting season.
The federation estimate that Malta can shoot as many as 72,000 quails and 63,000 turtle doves during the spring hunting season and still be in line with EU rules. The proposals were submitted last Tuesday to the Ornis Committee, the body which makes recommendations on hunting.
The proposals are meant to provide a framework for the government to apply another derogation from EU laws, in an attempt to keep a spring hunting season. The first four attempts (each year since Malta joined the EU in 2004) failed and saw Malta lose a case before the European Court of Justice (EJC).
However, the figures presented by the federation are more than double the number of birds which hunters claimed to have shot in the records kept between 2004 and 2007. The government had presented these statistics to the EJC when it argued its case.
According to this data, which is based on what hunters themselves claim, on average, 35,000 turtle doves and 17,000 quails were shot each spring during these four years since Malta joined the EU.
The ECJ ruled against Malta but conceded that the autumn season, in principle, did not really offer an alternative to spring - which the government interpreted as an opportunity to explore a "very limited hunting, under strict controls".
These proposals by the hunters are intended to back up the argument for that 'limited' hunting season. In the proposals, the federation argues that the new limits they are suggesting are only "theoretical" because hunters are unlikely to reach them given the erratic migration of birds over Malta during this time.
But there is no way of knowing conclusively how many birds the hunters shoot in reality, because the federation itself admitted that the statistics provided to the EJC were "on the low side".
Birdlife Malta executive director Tolga Temuge said these figures presented as theoretical limits were closer to what hunters actually shoot during spring.
He also disagreed with the calculations which back the federation's claim that hunters could be allowed to shoot so many birds.
The federation's secretary Lino Farrugia would not comment on the proposals, saying he would be breaching an understanding in the Ornis Committee that the proposals would not be made public while discussions were going on.
"This is unethical on Birdlife's part but I have come to expect this sort of thing. We did not even give the details to our members," Mr Farrugia said.
He did say, however, that the federation based its calculations on Birdlife's own statistics as well as guidelines provided by the EU. "That is all I can say for the time being, after the Ornis Committee makes its recommendation either way (on whether to apply a derogation again) we will publish the document."
Birdlife's biggest objection is to the federation's technical definition of these two species in the proposals.
The Birds Directive specifically disqualifies member states from applying derogations to species which are considered to be of "conservation concern" and both Turtle Doves and Quails fall under this category in the European Commission's guidance documents.
The government bypassed this problem in the case it argued before the EJC by citing global statistics by the International Union for Conservation of Nature, which do not place any conservation concern on the species on a global level. The hunters' federation is doing the same in its proposals, but Mr Temuge insisted this was scientifically and legal incorrect.
"Any derogation in the EU will consider the conservation status of the species in question within the territory of the European Union and not the populations for example in South America that do not migrate to Europe," he said.
If Birdlife is right, this alone could mean that Malta can end up before the court again should the government open the season.