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6. ON BANS ON COMMERCIAL FISHING


ASOCIACIJŲ SĄJUNGA „ŽUVININKŲ RŪMAI“
„ŽUVININKŲ RŪMAI“ THE ALLIANCE OF ASSOCIATIONS
L. Kerosieriui Iki pareikalavimo, Centrinis paštas, Vilnius, tel. 8674 38465, e. p. leonaslabora@gmail.com

To:
Mr Jean-Claude Juncker, President of the European Commission
Ms Kersti Kaljulaid President of the Republic of Estonia
Mr Raimond Vėjuon President of the Respublic of Latvia
Mr Andržej Duda President of the Respublic of Poland
Mr Stefan Lofven Prime Minister of the Sweden
Mr Stefan Lofven Prime Ministre of the Sweden
Ms Angela Merkel Cancler of Germany
Members of the European Parliament

To:
Ms Dalia Grybauskaitė, President of the Republic of Lithuania
Mr Viktoras Pranckietis, Speaker of the Seimas of the Republic of Lithuania
Mr Saulius Skvernelis, Prime Minister of the Republic of Lithuania
Mr Bronius Markauskas, Minister of Agriculture of the Republic of Lithuania
Mr Kęstutis Navickas, Minister of Environment of the Republic of Lithuania
Mr Andriejus Stančikas, Chairman of the Committee on Rural Affairs of the Seimas of the Republic of Lithuania
Mr Kęstutis Mažeika, Chairman of the Committee on Environmental Protection of the Seimas of the Republic of Lithuania
Mr Virginijus Sinkevičius, Chairman of the Committee on Economics of the Seimas of the Republic of Lithuania
Mr Linas Kukuraitis, Minister of social Secųrity and Labour of the Republic of Lithuania
Mr Artūras Černiauskas, President of Lithuanian Trade union confegeration
Ms. Agnė Razmislavičiūtė-Palionienė, Fisheries department of Ministry of Agriculture director
Ms. Indrė Šidlauskienė, Fisheries service director
Members of the Seimas of the Republic of Lithuania
ŽVEJAMS
The Media


ASOCIACIJŲ SĄJUNGA „ŽUVININKŲ RŪMAI“
“ŽUVININKŲ RŪMAI” THE ALLIANCE OF ASSOCIATIONS
To L. Kerosierius at call, Central Post Office, Vilnius phone: 8676 38465, e-mail: leonaslabora@gmail.com


ON BANS ON COMMERCIAL FISHING
Vilnius, 15.11.2017

Yours Excellencies Heads of State and leaders of institutions of highest responsibility, millions of people have granted you the powers to control and decide their lives.

With its 2.8 million citizens, Lithuania occupies 65.3 thousand sq. km. It has 2621 sq. km of inland waters, including around 3000 lakes, around 1500 ponds, approximately 29,000 rivers, streams, and channels, and the Curonian Lagoon. The lakes cover 47 percent (1232 sq. km), the Curonian Lagoon – 22 percent (576 sq. km), the rivers – 18 percent (472 sq. km), the ponds – 13 percent (341 sq. km).

THIS LETTER CONCERNS THE TOTAL BAN ON COMMERCIAL FISHING IN PUBLICLY-OWNED INLAND WATERS, EXCLUDING THE CURONIAN LAGOON.

The problems discussed in this letter have been known to the Lithuanian leaders for 7 years.

We hereby address the leaders of Estonia, Latvia, Poland, Sweden, and Germany as the scientists behind the Feasibility Study of 10.11.2015 relied on their experience in commercial fishing.

Commercial Fishing is regulated by the Law on Fisheries of the Republic of Lithuania. Article 2(30) thereof defines commercial fishing as fishing using commercial fishing gear in accordance with the established procedure. Article 6(1) prescribes the following: ‘Regulatory measures for fishing activity shall be established and applied on the basis of fisheries research data’. Article 14(1) lays down that commercial fishing shall only be allowed in private inland water bodies and water bodies exceeding 200 hectares.

We appeal to you mainly with regard to the fixing of limits for fishing of Rutilus rutilus, Perca fluviatilis, Carassius carassius, Esoxlucius, Abramis brama, Tinca Tinca, Scardinius erythroph thalamus, Sander lucioperca and Blicco bjoerkna in publicly- owned lakes and ponds, excluding the Curonian Lagoon.

