December 2021

The Low Impact Fishers of Europe (LIFE) calls on the Council of Ministers not to institute a closure of all eel fishing in 2022, as recommended in the ICES Advice of November 4 2021. This is not needed; it would be counterproductive and would do more harm than good.

Rather “smart measures” are needed to assure fluvial continuity from source to sea, measures to stop eels being killed by hydro-power plants and industrial water abstraction, and an end to the illegal capture, trade and trafficking of eels.

Any restrictions on eel fishing must be commensurate with the impact of the fishery. Marine catches are estimated to only cause 3% of eel mortality, and marine fisheries have relatively little impact on the biomass of the silver eel or their ability to reach the spawning grounds in the Sargasso Sea.

Any tightening of measures beyond what is already in place would have a profound impact on the viability of the Baltic Sea small-scale fishing fleet.

In the Baltic Sea, small-scale fishers account for over 60% of employment in fishing, and over 90% of the fleet by vessel numbers, with their catches destined for direct human consumption. But they are gasping for air. Increasingly their options are being closed down. Demise of and restricted access to crucial fish stocks – notably cod, herring, and eel – combined with increasing competition from predators such as seals and cormorants, is undermining the viability of their livelihoods.

Fishing for eels provides an important supplementary activity and source of income to small-scale fishers in the Baltic Sea, without which their livelihoods would become non-viable.

There are signs that the European Union’s Eel Regulation (establishing measures for the recovery of the stock of European eel), implemented since 2009 may be working. Since 2011 the dramatic decline in eel populations (90% over a few decades) seems to have been halted, and since 2013 eel restocking programmes are showing some increasing trends. According to Willem X. Dekker, a renowned eel biologist: “We are not sure that the Eel Regulation works, but we know that the expected effect does happen”.

According to DG Mare: “in the Member States having developed a comprehensive eel management plan, the Eel Regulation ((EC) No 1100/2007) has been effective.

For years eel fishers have been engaged in conservation efforts based on catching and transporting eels to stop them getting blocked by dams or damaged by hydropower installations. Europe has 12 million dams – one for dam every 400 metres of water. It is these barriers to eel migration and the damage being done to eel habitats, including the draining of wetlands, that are amongst the principle causes of eel declines.

Marine catches impact marginally on European eel stocks – causing only 3% of the overall mortality. In 2018 DTU Aqua concluded that capture of adult eels in

the marine areas has relatively little impact on the biomass of silver eel. However, predation and other anthropogenic impacts account for nearly 50% of eel mortality. In addition, the larval stages of the European eel are subject to large-scale illegal capture, trafficking and trade, described as Europe’s largest wildlife crime.

This is not to belittle the vulnerable situation of the European eel. The species is listed as critically endangered by the International Union for Nature Conservation (IUCN). The species also appears on CITES Appendix II, and is listed by the Convention on the Conservation for Migratory Species of Wild Animals (CMS). Urgent action is needed to bring the European eel back from the brink.

In 2017, LIFE recommended a 5 point plan, which we stick by today. This includes:

· Introduction of an all-encompassing Catch Documentation Scheme for European eel – for all stages of its life cycle;

· Increase efforts to curb the illicit capture, trade and trafficking of eels

· Facilitate eel migration by enhancing fluvial continuity from source to sea – including through “smart measures” based on eel migratory habits

· Reserve the glass eel fishery for restocking purposes only

Closure of the eel fishery in LIFE’s view would be counterproductive. Controlling and monitoring legal eel fishing and trade effectively would provide scientists and regulators with an important source of information on eel dynamics. It would also help to shine a spotlight and expose illegal eel catching and trade.

According to Andrew Kerr of the Sustainable Eel Group: “if we close the fishery, we will not save the eel. We will open up the rivers to uncontrolled poaching – widespread, widescale and on an incredible basis…”

So, please let’s preserve the fishery, conserve the European eel, and save the small-scale fishers.

Tuesday 30 November, Brussels. The Fisheries Committee responded to the “own initiative report” (INI) on “the small-scale fisheries situation in the EU and future perspectives”. The report is being prepared by João Pimenta Lopes from the Left Group (GUE/NGL).

The report is due to be completed by April 2022 and comes at a key moment in European fisheries policy making processes: by the end of 2022 the European Commission (EC) must report on the implementation of the Common Fisheries Policy (CFP), and during 2022 the EC will publish a proposal for an Action Plan to Conserve Fishery Resources and Protect Marine Ecosystems. The Action Plan is an integral part of the Biodiversity Strategy, designed to achieve the objectives of the EU’s Green Deal.

Both these processes are of key importance to small-scale fishers (the passive gear fleet segment using vessels below 12 metres) representing as they do 75% of the fleet and 50% of the jobs at sea. The CFP is notoriously biased towards larger scale fishing activities which take the lion’s share of the catch (over 90%) although representing only 20% of the fleet, with trawling being the dominant gear used.
The Action Plan aims to reduce the impact of fishing on the environment, notably on the seabed, in order to conserve biodiversity. From the Commission, Lena Andersson Pench highlighted the importance of small-scale low impact fishing in the transition to lower impact fisheries as envisioned by the Action Plan.

Given the way that the rights of the small-scale fleet have been prejudiced by successive CFPs – notably with regard to access to resources – this is an opportunity to examine how to right many of the historic wrongs. These include redirecting the way that subsidies for fisheries are used to support collective projects, encourage young fishers, provide capacity building and support cooperatives

Lopes’s draft report deals with the gamut of issues facing small-scale fisheries. A key theme of the report is that given the differences between small and large scale fishing, a differentiated approach is needed. “You don’t treat things that are different in the same way”, he said. Small-scale fishing requires a different treatment to large scale fishing, which means that both types of fishing need to have their roles, place and space more clearly defined, recognized and respected.

Amendments to the report will be discussed in the Pech Committee on December 17, with voting on the report scheduled for April 2022.

Draft INI Report on the small-scale fisheries situation in the EU and future perspectives.

You can watch the video of the Pech Committee discussion here. (minute 0.44.16 to 1.34.00)