Looking a bit like a Penis
Fairly recently, in the huge scale of time when tiny transparent young eels ( glass eels or elvers) have been quietly infusing our estuaries, swimming (the comparison is unavoidable) sperm-like each spring up every river, into every lake and ditch and wetland, feeding otters and bitterns, bringing an injection of fertility from the far Sargasso, it turned out to have been a bad plan for an adult eel to look a bit like a penis. That may be the entire reason why Far Eastern cultures developed the rage for the eel that threatens with extinction the Japanese eel, the European eel, the American eel and any other eel species they can get their hands on. For by the same sort of sympathetic magic that makes the Chinese value tiger penis wine, the eel is thought to give what the Japanese call biyaku,, vigour, and that may be the reason why they are prepared to pay extraordinary prices for the young eels fished in places like the estuary of the Severn or the Loire. For by vigour they do not mean just the extra energy that might send you out to mow the lawn. We are talking about eating eel in much the same way as we used to talk about eating oysters. Some appetites are about much more than nutrition. This was why the elvers of the River Severn were quietly scooped up every spring and air-freighted to eastern eel farms, scarcely noticed by governments, conservationists or even newspapers, who seemed more interested in stories of Gloucestershire quaintness for the Sunday supplements. It has been touch and go whether world eel populations would tide them over until the invention of Viagra, and now of course they have developed such a taste for it that eel in sushi is part of the world-wide Japanese brand.
It was the EU, not any UK government, that finally got around to banning the trade in European Eels outside Europe, creating overnight a massive smuggling problem. But it was the UK government Department for the Environment, Food and Rural Affairs (Defra) that sanctioned the creation of a loophole that they thought allowed the last elver merchant in the UK to ship elvers to Russia, which was widely criticised by environmentalists and seen by many as undermining the efforts of the EU to control the elver trade and elver smuggling.
Now under the new government Defra will be reviewing all their policies, but I suspect the culture of the English establishment and the powerful lobbying of the landed interest has had a pervasive effect on Defra staff who seem drawn to the values and attitudes of the propertied classes rather than those of conservationists, and may naturally tend to advance the perceived and short-term interests of landowners and businesses when they conflict with the protection of the environment.
This trade in elvers has been quietly sanctioned by Defra and the Environment Agency largely behind closed doors. If you search the internet for elver export statistics you will almost certainly find nothing about this Russian trade, which has been slowly growing now for some years; all I found was a very oblique reference that did not actually name Russia at all, simply mentioning exports to what they call a ‘range state’. Environment Agency sites state categorically that eels or elvers from the UK cannot be exported to anywhere outside the EU under European eel protection legislation and regulation to which the UK is a signatory. If you submit a Freedom of Information request to Defra about permits to export elvers to Russia you will get a very heavily redacted copy of the export permits – “commercial confidentiality, old boy! “ – and of course you would have had to know about the trade in the first place to make such a request.
Many of us in the English eel community find it very difficult to understand why Defra, alone in Europe, has found a way to justify giving permits to trade in elvers to Russia. Defra more than many government departments has to balance the benefits of trade to the local or national economy against their clear legal duty to protect and enhance the natural world, as set out in legislation such as the Environment Act of 2021 which requires all government department to work towards the enhancement and improvement of biodiversity, going beyond the mere – very mere - maintenance of biodiversity in its current state.
Elver fishing in the UK chiefly – very chiefly, actually – benefits one man, the owner in Gloucester of UK Glass Eels, an elver exporting company. At one time during the gold rush days when we sent elvers to the Far East as fast as if to try to ensure there would be no tomorrow, maybe 300 local men went out elvering during the season, but there has never been a professional fishery. This has always been a part-time beer-money fishery, apart from a period during that gold rush in the ‘90s when the trade to the Far East drove prices up and there was more beer money than you could shake a stick at as the elver merchants fought for their share of the bonanza. Since the EU banned the export trade to countries outside Europe the fishery has declined. There is, since Brexit and the Northern Ireland protocol, virtually no legal market for UK elvers, and only this one elver merchant remains, who can buy elvers cheaply because he has no competition. There are now only a handful of very seasonal elver fishermen. For Defra and the EA to permit elvers to be exported to Russia cannot be justified as supporting local fishing communities. There are none. The many vernacular fisheries of the Severn, such as the salmon putcher ranks and the compass nets, have long gone except for those few nostalgics who go out with lave nets in the estuary to chase very rare salmon that they are not allowed to keep.