About 90 percent of fish is caught in the Curonian Lagoon, which accounts for about 22 percent of the total area of inland waters while only 10 percent comes from the remaining water bodies.

We appeal to you with a plea, supported by our explanations, to ensure that the vast areas of the publicly-owned lakes and ponds of Lithuania (60% – 1673 sq. km) are made available for commercial fishing, at least 4.6 kg per hectare. The Minister of Environment, the officials of highest responsibility, and some of the politicians do not want commercial fishermen to provide more fish to the market and make cheap and low-value fish available to the poor.

BELOW WE PROVIDE INFORMATION ON THE ALLOCATION OF LIMITS FOR COMMERCIAL FISHING:

Limits of fish catches set by Ministry of Environment of the Republic of Lithuania in the inland waters for 2010-2014
Year Quantity of Inland waters Inland waters territory (ha) Limit set by Ministry of Environment (kg)
Total From:
Pikes Tenches Breams Pike perches
2011 14 21 026,3 140 240 4 805 2 525 22 880 200
2012 13 20 452,9 152 770 4 705 2 525 22 680 200
2013 10 13 433,5 67 570 4 535 700 13 150 0
2014 10 12 779,8 58 870 4 600 700 9 650 0
 

No limits for commercial fishing in inland waters, excluding the Curonian Lagoon, have been allocated since 01.01.2015.
According to the data in the table, in 2011, the average catch limit was 6.67 kg per ha, in 2012 – 7.46 kg, in 2013 – 5.03 kg, in 2014 – 4.6 kg. According to the research by scientists, the recommended catch limit for fish production in the lakes and ponds was about 21 kg per ha.
On 10.11.2015, the scientists presented the Feasibility Study for Recovery of Fish (Except For Salmonidae) and Crustaceans for 2016–2020. The study presents researched water bodies that require to be stocked with of valuable fish, refers to commercial fishing, and explains that fishing regulation must primarily depend on the condition of the resources and research results while the fishing gear, fishing duration, fishes authorised for catching must be strictly regulated and proper accounting of fish caught must be ensured with regard to both amateurs and businessmen. When preparing the study, the scientists took the experience of Estonia, Latvia, Poland, Sweden, and Germany into consideration.
On 07.04.2017, Minister of Environment K. Navickas provided the information that in 2011–2016, the total fish biomass in the 384 lakes and ponds researched increased 1.5 times while the average fish weight increased 1.3 to 1.4 times. The recommended catch limits for the production of the recommended fish in the 68 researched water bodies exceeding 200 ha, total area thereof amounting to 41,463 ha, are the following: Perca fluviatilis: 142,627 kg, which constitutes 16.33 percent, Carassius carassius: 7,836 kg (0.9 percent), Esoxlucius: 23,864 kg (2.73 percent), Tinca Tinca: 33,946 (3.89 percent), Abramis brama: 126,876 (14.53 percent), Sander lucioperca: 9,627 kg (1.1 percent), Rutilus rutilus: 270,390 kg (30.97 percent), Blicco bjoerkna: 94,419 percent (10.81 percent), Scardinius erythroph thalmus: 13,035 kg (1.49 percent), other fish: 150,570 kg (17.24 percent), total: 873,190 kg. We hereby attach the recommended catch limit table (supplement No. 1, 1.5 pages).

We draw your attention to the fact that the average recommended catch limit in the aforementioned researched water bodies is 21.06 kg per 1 ha while the average catch limit set for commercial fishermen in 2011–2014 was 7–5 kg of fish per ha. It should be noted that around 44 percent of the fish found in the water bodies researched is low-value carp family fish. The abundance of said fish has numerous negative consequences on fish shoals and the general ecological condition of the water bodies.
On 01.02.2017, the Government, implementing the European directives and taking into consideration the scientists’ research, ordered biomanipulation to be performed in certain water bodies. That meant exhaustion of the stocks of low-value carp family fish and introduction of predatory fish. We note that over the course of the last 9 months, the Ministries of Environment and Agriculture have not authorised fishing of low-value carp family fish.

We draw your attention to the fact that in August 2017, the Vice-Minister of Agriculture A. Bogdanovas started claiming that he was going to reduce the volumes of fishing farming by 86.1 percent, including predatory fish: Esoxlucius – 3 times, Sander lucioperca – 2.5 times, and that all publicly-owned fishing farming objects must be privatised. The attempt to privatise publicly-owned fishing farming objects was met with a great deal of resistance.


