As previously noted to all of you, there is now an open consultation from the EU Commission regarding the effectiveness etc of the current eel regulation. I have made a “template” response that I hope can serve as inspiration and help for you all to reply to this consultation. It is fine to reply with similar words (even just copy paste) as it is still useful for the Commission to show the interest and amount of replies indicating that the plan is not enough, has not been implemented properly etc. The open consultation can be found here: https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-1986447/public-consultation_en
What I have done is download the questionnaire and marked responses with yellow in the PDF. Then there are a number of open answer questions numbered in the word document and corresponding the the question in the form you must use to reply online. For all those I have written comments. Both attached.
The deadline is March 8th so there is still some time to get this done.
The crucial points:
- the national plans have not been fully or equally implemented across the EU and not in the Baltic either.
- because the plans are national, they have serious flaws because a nearby country may not take the same measures thus cancelling out what has been done upstream so to speak
- the plans seem to both aim at keeping a fishery open and increasing eel recruitment and this is not acceptable, example: restocking eel not to increase the eel stock but to be able to keep the fishery open.
- the regulation itself is not ambitious enough and not in line with other legislation (CFP, WFD; MSFD etc) and it leaves far to much to MS to “decide” and not enough oversight and strong tools for the EU to act when MS do not implement. A new regulation needs more of both stick and carrot and less freedom to MS to design their own plans.
- The plans targets are not sufficient and not in line with ICES advice of as close to zero mortality as possible
Please, please take some time to reply to this consultation. If you like you may note your responses as “anonymous” meaning that they will be shown only to the Commission