Comments to the evaluation roadmap of the eel recovery plan and national implementation of the plan

The Finnish Association for Nature Conservation thinks that this evaluation is extremely important for the future of critically endangered Eel.

We stress, that this can be the only time to update these management plans for a long time. That is why evaluation should be done properly. If more time is needed for studies, the timetable should be flexilble.

The evaluation should ask if these Eel plans are still fit for purpose. This means, that It is important to compare measures and results to the conservation status. It is not enough to technically check whether Member States have implemented their own plans or not.

– For example, the Finnish Eel plan is very bad: The main idea is to take juvenile Eels from UK to Finnish lakes, so they can die in hydropower turbines when swimming back to the sea. Finnish Eel plan has no measures for fishways etc.

The evaluation should make an critical analysis about moving Eels from one country to another, like from UK to Finland. Is there even public money – EMFF and national money – in this work? Are they harmful subsidiaries?

Are there best practices about EMFF projects with Eel, e.g. fisways or dam removals?

WFD can be an important tool, including possiblities to make fishways or remove dams to open rivers for migration to the seal. The basic question is how Eel and fishways have been taken into account in RBMPs. And how Eel is covered in the plans of the MSFD in coastal areas?

It is important to study why regionalisation failed with Eel. Why Member States want to have just this species managed in the EU level? Could there be some added value in e.g. Baltic Sea measures?

How are HELCOM and other seas conventions working with Eel?

How Eel policies are in the line with international conventions, as CBD, CMS and CITES?