It is a WELL-KNOWN FACT that all over the World, including our neighbouring COUNTRIES, commercial fishing in inland waters and sale of fresh fish is PROPAGATED AND ENCOURAGED. However, THE LITHUANIAN AUTHORITIES are ruining small fishing businesses. WE SUPPOSE THEIR STINGY MINDS CANNOT BEAR THE IDEA OF businessmen selling low-value carp family fish, for example, Rutilus rutilus, Blicco bjoerkna, Scardinius erythroph thalmus, to the poor. They must be AGONISING OVER and LOATHING the thought of a honest businessman earning several hundred extra Euros.
Over the course of seven years, about 90 letters have been sent to the Lithuanian institutions of highest responsibility, requesting limits to be fixed for commercial fishing, the Curonian Lagoon excluded. The responsible institutions direct our letters to the Minister of Environment. The Minister, in return, refuses to fix limits for commercial fishing, breaching the Law of Fisheries of the Republic of Lithuania. We note that no FORCE MAJEURE circumstances have been in effect during this time.
The Ministry of Environment, some of the politicians and state officials, as well as amateur fishermen, usually justify the refusal to fix limits for commercial fishing with the fact that commercial fishermen exhaust the water bodies and engage in poaching, that not enough fish is left for amateur fishermen, and that the businessmen disturbs the fishing for the amateurs. It should be clear as day to anyone that such malicious disregard for the businessmen has no basis as never have scientists identified a single water body as having been exhausted by commercial fishermen, nor have the latter been found guilty of pouching. A person of a sane and sober mind should be able to realise that the businessmen, fishing in the 10–14 aforementioned water bodies, could never exhaust the entirety of over 33,000 water bodies. The Ministry of Environment has also imposed a ban on commercial fishing for the lessees of water bodies. WE DECLARE that the bans on commercial fishing is part of the POLITICAL AND ELECTORAL agenda as back in 2006, politicians started claiming that amateur fishermen could provide them with many more votes in comparison to commercial fishermen. Parties, members thereof, and their sponsors are systematically engaged in political ELECTORAL manipulations in their attempt to gain votes, showing disdain for commercial fishermen and causing division between commercial and amateur fishermen. We draw you attention to the fact that that all citizens of Lithuanian pay taxes to the budget; therefore, they have the right to purchase fresh water fish of Lithuanian origin (Rutilus rutilus, Perca fluviatilis, Carassius carassius, Esoxlucius, Abramis brama, Tinca Tinca, Scardinius erythroph thalamus, Sander lucioperca and Blicco bjoerkna). Nonetheless, the Ministry of Environment continues to prohibit commercial fishing.

We note that the businessmen notify the agencies of fishing activity in advance. Fish is unloaded in authorised places.

Lithuania applies severe punishments for breaches of the fishing rules, including confiscation of fishing gear and compensation for environmental damages: 1 illegally caught Abramis brama is fined 60 Euros, 1 Silurus glanis– 290 Euros, 1 Salmo – 580 Euros, Esoxlucius – 145 Euros.
Most officials and citizens are subject to prosecution for failure to comply with or implement legislation and liability to compensate for damages. However, neither the Minister of Environment, nor the responsible officials have been held liable for the systematic breaching of the Law on Fisheries of the Republic of Lithuania – refusal to fix limits for commercial fishing. Every year, commercial fishermen incur great losses while buyers, especially the poor, are deprived of access to cheap fresh water fish.





EVERYONE realises that amateur fishing must be ENCOURAGED. In accordance with the current legislation, amateur fishermen are allowed to fish in all water bodies. However, proper attention should be PAID to commercial fishing as well, and not only in the Curonian Lagoon. THERE MUST BE ENOUGH SPACE FOR BOTH THE AMATEURS AND BUSINESSMEN UNDER THE SUN.

WE STATE that the Ministers of Environment have not fixed any limits for commercial fishing in lakes and ponds since 01.01.2015; HOWEVER, the responsible institutions have not reacted. The President, the Chairman of the Seimas, and the Prime Minister must be satisfied with the bureaucratic interpretations and evasions of Minister of Environment K. Navickas and former Ministers of Environment and their deceitful replies, disdaining and humiliating commercial fishermen. Not once have the Lithuanian leaders demanded implementation of the Law on Fisheries of the Republic of Lithuania from the Ministers of Environment. We note that the law provides no exceptions and that Lithuania has not been subjected to FORCE MAJEURE circumstances. That is the only reason preventing use of the state assets – lakes, rivers, and ponds, the Curonian Lagoon excluded, for commercial fishing and production of food products.

