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November 2022

TP-Eel-fishing

Please Keep Eel Fisheries Open: save the European Eel and small-scale fishing communities

Open letter sent by e-mail to: Member states across the EU

CC: to Commissioner for Environment, Oceans and Fisheries, Virginijus Sinkevičius

Director General for Maritime Affairs and Fisheries, Charlina Vitcheva

BALTFISH, and The Scheveningen Group

Dear Ministers

Please Keep Eel Fisheries Open: save the European Eel and small-scale fishing communities

We write to urge you not to adopt a new regulation, due to be voted on in the December AgriFish Council, to implement a 6-month closure on all European Eel fishing in marine and adjacent brackish waters, as set out in the Commission’s Proposal for fishing opportunities for 2023[1].

This proposal and the current 3-month closure period will shut down the marine eel fisheries for good. It will not save the eel[2], and it will undermine eel management, which is placed – rightfully – within the framework of the European Eel Regulation from 2009 (Council Regulation (EC) No 1100/2007). Furthermore, this proposal ignores many of the recommendations made by ICES in their response to the EU request for technical evaluation of the Eel Management Plans progress reports.[3]

We as representatives of small-scale low impact fishers from across the EU call for:

  • A more comprehensive approach, using both fisheries and non-fisheries related measures, to ensuring the recovery of the eel
  • A renewed focus and more effort on implementing the Eel Regulation, adopted in 2007.

We urge Member States to agree to an alternative to the current 3-month closure.

We request that member states implement measures other than a fishery closure. As specified in the text of the Fishing Opportunities for      2023 proposal, there should be an alternative to the closure period where Member States have the opportunity to implement their own measures to allow eel fishing to continue while still contributing to recovery of the eel.

We also call for improved data collection on the escapement of silver eels and      on glass eel recruitment. Small-scale fishermen across the EU have observed large increases in the abundance of eel at all life stages.

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BACKGROUND: In 2007 EU Member States agreed to establish a framework for the protection and sustainable use of the stock of European eel. EU member states agreed that the target should be achieved in “the long term” (Council Regulation (EC) 1100/2007).

According to the Evaluation of the Eel Regulation from 2020, there have been notable successes in terms of reducing fishing mortality across the EU, but there is still a need for a considerable improvement, especially when addressing non-fisheries related anthropogenic mortality[4].

Measures stipulated in the national eel management plans have been adopted since 2009, however, implementation can and should be improved. Fishers           have played their part. Furthermore, the decline in glass eel recruitment has been halted. The generation time of eel is around 13 years, and measures have been in place for 13 years.

It was never the goal – nor possible – to rebuild the eel stock in such a short timeframe. Eel recovery will take a long time. Today we are in a better situation than when the eel regulation was adopted. Things are going in the right direction.

Despite this, you – EU Ministers and the European Commission (EC) – have started to take measures outside of the agreed Eel Regulation.

Since 2018 the AgriFish Council of Ministers and the Commission have moved decisions on the management of the eel to the yearly TAC negotiations in December.

We see this as a very dangerous move, which we believe will jeopardize the implementation of the Eel Regulation, and thereby the possibility of the Union, to rebuild the eel stock and preserve the associated fisheries. The result will be complete failure in achieving the key objectives of the Eel Regulation.

Those engaged in the fisheries have done much. Closing fisheries will be counterproductive and,according to ICES, will be insufficient to ensure the targets are reached.

Fishermen across the EU have engaged in the rebuilding of eel stocks for the last 13 years. They have reduced their fishing effort in line with the agreed EU Eel Regulation, in the belief that Member States and the EC would also implement       other, non-fisheries measures, as well as establishing a fit for purpose data collection system.

Due to a failure by Member States and the European Commission to do so, fishermen will again pay the price. We      as fishers      can, and will, contribute to eel conservation, employment and food security. If we are allowed to.

