Patrick Barkham, in his article of the 22nd of October, titled “UK export of millions of endangered eels to Russia attacked as bonkers”, is correct to the extent that millions of critically endangered eels have indeed been exported from the Severn estuary to Russia this year. What is not reported is that this is part of a conservation project that was in development before the invasion of Ukraine by Russia.
The project is to transport juvenile eels from the Severn Estuary to the Vistula and Curonian lagoons, which Russia shares with Poland and Lithuania.
Unlike the Severn River Basin District (RBD), the lagoons are pristine habitats for eels with unrestricted migratory pathways to the Baltic. In contrast, the wetland eel habitat of the Severn has been destroyed by modern agriculture, industry, housing estates and pollution. What little remains is inaccessible to the eels because of the canalisation of the River Severn with locks and weirs for commercial and leisure, flood defences and other man-made barriers to migration.
The consequence is that the majority of the eels that swim into the Severn estuary perish when stopped by these barriers.
The scientific basis for the project is set out in the European Union eel regulation 1100/2007. The essence is that the natural eel population in these two lagoons has declined. There has been some limited stocking by Poland but virtually nothing from Lithuania. The objective as set out in the Eel Management Plans is to achieve silver eel escapement to equivalent to 40% of the EU escapement target as set out in the EU eel regulation 1100/2007. An approved management plan sets out how this escapement will be monitored and safeguarded. As recruitment is low, this can only be achieved through stocking. The stock is being supplied from the Severn as this system has a surplus of glass eels over and above what is required to meet its now depleted carrying capacity. This set out in the Joint Nature Conservation Committee (JNCC) report No. 745. Whilst ICES (International Council for the Exploration of the Sea) recommends that any Non-Detrimental Finding (NDF) is made at the level of the full stock, evidence provided here demonstrates that a positive NDF can be made at smaller spatial scales. Using this approach, the NDF justifies continued sustainable trade from the two main UK fisheries.
In addition, unlike the highly mechanised industrial fisheries of the rest of Europe, the UK glass eel fishery is a hand net artisan fishery using the same methods that go back to time immemorial. As such it is the most environmentally sensitive fishery in Europe the JNCC report indicates that recruitment is well in excess of the carrying capacity of the river basin. Our own peer reviewed and published study on the Severn the exploitation rate was 7.8%. The study confirms that the fishery is not a significant cause of the Severn RBD failing to meet escapement targets but rather the destruction of the habitat.
The Russian federation has developed a forward-looking environmental project which will assist the recovery of European eel all across Europe. Once operational it will be the largest recovery plan for the eel anywhere in Europe. As the eel is a panmictic species, every country in Europe will benefit from this plan. This is an international conservation opportunity not to be missed or sidelined. Using our soft power, we have been able to encourage alignment with EU policies. For example, the Federation plan was to stock with Juvenile eels greater than 10 gms. Our policy is to have shorter quarantines and to stock with juveniles of just 1-2 gms. Long quarantines may run the risks of altering sex ratios and imprinting behaviours that relate to the artificial environment of the quarantine. For the Curonian and Vistula lagoons it is now agreed that artificially stocked eel should be marked with strontium chloride. In the long term this will enable the efficacy of stocking to be measures against natural stocking. There is also a six month ban on eel fishing in the lagoons that is aligned with EU policy COM(2024) 506.
As to the banned trade for European Eels. It is not quite as straight forward as described. The EU banned all trade in European Eels across all its borders irrespective of whether it was inside or outside the eels’ natural geographic range. There is however, still a very significant internal glass eel (juveniles) trade within the EU. The French quota for glass eels was 65 tonnes last year and the production from Spain and Portugal another 15 tonnes giving a total of 80 tonnes of legal trade for consumption, aquaculture, and stocking. In addition to this legal trade, Europol state, supported by the Sustainable Eel Group (SEG), that the historical illegal trade of glass eels from France, Portugal and Spain was in the order of 100 tonnes. If this is not additional catch then it would have come from legal traders some of which would have been SEG certified suppliers. It is in any event a significant quantity of glass eels when compared to the trade of 1 to 3 tonnes of the conservation project.
On other points of detail, it is not true that the conservation project exploits a loophole in the legislation. The EU has banned trade across its borders but it is still allowed elsewhere. With Brexit, the status of the UK changed. The UK is no longer a member of the EU, it is no longer represented at the Science Review Group (SRG) meetings in Brussels, it has now become a third country and trade between third countries is permitted. (provided an appropriate ‘Non-Detriment Finding’ has been approved and other permitting conditions are met).