IT APPEARS that Lithuania does occasionally witness cases of LEGISLATION BEING OBSERVED. H. Daktaras, sentenced to life in prison for murders and other serious crimes, have been granted facilitated ACCESS TO A BALLPOINT PEN; however; the Lithuanian leaders are either incapable of unwilling to DEMAND that the Minister of Environment implements the Law on Fisheries of the Republic of Lithuania.

WE NOTE that on 12.10.2017, the new Chairman of the Committee on Environmental Protection Committee of the Seimas of the Republic of Lithuania, together with Members of the Seimas M. Majauskas, V. Vingrienė, and A. Gaidžiūnas, registered and IMMEDIATELY started publishing amendments to the Law on Fisheries of the Republic of Lithuania, proposing a ban of commercial fishing in all water bodies, excluding the Curonian Lagoon. POLITICAL ATTACK FORCE HAS EMERGED: Minister of Environment K. Navickas refuses to fix limits for commercial fishing, the Chairman of the Committee on Environmental Protection of the Seimas is preparing a ban on commercial fishing while Vice-Minister of Agriculture A. Bogdanovas seeks to increase fish introduction by 86.1 percent and is preparing a plan for privatisation of publicly-owned fish farming objects.

According to the investigations of the Lithuanian Special Investigation Service, the Seimas of the Republic of Lithuania came SECOND among the most corrupted institutions in Lithuania in 2014. Perhaps it is no wonder that the Law on Fisheries of the Republic of Lithuania adopted by the Seimas is not being implemented. We draw your attention to the fact that Member of the Seimas V. Mazuronis was also serving as Minister of Environment at the time. He was playing first fiddle on all fronts in the war against commercial fishing, seeking to make sure that no limits are fixed and that COMMERCIAL FISHING IS BANNED in inland waters, excluding the Curonian Lagoon.

Many of the new members of the Seimas were elected under promise to create new workplaces, improve people’s well-being, increase salaries and pensions, and reduce social exclusion.
The reality of life has showed: the long-term ban on commercial fishing and refusal to fix limits for commercial fishing PROVES that our LEADERS have no intention to create new workplaces, even though the FISH RESOURCES are plentiful and the Law on Fisheries of the Republic of Lithuania IMPOSES THE OBLIGATION to fix limit for commercial fishing in LAKES AND PONDS.


WE STATE that already back in 1995, the Food and Agriculture Organisation (FAO) of the United Nations, which Lithuania is a member of, adopted the Code of Conduct for Responsible Fisheries, which refers to the important contribution of small-scale fishing businesses to the employment and income of citizens and increase in food resources.

On 17/18.07.2017, I protested against the ban on commercial fishing at the Palace of EU Presidency in Tallinn. On 24.07.2017, I continued by protest in Vilnius, at the Presidential Palace of the Republic of Lithuania. On 27.07.2017, I presented a letter entitled ‘Regarding the Protests in Tallinn and Vilnius’ (supplement No. 2, 9 pages) to the responsible leaders of Lithuania. WE NOTE that the responsible institutions forwarded the letter to the Ministry of Environment. The Minister of Environment did not fix limits for commercial fishing.
On 14.09.2017, we appealed to the responsible leaders of Lithuania once again with a letter entitled ‘On Commercial Fishing’, requesting that limits are fixed for commercial fishing (Supplement No. 3, 3 pages). WE NOTE that the responsible institutions forwarded the letter to the Ministry of Environment. The Minister of Environment did not fix limits for commercial fishing.

On 25.09.2017, we presented a letter entitled ‘On Commercial Fishing in Lithuania’ to the leaders of the Lithuanian parties currently in the Seimas, to the heads of trade unions and municipalities and, FOR INFORMATION, to the responsible institutions of Lithuania (Supplement No. 4, 4 pages). WE NOTE that the responsible institutions forwarded the letter to the Ministry of Environment. The Minister of Environment did not fix limits for commercial fishing.

On 28.09.2017, we addressed the responsible leaders of Lithuania in writing with a letter entitled ‘When Is Commercial Fishing in Inland Waters Going to Be Resumed???’ (supplement No. 5, 2 pages). WE NOTE that the responsible institutions forwarded the letter to the Ministry of Environment. The Minister of Environment did not fix limits for commercial fishing.

