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Sie sind hier: Kampagnen > Irland > Treibnetzfischerei > Brief an Bertie Ahern, Nov. 2002

Brief von Orri Vigfússon an den Premierminister der Republik Irland Bertie Ahern, 15. November 2002

NORTH ATLANTIC
SALMON FUND
Skipholti 35
105 Reykjavík
Iceland

Bertie Ahern, T.D.
An Taoiseach
Government Buildings
Merrion Street
Dublin 2

November 15, 2002

We are writing to you formally on behalf of a coalition of legitimate interest groups in a number of EU countries. We wish to request that no decisions on netting quotas for Atlantic salmon be taken within the fisheries jurisdiction of the Irish Republic for the year 2003 and beyond without full consideration and attention being given to the protection of salmon that originate in France, Spain, Wales, Germany, England, Denmark, Sweden, Scotland and Northern Ireland.

The success of fisheries management, like that for the wild salmon resource, depends on the involvement and contributions of a wide range of organizations, private and public, including industry associations, conservation organisations, academic and scientific institutions.

Ireland acts as a host country to the wild salmon of these countries as they pass through your coastal waters on their way home at the end of their migration journeys. It has been established that the Irish nets, primarily drift and draft nets, operate a mixed-stock fishery -- the term fishery scientists use to describe an intermingling of fish from many natal sources. They intercept the salmon returning to your neighbouring countries and they are doing increasing damage to Irish stocks.

In terms of sheer numbers of fish caught the impact of these nets is very substantial. This is especially serious because the stocks of these other countries are either very low or on the point of disappearing. The activities of these Irish nets prevent your neighbours from initiating any effective recovery plans. The fact is that salmon stocks in the vast majority of these rivers are far below safety levels and it is feared that several of the rivers are already beyond the point of recovery. All your own salmon scientists have now conceded that the Irish driftnet industry is "untenable". Our joint obligation is to ensure that everything is done to stop further decline and work towards a general restoration of what should be a very important resource both for you and for them.

Many of the salmon stocks originating in the rivers of Europe are inherently bi-national resources because they cross international boundaries during their oceanic migrations. Countries such as Ireland are thus both host countries and countries of origin. Article 66(1) of the United Nations Convention on the Law of the Sea directs that "state(s) in whose rivers an adromous stocks originate shall have the primary interest in and responsibility for such stocks." We believe this provides our coalition partners with substantial rights to share in determining measures -- such as total allowable catches (TACs) -- to protect their stocks while they are in Irish coastal waters.

Moreover, the case in which salmon originating in the rivers of one state migrate into the waters of another state is covered by other provisions in Article 66 and elsewhere in the Convention. Article 66(4) provides that where salmon originating in the rivers of one country migrate into or through the waters of a neighbouring state, the neighbouring state "shall cooperate with the state of origin with regard to the conservation and management of such stocks." Article 66(2) allows a state of origin, after consulting with the neighbouring state, to establish the total allowable catch (TAC) for salmon originating in its rivers and Article 56(2), directs each state to give "due regard to the rights and duties of other states."

We would also like to draw your attention to the protection afforded to the rivers within the European Union by being designated as Special Areas of Conservation (SACs). In most cases salmon are a primary reason for that important status. Under the European Habitats Directive, which member nations must obey, this protection involves the observance of cross-border international laws.

The fact that the salmon stocks of these rivers are failing to the point where some of them are in desperate straits must mean that Ireland cannot continue to harvest the protected salmon of your European partners. Quite apart from the effect your commercial fishery has on other countries you should also realise that the commercial fishery is also netting salmon from Irish SAC rivers and seriously damaging them and your economy in the process.

We and our partners claim that Ireland is in serious infringement of the Habitats Directive on several counts including the following

1. Failing to make an appropriate assessment (under article 6[3]) of a plan or project likely to have a significant effect on the favourable conservation status of a species (Salmo salar) for which candidate Special Areas for Conservation have been identified both in the Republic of Ireland and elsewhere in the Atlantic Bio-geographical region, specifically the UK
2. Licensing and allowing the killing of an Annex II directed species without taking account of, or consulting other member nations on, the impact upon their SAC's of that licensed activity.
3. Failing to designate a site that is a clearly identifiable area representing factors essential to the life and reproduction of an Annex II species; i.e. a salmon migration route. (Article 4).
4. Failing to adequately address the community importance of sites included on the national lists of other Member States; Not recognising the geographical importance of sites in relation to migration routes of species in Annex II (Annex III - Stage 2.- 2.1 & 2.2 [b]).

Finally we would like to mention that Ireland is a signatory to the Bonn Convention on the Conservation of Migratory Species of Wild Animals and numerous other conventions and treaties for international cooperation.

Our Coalition extends across the nations on both sides of the salmon's North Atlantic range and includes all the EU and non-EU countries surrounding Ireland together with Canada and the USA. By now your government should have received messages from the private sector and from public officials in all these countries stressing their great concern over the situation. The United States attaches significant importance to Article 12 of the 1995 United Nations Straddling Fish Stocks Asgreement, which provides that "States shall provide for transparency in the decision-making process and other activities of subregional and regional fisheries management organizations."

We have chosen to write to you directly for two reasons. We want to ensure that you are fully aware of the current situation and we are also in doubt about which of your Government departments should handle these consultations.

The situation of the world's stocks of wild Atlantic salmon is very serious. We trust you will agree that the enthusiastic participation of Ireland in the necessary remedial measures is vital to consolidate international unity.

We would be most grateful for an early meeting with the appropriate Minister.

Yours sincerely,

On behalf of the Coalition partners
Orri Vigfússon, Chairman
North Atlantic Salmon Fund

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