Andrew Kerr states that the glass eels could be smuggled eastwards towards Asia if exported to Kaliningrad. The allegations that Kaliningrad is the centre for illegal trade in glass eels are not supported by any evidence and are simply not true. This conservation project is a government contract, with a large investment in the quarantine and the “growing on” facility to rear the glass eels into small juveniles before release which negates any economic motivation to export to Asia. Certainly not economic. The eel management plan sets out in some detail how the objectives of the project and traceability of the stock will be achieved.
This contrasts with good evidence that some illegal and unregulated trade is still taking place in France, Spain and Portugal but not from the UK. There is full traceability of stock within the UK.
As to Andrew Kerr’s statement it was not good conservation practice to send the eels to the eastern edge of their natural range. He has not until now raised any objections to EU stocking in the Baltic countries, Poland, Lithuania, Latvia and Estonia, only Kaliningrad. There is no evidence either way to indicate where stocking would be best to produce the greatest net benefit to the species. The protocol of the project to mark the artificially stocked eel with strontium chloride should in future provide the scientific evidence to determine the latter.
As a member of SEG he also conversant with the fact that as an increase in the population density of glass eel incurs there is a greater natural mortality. The most successful stocking in Lough Neagh is in the range of 300 glass eels /hectare. Natural glass eel recruitment of the Severn can be counted in tens of thousands of individuals per hectare. There is no escapement. A greater net benefit can be. How were the assets and liabilities transferred. Where are the records? achieved by lowering the local density of the glass eels by capture and stocking at lower densities in an alternative pristine habitat.
The estimate given that 100,000,000 glass eels swim into the Severn is a lot less than the recent estimate produced by CEFAS, the UK Government Centre for Environment Fisheries and Aquaculture Science. However, based on the assumption by Charles Foster in the Guardian that 100 million glass eels enter the Severn and that the UK fishery currently takes 3 million there is a surplus for stocking. In reality CEFAS data indicates that in terms of glass eel numbers the L95 value = 626,123,520 and the U95 value = 3,403,717,172. Put simply there is a 95% confidence that the true glass eel population mean is between L and U and this is at least six times greater than the 50-100 million quoted. The reference for the report is (Robinson D. Maxwell, M Breckels (2021). SP107 Worst case glass eel entrainment assessment for HPC. Predicted whole estuary glass eel biomass (Table 4, page 24)). Sadly, most of the surplus stock that remain in the river die due the loss of habitat, barriers to migration and high stocking densities.
The translocation of live glass eels from the UK to Germany started in 1908. In the last 50 years we have sent more than 1000 million glass eels to locations all across Europe in order to support the recovery of the European eel
While it is not agreed, the best approach would be to tackle the root causes of the low rate of escapement of silver eels from the Severn RBD by preventing further destruction of habitat and removing the migratory barriers from the river. However, in the absence of conservation and governmental organisations with the stomach to do this, due to economic pressures, translocation of the surplus eels to a pristine environment is the only viable option to try to conserve the species, something Andrew Kerr has campaigned strongly against since the start of this project in Kaliningrad.
The exports to the Russian Federation do not serve or further Russian objectives in the war. Quite the reverse. There is a serious investment required to support these environmental projects and not just the costs of the glass eels but also the funding to develop the infrastructure in terms of a quarantine station, a research vessel and the monitoring program. A comprehensive eel management program has been developed by the Russian Federation for this stocking project. The long-term plans do depend on the financial resources available and sanctions are hitting hard. It would be arrogance to believe we have a monopoly in the West on environmental programs and the desire to save endangered species.
The SEG organisation in the early days, did a lot of valuable work in reducing the illegal trade sourced within the EU. However, in 2023 there were still 256 arrests. It has supported the eel farmers in Europe. It has been less successful in supporting and representing the glass eel fisheries in the UK and France.
SEG seems to have lost its direction. Geopolitics now seems to be a priority over the recovery of the eel.
Of course, SEG can make its own decision concerning the geopolitical situation but everyone should be aware that this has nothing to do with sustainability and supporting the recovery of the eel.
07/11/2024
Peter Wood, MRCVS., MSc., B.Vet.Med. Original founder and funder of SEG.
UK Glass Eels 