Similar oppression of small businesses, carried out by public institutions, is also evident in agriculture and other businesses. Perhaps that is the reason why the average monthly net salary of Lithuanian employees was among the lowest in the European Union (602 Euros) in 2016 while the average old age pension was only 255 Euros. Perhaps that is why 870 thousand Lithuanian citizens are living below the poverty threshold. SOLELY BECAUSE OF THIS, LITHUANIA IS THE HEAVIEST-DRINKING COUNTRY IN THE WORLD while almost one third of the inhabitants (around 900 thousand people) have emigrated in fear of unemployment and starvation. Furthermore, SOLELY BECAUSE OF THIS, the social exclusion is increasing. THAT IS PROBABLY THE REASON why the survey carried out at the end of October revealed that 82 percent of pupils of year 9 to 12 considered emigration – 31.9 percent of the respondents would like to permanently leave Lithuania. AND THAT IS PROBABLY WHY doctors and teachers are preparing for massive strikes – they are expected to have many supporters.

STATING that, according to the scientific research, the recommended catch limit for fish production is 21.06 kg, and DRAWING your attention to the fact that commercial fishing was until recently allowed in 12–14 water bodies with the average limit of 6 kg per ha and the refusal to fix limits for lessees of water bodies, WE DECLARE that we are under impression that the people in power are committing an economic, political, and social SABOTAGE against commercial fishermen and lessees of water bodies.

Highly esteemed Chairman of the European Commission, Presidents of Estonia, Latvia, and Poland, Prime Minister of Sweden, Chancellor of Germany, as you are in contact with the President of the Republic of Lithuania, the Chairman of the Seimas, the Prime Minister, and other responsible officials of Lithuania, WE HEREBY ASK YOU to explain to the Lithuanian leaders the practice of



implementation of legislation with no FORCE MAJEURE circumstances in effect in the European Union and specifically Estonia, Latvia, Poland, Sweden, and Germany, as well as liability for failure to implement legislation.

Highly esteemed Chairman of the European Commission, Presidents of Estonia, Latvia, and Poland, Prime Minister of Sweden, Chancellor of Germany, we hereby ask you to request the Lithuanian leaders to demand that Minister of Environment K. Navickas implements the Law on Fisheries of the Republic of Lithuania and IMMEDIATELLY fixes commercial fishing limits for catching Rutilus rutilus, Perca fluviatilis, Carassius carassius, Esoxlucius, Abramis brama, Tinca Tinca, Scardinius erythroph thalamus, Sander lucioperca and Blicco bjoerkna and other low-value fish in lakes and ponds, at least 4.6 kg per 1 ha.

Highly esteemed Chairman of the European Commission and President of Estonia, we hereby ask you to allow our representative to speak at the Meeting of Directors for Water and Maritime Affairs that will take place on 4–5 December 2017 in Tallinn.
Highly esteemed Chairman of the European Commission, we hereby ask you to allow our representative to speak at the meeting of the Agriculture and Fisheries Council that will take place on 11–12 December 2017 in Brussels.

Lithuania has taken care that the most famous and cruel criminal H. Daktaras, sentenced to life in prison, has ACCESS TO A BALLPOINT PEN in his cell.
Life will show whether THOSE IN CHARGE OF THE RULLING OF LITHUANIA WILL ENSURE that commercial fishing limits are fixed for catching Rutilus rutilus, Perca fluviatilis, Carassius carassius, Esoxlucius, Abramis brama, Tinca Tinca, Scardinius erythroph thalamus, Sander lucioperca and Blicco bjoerkna and other low-value fish in lakes and ponds and provision thereof to the market – will the Law on Fisheries of the Republic of Lithuania be implemented and who will be held liable for the consistent breaching thereof?

BREACH OF OATH and LACK OF PARLIAMENTARY CONTROL OR ABSENCE THEREOF LEAD TO ABUSE RELATED TO IMPLEMENTATION OF LEGISLATION AND CAUSE DISCONTENT AND PROTESTS BY CITIZENS. Despite numerous appeals, the Seimas has withdrawn from control of the implementation of the Law on Fisheries of the Republic of Lithuania – possibly in hopes of gaining more votes

President of “Žuvininkų rūmai” The Alliance of Associations Leonas Kerosierius

 

President of “Žuvininkų rūmai” The Alliance of Associations                   Leonas Kerosierius      

e-maiul: leonaslabora@gmail.com