So the benefits of trading elvers to Russia accrue mainly to one old man who has been very efficiently exploiting elvers for maybe forty years, and as wages to his manager and company secretary, to some seasonal part-timers and maybe to his lawyers. On the other side are the endangered eels, so much at risk that some European countries (Ireland and Slovakia) have completely banned all forms of eel fishing.
What is it about the trade to Russia that trumps the duty of Defra and the Environment Agency to protect eels, to enhance the natural environment, and to support European legislation to protect eels and counter elver smuggling?
A previous piece explored some of the background to this trade, supposedly to a restocking project in the Vistula and Curonian lagoons near Kaliningrad: https://richardfleming.substack.com/p/the-end-of-elvering
Defra and the EA appear to have allowed themselves to be convinced that this export trade is to a restocking project. Restocking is not necessarily the same as conservation, and the conservation value of restocking is questioned by some eel biologists. The lagoons apparently being stocked are and will be fished commercially, and this ‘restocking’ will be of no benefit to the European Eel breeding stocks unless some of the eels are allowed to mature, to become adult Silver Eels, and to escape to their mating grounds. Under European eel regulations the aim should be for the equivalent of 40% of the silver eels of a theoretical pristine biomass to be able to escape to breed, but it will be almost impossible to count how many silver eels escape from these lagoons, so that Defra has no way be sure that this project is compliant with Europe-wide requirements. The Kaliningrad Eel Management Plan seems particularly questionable on the matter of silver eel escapement, using modelling and calculus and so forth sometimes copied from elsewhere and lacking important elements (e.g. fishing pressure). This purely theoretical ‘modelling’ cannot in my view give Defra any assurances (1) that any silver eels will escape to breed or (2) that they will ever get any concrete evidence of this, and this is before the silver eels have to run the gauntlet of the pound nets set for them in the western Baltic and in the Kattegat, the narrows between Denmark and Sweden where the Baltic runs out into the North Sea. That some eels should escape to breed (the often quoted 40% escapement) is fundamental under the terms of the European Eel Regulations. If there is no verifiable escapement of adult eels from the Kaliningrad lagoons the house of cards collapses.
Although Russia is under sanctions and at war with Ukraine and, by proxy, us, and run by a dictator, it seems likely that the ‘restocking’ project is run by serious and competent people. A commercial aquaculture company called Gudfish appears to be central to the project, apparently holding the elvers in tanks, quarantining and feeding them, and releasing some of them into the Vistula lagoon at various sizes. The entire approach seems to be commercial, and possibly very efficient, but that does not make it a conservation project. Because no EU country will allow the export of elvers to Russia, this Russian project has become entirely dependent on buying UK elvers, and for similar reasons UK Glass Eels is also entirely dependent on this trade to Russia, but it is not Defra’s business to facilitate the connection between these two strange bedfellows. And because Russia is outside the range of European regulatory agencies, we cannot know for certain how many of the elvers ever reach this ‘restocking’ project. Part of the problem is not what we know but what we don’t know, and, to quote George Bush, what we don’t know we don’t know. The conservation of the eel is definitely one of Defra’s duties, but I believe they have no verifiable means of knowing if this project has any conservation value whatsoever.