We urge you to not to make small scale fishermen pay the highest price. Please don’t close our fisheries: give the Eel Regulation time to work, implement the other needed measures in the member states, and implement an improved data collection on glass eel recruitment and silver eel escapement.

With kind regards,

Brian O’Riordan

Executive Secretary, LIFE

[1] Press release from EU Commission, 22nd of October 2022, link here.

[2] Although reduction in marine catches is expected to have a positive impact on the potential spawning stock in the long term, none of the options suggested above would be sufficient to achieve the 40% escapement biomass target of the EC Eel Regulation for any sea basin by 2020”. ICES: EU request to provide advice on fisheries-related anthropogenic impacts on eels in EU marine waters, 2017.

[3] ICES (2022): EU request for technical evaluation of the Eel Management Plan progress reports. ICES Advice: Special Requests. Report. https://doi.org/10.17895/ices.advice.19902958.v2

[4] European Commission, Directorate-General for Maritime Affairs and Fisheries, MacNab, S., Luchetta, G., Nimmo, F., et al., Evaluation of the Eel Regulation : final report, Publications Office, 2020, https://data.europa.eu/doi/10.2771/679816

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Call to Action: Better Implementation of the Common Fisheries Policy through a Differentiated Approach

,

In Europe, fishing provides an important source of food, social cohesion, livelihoods and economic activity in coastal areas. Fishing thus provides a socio-economic and cultural anchor for communities with few alternative options. Fishing and fishing communities also contribute to our collective cultural maritime heritage, to biocultural diversity and to our knowledge of the seas and natural phenomena.

There are two very different approaches to fishing, based on very different social, economic and environmental logics. Larger scale industrial operations using towed gears, catch tonnes of fish per day, spend several days at sea, provide fish for mass markets, and generate hundreds of thousands or millions of Euros per year. However, these operations cause significant damage to seabed ecosystems and through their use of non-selective gears impact negatively on the reproductive capacity of fish stocks.  Smaller scale, low impact artisanal operations use passive gears, catch tens of kilograms of fish per day, providing a high-quality value-added product to a different market segment, generating on average a few tens of thousands of Euros per year. Their use of selective gears results in significantly fewer discards.

Through targeted support and a favourable regulatory framework, successive Common Fisheries Policies have incentivised larger scale fishing at the expense of the smaller-scale sector. This has created distorted seas across Europe, with most of the fishing opportunities concentrated in few hands, with markets dominated by relatively few high-volume commodity species.

9 years after the adoption of the reformed Common Fisheries Policy (CFP) in 2013 and its implementation in 2014, the intended improvement in sustainability outcomes for the small-scale low impact fleets across the EU are not being delivered; the opportunity to harness their potential to achieve wider social, environmental and economic sustainability goals is being squandered. Measures intended to support small-scale fisheries in Regulations (EU) 1380/2013 (notably Article 17), 1379/2013 (notably Producer Organisations), and 508/2014 (notably under Article 18 concerning the elaboration and implementation of action plans for the development, competitiveness and sustainability of small-scale coastal fishing) are not being applied.

Small-scale coastal fisheries represent 76% of the fishing fleet by vessel numbers, and provide 50% of the jobs at sea. Small-scale low impact fishers fish in the least environmentally damaging ways to provide the greatest benefits to society. Yet they are restricted to landing 5.8% of the catch[1].

Evidence indicates that if small scale fishers were provided with the enabling policy environment intended by the CFP and the political will to implement it[2], small scale low impact fisheries could make all the difference between success and failure in the implementation of the 2014 CFP and the Marine Spatial Planning Framework Directive; achieving the targets set by the Marine Strategy Framework Directive for Good Environmental Status by 2020, meeting the goals of the European Green Deal, associated Biodiversity Strategy (including the Nature Restoration Law); and its international obligations adopted as part of the Rio + 20 (UNCED) process, including the Sustainable Development Goals (SDGs) – notably SDG target 14b).

