L F V

UNION DER ANGEL- UND BERUFSFISCHER LANDESFISCHEREIVERBAND BAYERN E.V.

Referat III Fischerei, Gewässer- und Naturschutz

Landesfischereiverband Bayern e.V. Pechdellerstr. 16 81545 München

European Commission Directorate-General Environment BU 5-6/140 B-1049 Bruxelles Belgium

Johannes Schnell Telefon: 089-64 27 26-27

Fax: 089-64 27 26-66

Email: johannes.schnell@lfvbayern.de

München, 24.07.2015

our sign: 15/07 LFV-Bayern fitness check NATURA 2000

Fitness check NATURA 2000

Dear ladies and gentlemen of the European commission,

thank you for the possibility to take part in the fitness check on EU nature legislation (Birds

Directive, Habitats Directive) (EN).

Additional to the questions on the internet platform we see some demand to specify some

answers to some questions. The reason therefore is that some of the offered possibilities

to answer need a specific differentiation to avoid a dilution, which can be contra productive

to aims of the NATURA 2000 directive. Following you can find our statements to several

questions of the fitness check.

In your internet mask to put in the description of our organisation there is only one point to

click on. Please note that our organisation is representing following fields:

• Environment (NGO for environmental protection)

• Fishery and aquaculture (NGO)

• Angling (NGO)

LFV Bayern e.V., Präsident: Prof. Dr. Albert Göttle, Amtsgericht München VR 7715, USt.-ldNr. DE129517393

Bankverbindung: Münchner Bank e.G., IBAN: DE07 7019 0000 0002 8256 35, BIC: GENODEFIMOI

Öffnungszeiten Mo-Do. 8-12 Uhr und 13-16 Uhr, Freitag und an Tagen vor Feiertagen 8-12 Uhr

Email poststelle@lfvbayem.de, Tel. 089/64 27 26-0, Homepage: http://lfvbayern.de

mailto:poststelle@lfvbayem.de

LANDESFISCHEREIVERBAND BAYERN E.V.

Question 3: How important to nature conservation are the Birds and Habitats Directives?

This question contents the bird's directive and the habitat's directive. Both directives have

different aims. In some aims the directives are in the opposite direction.

E.g. the protection of piscivor animals like cormorant (Phalacrocorax spec.) or otter (Lutra

lutra) can be a disadvantage for aquatic animals, which are lieted in the habitat's directive.

This means e.g. the prédation of endangered fish, mussels, lampreys and crayfish.

Examples therefore are the prédation of Huchen (Hucho hucho) or Frauennerfling (Rutilus

pigus) or Zingel (Zingel zingel) by cormorant. The otter is noted as an predator of freshwa

ter pearl mussel (Margaritifera margaritifera).

Special in Bavaria al lot of ponds for aquaculture are elementar pieces of habitat directive

areas. The cultivation and maintenance of the ponds by fishermen is the reason for the

existence of these ponds. Also the biodiversity in and around these ponds is a resultant of

this. Fishfeeding birds inside the birds directive and also fisfeeding animals form the habi

tat's directive can cause heavy damages to the ponds by taking out a lot offish. Losing

their economy these ponds get no more cultivation and maintenance, meaning that the

ponds disappear step by step. As one result the aim to protect or develop special types of

biotopes and/or species (e.g. dragonflies) can be failed.

An additional point is the beaver (Castorfiber), which can affect the ponds negatively e.g.

by digging inside dams ore closing the water supply of ponds. The economic decreases by

beaver can have the same effect as shown at fishfeeding birds.

A coaction of feshfeeding birds and beaver on ponds increases the risk to lose the ponds

as an hotspot of biodiversity.

For the future it will be necessary to have an European management to avoid effects like

shown here.

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LANDESFISCHEREIVERBAND BAYERN E.V.

Question 5: Is the approach set out in the Directives an appropriate way to protect species and habitats in the EU?

Here we refer to our answer for question 4. The protection of singular species inside the

directives must not be a substantial disadvantage for other species.

Question 6: Have the Directives been effective in protecting nature?

The protection given by the named directives often is static. This is caused by a very con

servative treatment by the Executive.

On aquatic ecosystems like rivers and creeks this can cause negative influences to in

struments that include dynamic aims, like the EG-water framework directive.

E.g. if the aim of water framework direction is to restore the natural dynamic of a river, of

ten the protection of special biotope types of NATURA 2000 (which are often a result of

the loss of natural dynamics) can be contra productive.

E.g. the removing of fixed riversides to initiate natural dynamic effects are not possible be

cause behind the fixed riverside are some biotops or special species, that could be lost

during natural dynamic activities of the river.

For the future it will be necessary to have an European management to avoid effects like

this.

Question 7: How important is the Natura 2000 network for protecting threatened species and habitats in the EU?

The NATURA 2000 Network is very important. The precondition therefore is that the as

pects shown in our answers for questions 4 to 6 are respected.

Question 9: While the Directives are primarily focused on conserving nature, to what extent have the following been taken into account in implementing them?

For all items look to our answer for question 3, referring to fishery and aquaculture as a

guarantor for aquatic biodiversity.

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LANDESFISCHEREIVERBAND BAYERN E.V.

Question 10: Do EU policies in the following areas generally support the objectives of the Birds and Habitats Directives?

Some policies are not listed in the catalogue of question 10. Here is to name the EU-policy

for flood-protection on dams and water storages. In Germany this is called DIN 19.700.

This policy can affect the preservation of ponds to save aquatic biodiversity negatively. To

reach the necessary standards of flood protection on these artificial water bodies is con

nected to very high costs. Without support the owners and operators (fishermen) there

often is no other way than to let the water out, because these costs to fulfil the standards

of flood protection are higher than the economical productivity.

To preserve ponds as a centre of aquatic biodiversity inside directive's area it is necessary

to support the owners and operators (fishermen).

Question 11: To what extent have the Directives provided more value than could have been acheived through national or regional laws in this area?

Especially for fishery and aquaculture as a guarantor of aquatic biodiversity (please com

pare answer to question 4) the directives can be contraproductive.

On natural waters (lakes, rivers, creeks) the habitat directive can be an additional im

provement.

Question 12: To what extent have the Directives added value to the economy (e.g. job creation, business opportunities linked to Natura 2000)

Especially for fishery and aquaculture the influence of the directives can be harmful. One

result of this is the loss of aquatic biodiversity, e.g. by loosing ponds as a reason of declin

ing economy for the operators (fishermen).

On the other side the value for natural waters (lakes, rivers, creeks) the added value to the

economy can increase.

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LANDESFISCHEREIVERBAND BAYERN E.V.

All these answers are done to part 1 of your question catalogue. Please note that our an

swers also refer to part 2, which contents more specific questions.

The specific questions of part 2 were also digitally answered by us.

Please feel free to ask me some questions.

Yours sincerely

i.V. Johannes Schnell

(Dipl. Ing.)

Leiter Ref. Ill (Fischerei, Gewässer- und Naturschutz)

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