It is also possible that the conservation value is much less than nil. Elvers are the most smuggled wildlife on the planet, both in terms of value and of individuals, and Kaliningrad has advantages for those wishing to smuggle elvers to China and Japan. Once Defra allows the trade, and the elver merchant’s private plane lands in Kaliningrad, I suggest that Defra has no way of verifying what happens to all the elvers. Indeed I am not convinced that CITES or Borderforce, who check the cargo at Cardiff airport, are even adequately prepared, trained or have the necessary equipment, tanks and so forth to satisfy themselves that the weight of elvers loaded corresponds accurately to the weight on the permit. Various actors in this supply chain might be able to divert some or all of the elvers to China or Japan, and the rewards for this are huge. Each 500kg plane-load leaving Gloucester via Cardiff airport is potentially worth several million pounds, and we know that elver smugglers often use a legitimate trade as cover for smuggling. If any of the elvers shipped this spring were to have reached Japan they could have fetched $15.000 per kilogram, the current price at Shizuoka this April. The two 500kg loads sanctioned by Defra would at that price have fetched $7.5 million. (https://www.undercurrentnews.com/2024/04/12/glass-eel-prices-hit-all-time-high-at-15000-kg-in-japan-on-continuous-poor-harvest/)
I am, let me make it extravagantly clear, not accusing anyone of elver smuggling, but for Defra to take it on trust that (a) these elvers will be used for restocking, and (b) that the restocking project is not cover for some eel farming and a purely commercial fishery, and (c) that no-one in Russia will be tempted by the astronomical prices in Japan to siphon any elvers off, is surely a failure of duty and of the need to exercise due diligence.
I cannot actually demonstrate that Kaliningrad is on a known elver-smuggling route. All the seizures of smuggled elvers by Interpol and Operation Lake tend to be within the EU because that is where Interpol and such organisations are able to operate, whereas Russia is to all intents and purposes outside their jurisdiction. But if to facilitate means to make something easy or possible, then allowing elvers to be sent somewhere where you have no way of checking up what happens to them, where smugglers may be able to operate with impunity, is to create a situation where it may be relatively easy to smuggle them. Although CITES theoretically applies in Russia to control trade in endangered species, it is possible that the Russian authorities are more alert to trade in Siberian tiger parts or Steppe Eagles than to elver smuggling. There are few frontiers to negotiate between Russia and China or Japan. If this makes elver smuggling easier than within the EU, the question arises: are our government agencies facilitating wildlife crime in the literal meaning of the word ‘facilitate’, ‘to make easy’. It is possible to facilitate smuggling even if it does not happen. How Defra and the Environment Agency, (and the JNCC and NE and APHA and all the other acronyms) can justify this is a mystery to me. The risks to both eel stocks and to Defra’s reputation are considerable, and the trade may risk undermining European initiatives to halt elver smuggling. Were Defra to compile a risk assessment of this trade to Russia, these seem to be risks that they would have to consider.
A risk, if we are to assess it, needs to be balanced by advantages that make the risk worth taking. Many of us in the eel underworld wonder what those advantages are. The benefits to the UK economy or even the local economy of the Severnside region are piffling, as the elvermen appear to be paid a very small proportion of the street value of the elvers, and are all part-timers. Some riverside gossip suggests that Defra doesn’t want to have to pay compensation for the closure of the fishery, which has a certain absurdity, as the loss of elver markets is the result of Brexit, not of any action by Defra. The owner of UK Glass Eels was at the time something of a poster-boy for Brexit, and is said to be sucking his teeth now. Not allowing a questionable trade to Russia is not to close the elver fishery, even if it may have that effect.
Compensation for not being able to exploit a natural resource has a certain resonance with the very British response to the abolition of slavery, which was to compensate the slave ‘owners’ for their property loss rather than to compensate the slaves for the assault on their very humanity. I do not believe someone who for forty years has exploited a wild creature (or a natural resource, as I prefer not to call it) should have any right to compensation for not continuing to exploit it in the face of (who would have thought it?) population collapse.