We therefore call on the European Commission and EU Member States to adopt a differentiated approach to fisheries management based on:

  • Inclusive Blue Economy. Place small-scale fisheries at the heart of Blue Economy and protect it from displacement and spatial squeezing by competing or incompatible activities. Do not allow or support any new ocean use that may negatively impact marine ecosystems and the communities that depend on them for their livelihoods; and invest in long-term fisheries management, resource conservation,  ecosystems restoration and innovations introduced by women and men from fishing communities.
  • Fair access to fishery resources. An equitable allocation of fishing opportunities to small-scale low impact fishers, using Article 17 to reallocate fishing rights to smaller scale, environmentally compatible, economically viable and socially responsible fishery activities, rewarding a positive history of compliance and ending the sole use of track records as the tool for allocating fishing opportunities by member states, and putting an end to the privatisation of fishery resource access.
  • Fair access to restored and co-managed fishing grounds. Secure wider inshore fishing areas reserved for small-scale low impact fishing, effectively managed through adaptive local co-management regimes in which small-scale fishers are supported to participate effectively;
  • Reduce environmental impacts of fishing and end discards. Legislate for more diversified, polyvalent, seasonally sound and selective fishing (right gear, right time, right place) to end discards; phase out those high impact gears that have unacceptably high by-catch rates of uneconomic and vulnerable species and of fish below minimum size, and which cause the most damage to seabed, habitats and marine ecology.
  • Fair access to markets and sustainable food systems. Differentiation of small-scale fishery products in the market through traceability, Community Supported Fisheries and direct, short chain, marketing schemes, empowering fishing organisations to become price makers. Establish an enabling policy framework for establishing small-scale Producer Organisations, based on value not on volume.
  • Invest in appropriate infrastructure and climate change resilience. Provide for specific small scale fisher infrastructure investment to improve facilities in landing areas, strengthen short supply chains and food security, and prioritise decarbonisation of the small-scale fleet. Fastrack research and investment into fossil fuel alternatives for the small-scale fleet and associated supply chains; and support fishing communities to mitigate impacts of, and adapt to climate change.
  • Public monies for the common good. Develop a code of practice for financing sustainable small-scale low impact fisheries. Establish a level playing field by ending inequitable subsidies and other incentives which disadvantage the small-scale sector. Public monies should be used for public good not individual gain, to promote fishing better (quality) not more (quantity), through collective projects.
  • Improved EU Governance. Full implementation of the CFP regulation objectives. End ambiguity between the responsibilities of the European Commission and those of member states in the implementation of the CFP to ensure accountability. Full transparency must be adopted in the implementation of the CFP to ensure that public fishery resources are being used for the public good. Ensure coherence between fishery and environmental regulations so they work in harmony to achieve their respective objectives while maintaining biocultural diversity, cultural heritage, equity and social cohesion.
  • Inclusive policies for present and future fishing communities. Recognise and respect the role of women and support fishers of the future through affirmative action initiatives to promote gender equity and inclusion of youth towards equitable generational renewal.
  • Dedicated Research. Specific small scale fisheries research and development to be promoted and resourced through EU and national research programmes, prioritising good cooperation with the SSF sector and the incorporation of Traditional Ecological Knowledge.
  • Align CFP with global frameworks and international obligations. Ensure that the CFP, the CMO and associated fishery and environmental regulations fully comply with the letter and spirit of the FAO Voluntary Guidelines for Securing Sustainable Small Scale Fisheries and contribute to the Sustainable Development Goals.

[1] Data from the 2022 Annual Economic Report on the EU Fishing Fleet (STECF 22-06), STECF https://stecf.jrc.ec.europa.eu/documents/43805/35330729/STECF+22-06+-+AER+2022.pdf/e9f061e5-cd7e-4f20-9bba-afc67dea695f?version=1.1&download=true

[2] European Parliament Resolution of 7 June 2022 on the Implementation of Article 17 of the CFP Regulation (2021/2168 INI) https://www.europarl.europa.eu/doceo/document/TA-9-2022-0226_EN.html

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