https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:C_202404214

This document relates to the European Parliament resolution of 21 November 2023 on the implementation of Council Regulation 1100/2007 establishing measures for the recovery of the stock of European eel.
It confirms what French professional fishermen have been saying, and has apparently not been taken into account by either our administration responsible for fisheries and environmental protection or the European administration responsible for fisheries.
One point in particular draws our attention: ‘Member States’ reports are often incomplete and non-standardised’ (recital G), and over time fewer and fewer Member States are submitting them.
As AFPMAR has already mentioned, this incomplete and uninformative reporting can be applied to the draft report drawn up by the French administration which, in fine, is an anti-fisheries report that overlooks the effects and impacts of other uses.

It is important here to realise that the document we are talking about is the opinion of the European Parliament, which has not been taken into account, or only very partially, by a national or, more broadly, a European administration that shows a desire to treat fishing as an adjustment variable or as an expiatory victim for obvious reasons of convenience or, worse still, of complacency for activities deemed essential to the development of our societies. This is to forget very quickly that without fishing and agriculture, our food security will no longer be assured, and that all activities other than fishing that harm the productivity of aquatic environments must imperatively minimise their ecological footprint, and even more so in the context of climate change. The survival of the eel and the pursuit of related activities are at this price, and our administrations would do well not to forget it.

This document makes this clear, emphasising a number of points that have caught our attention:
1- The Eel Regulation is the most appropriate global instrument. ‘It is at the core of the eel stock management and recovery policy, ensuring a comprehensive and coherent approach that also provides for the full application of measures in other relevant areas outside fisheries’;
2- ‘Stresses that the data shows that the decline in the recruitment of glass eels and yellow eels has stopped since the adoption of the eel regulation’, which is ignored by DG FISH, which bases itself on ICES and GFCM expert reports that do not take into account the data collected on the field by professional fishermen;
3- ‘Is seriously concerned, therefore, by the reductionist approach adopted in the Council Regulation amending Regulation (EU) 2023/194 of 30 January 2023 defining for 2023 the fishing opportunities for certain fish stocks,….. which restricts eel fishing by means of a 6-month closed season, without providing for a comprehensive package of measures extending to other policy areas and adequate compensation’;

4- ‘Calls, therefore, for the creation of an eel-specific expert group that ensures the full and balanced representation of all relevant stakeholders’;
5- ‘Draws attention to the important role that eel fisheries play for society, particularly in the local communities where they are practised, as eel fisheries are both a socio-economic activity and a centuries-old cultural tradition; notes that eel fisheries have declined considerably over the last decade; calls on the Commission and the Member States to monitor existing fisheries restrictions and, where appropriate, to propose measures to improve the sustainability of eel fisheries; Stresses that commercial and recreational fishermen have an important role to play in data collection and as guardians and ‘eyes and ears’ of our seas and rivers, and are thus a valuable asset in the fight against illegal, unreported and unregulated (IUU) fishing; stresses that eel fishing is a small-scale artisanal activity and is often located in rural and remote areas, where commercial and recreational fishermen play an important environmental and socio-economic role’;

6- ‘Reaffirms that restocking is one of the recovery measures listed in Article 2(8) of the Eel Regulation; is of the opinion that restocking is a necessary measure in the short to medium term until the problem of migration barriers has been adequately resolved’;
7- ‘Stresses that further efforts are needed with regard to factors other than fishing that have an impact on eel mortality; stresses that infrastructural barriers are one of the most detrimental factors with regard to eel mortality; notes that this problem has not been sufficiently addressed by the Member States, as demonstrated by the Commission’s evaluations in 2014 and again in 2020’. This is a subject on which professional fishermen are constantly intervening and calling for the ‘polluter pays’ principle to be applied by an administration that is too accommodating towards energy producers in particular. Little effort has been made by Member States, and France in particular, to assess impacts and effects other than fishing, despite the fact that the degradation of aquatic environments is obvious and has been highlighted by reports from the Water Agencies.;
8- ‘Encourages Member States to pursue trapping and transfer projects as well as assisted migration as a temporary solution for the escape of silver eels, should structural solutions not be possible in the short term’. This is contrary to the decisions taken by the French administration to shut down or hamper projects proposed by professional fishermen in cooperation with research bodies to assess silver eel populations on major rivers.

These considerations, expressed by elected representatives of our communities, should be followed. It has to be said that this is not the case and that the current policy pursued by our administrations, sometimes cynically [1], is to eradicate, for the sake of simplicity, an activity whose future is linked to the productivity of aquatic ecosystems.
AFPMAR has put forward a number of proposals within a framework that is intended to be global and characterised by more democracy and less technocracy.

First of all, French reporting is incomplete and not in line with what the European Parliament is asking for and with this implementation of the European regulation on eels. The solutions proposed by the administration are sector-specific and do not take into account, or even ignore, the socio-economic imperatives of fishing and traders companies. Management plan assessments cannot continue to be based on truncated reports which, at the scale of the species’ range, do not even take into account most of the information gathered in the field by those who hold it and make it available to managers: for example, the non-use of classic indicators such as CPUEs for elver fishing in order to have indicators for the evolution of estuary recruitment. The indicators used by ICES and adopted by the GFCM are biased (mixing indicators from the Atlantic and Mediterranean areas, ignoring information from the main French glass-eel fisheries) and unrepresentative of changes observed in the field by French professional fishermen, as shown by the difference between the value of the indicators provided by experts and the feelings and observations of professional fishers in the field.

Simple solutions exist that would make it possible to reconcile both minimising the ecological footprint of fishing and maintaining the economy of the fishing industry, particularly that of the glass eel fishery, which has paid the highest price (400% loss of value since the introduction of Regulation 1100/2007) under this eel regulation. These consist of modifying the consumption/repopulation distribution key and defining a sub-quota on the consumption quota for exports outside the EU that are not prohibited by CITES for species classified in appendix II.

When it set up its Management Plan, France defined a consumption sub-quota and a restocking sub-quota in accordance with EU requests. This was done in order to facilitate exports outside the EU of all or part of the consumption quota. As far as the future of the species is concerned, whether the glass eel is consumed in Europe or Asia, it is clear (or it should be for a European administration) that its fate will be the same biologically: it will not contribute to the production of silver eels in the natural environment. In economic terms, however, the deficit generated by this incomprehensible administrative decision is considerable. In 2016, the average ex-fisherman price for American glass eel in the State of Maine was US$3,500, more than 10 times the average price paid to fishermen on the European market. It’s an economic and social waste that France could certainly have done without, without affecting the future of the species. A quick calculation shows that with an export quota outside the EU of 10 tonnes (less than half the consumption quota) since 2010, the fishing and fish trade has lost €400 million in revenue.

Instead, without any prior assessment of the management plans or evaluation of the socio-economic impact, DG FISH is defining fishing periods that are incompatible with the survival of fisheries businesses, while blocking glass-eel production on a European market that is not very dynamic and is mainly in the hands of the eel farming industry. This is totally at odds with the considerations put forward by European elected representatives in implementing Regulation 1100/2007.

Finally, a concerted restocking plan on a European scale, financed by water users other than fishermen on the basis of the polluter-pays principle, must be put in place. This large-scale restoration plan must be implemented in such a way as to guarantee the traceability of the eels intended for restocking, so that they do not constitute a by-product with a high value added to low-growth eels.

[1] For example, the allocation of professional fishing licences in the Rhone basin, with quotas of just a few kilos per season, would not cover the costs involved. Or banning elver fishing for 6 consecutive months during the main upstream period, which only lasts 4 months!