In order to avert that collapse, the aim of European eel conservation measures (to achieve “the escapement to sea of at least 40% of the silver eel biomass relative to the best estimate of escapement that would have occurred if anthropogenic influences had not impacted on the stock”) applies not only to the Kaliningrad lagoons but also to the River Severn. Figures listed by ICES Working Group Eel estimate only 2.3% is achieved currently in the Severn. Whatever the claims made by some elver fishermen and the owner of UK Glass Eels of ‘surplus’ elvers, it is clear that this, one of the greatest river catchments in the country, is not producing the tonnes of silver eels that should be migrating back to the Sargasso Sea to breed if the eel stocks were in good shape. Before we allow the export of eels to face an uncertain future in Russia, perhaps we should be working to improve their prospects here in this great river catchment.
The Environment Agency may claim that they are working on this and that around £25million has been spent on fish passes to allow elvers to get past the weirs and migrate through the whole river system. Although that may seem a lot of money it may be much the cheapest way to appear to be doing something to help eel recovery. I have been told on very good authority that there are staff at the EA who believe that the real barrier to elver migration in the Severn is chemical, not physical. If chemical pollution from farms and industry and sewage reduces the life of the river, limits the living food available to elvers, and possibly damages the elvers themselves, that may be a barrier to eels and elvers more serious than any weir.
There are certain pollution levels in rivers that are treated in theory as upper limits, though even they are actually quite unhealthily high. In a pristine river these pollutants should scarcely be measurable, but these upper limits are useful to demonstrate the utterly appalling state of the Severn, probably the worst polluted river in the UK.
The upper limit for ammonia is 0.3 parts per million. In Worcester the other day the level was 0.62 ppm – more than twice the upper limit. These are toxic levels for freshwater organisms.
The upper limit for phosphates is 0.3 ppm. It was 1.86, more than 6 times the upper limit.
Anything over 5ppm of nitrates is excessive. The level at Worcester was 20ppm, four times the upper limit.
For water to be classed as safe for bathing, it should have no more than 1000 colony-forming units of e.coli per 100ml of water. That’s 1000 such festering clumps of e.coli in a very small glass of water. I don’t much like the sound of even that myself, but the reading at Worcester the other day was 48,900. Maybe we should have units that express how much water there is per 100ml of sewage.
When I saw the wonderful Feargal Sharkey on Youtube and LBC showing these test results from the Severn
I found myself wondering if the huge shoals of transparent elvers arriving in the Severn Estuary every spring, one of the global wonders of nature, might actually be better off being shipped by the elver merchant to almost anywhere other than the River Severn in which they should belong. Because we can’t fix the Severn with a few fish passes. To get rid of the causes of the pollution of the Severn we have to do more than ‘clean up the water industry’. We have to clean up the farming industry, which has abandoned husbandry for herbicides, and poisons our land and our waterways routinely with phosphates and nitrates as well as all the spray residues. We have to revive our wetlands, which could store water and carbon and feed the birds and insects that current farming starves and poisons. If we are to do what the Defra minister Steve Reed promised at his party conference – to give our children back the natural world that is their birthright – we will need a revolution in the way we live and the way we produce food and the way we treat, think about and even ‘own’ the natural world. And we will have to come to the realisation that the change needed may be exciting, and liberating, and democratising, and maybe even joyful. Or we can watch great rivers like the Severn become lifeless drains taking chemicals and soil wash-off out to poison the seas, as we congratulate ourselves that we have cut down on eating meat a bit.
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I’m hoping by the morning I will have recovered my fighting spirit enough to ask if maybe you would like to sign the Change.org petition (link below) that aims to persuade the Defra of the new government to review and reject the policies and attitudes of the previous government’s Defra, and be true to the new Defra Minister Steve Reed’s promise at the Labour conference that ‘our legacy will be to give our children back the natural world that is their birthright’ by, in this particular case, ending the elver trade to Russia.
Thank you!