EUROPEAN COMMISSION 
Brussels, 2.12.2011 
SEC(2011) 1416 final 
  
COMMISSION STAFF WORKING PAPER 
Impact Assessment 
Accompanying the document 
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL 
on the European Maritime and Fisheries Fund [repealing Council Regulation (EC) No 
1198/2006 and Council Regulation(EC) No  861/2006 and Council Regulation No 
XXX/2011 on integrated maritime policy 
{COM(2011) 804 final} 
{SEC(2011) 1417 final}  
 
  
COMMISSION STAFF WORKING PAPER 
IMPACT ASSESSMENT  
ACCOMPANYING THE DOCUMENT  
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL 
on the European Maritime and Fisheries Fund [repealing Council Regulation (EC) 
No 1198/2006 and Council Regulation(EC) No 861/2006 and Council Regulation No 
XXX/2011 on integrated maritime policy 
   
 
 
This report commits only the Commission's services involved in its preparation and does 
not prejudge the final form of any decision to be taken by the Commission. 
 
 
 
 
   
 
2 TABLE OF CONTENT  
1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED 
PARTIES.....................................................................................................................4 
1.1. Organisation and timing ....................................................................................4 
1.2. Internal consultation..........................................................................................4 1.3. Consultations with stakeholders........................................................................5 1.4. Dissemination of the results of consultations with stakeholders.......................6 1.5. Incorporating comments from the Impact Assessment Board ..........................6 
2. THE STRUCTURE, PERFORMANCE AND PROBLEMS OF THE 
PUBLIC FINANCIAL SUPPORT OF THE CFP AND THE IMP ............................6 
2.1. Structure ............................................................................................................6 
2.2. Performance and problems ................................................................................8 2.3. Problems linked to the design of the CFP and IMP financial 
instruments …. ..................................................................................................9 
2.4. ….limit their effectiveness in achieving CFP and IMP objectives .................13 
3. THE JUSTIFICATION FOR THE REFORM OF THE PUBLIC 
FINANCIAL SUPPORT INSTRUMENTS..............................................................21 
3.1. Who is affected by the public financial support instruments and how ...........21 
3.2. Has the EU the right to act?.............................................................................22 
4. WHAT ARE THE POLICY OBJECTIVES?............................................................24 
4.1. Objectives related to the design of the financial instrument ...........................25 
4.2. Objectives related to the content of the financial instrument..........................25 
5. WHAT ARE THE POLICY OPTIONS? ..................................................................26 
5.1. Elements common to all reform options .........................................................27 
5.2. Description of the options ...............................................................................29 
6. COST-EFFECTIVENESS AND EX ANTE EVALUATION ..................................32 
6.1. Environmental sustainability...........................................................................32 
6.2. Economic sustainability: innovation gap ........................................................34 6.3. Social sustainability: territorial development of coastal areas ........................37 6.4. Allocation between green sustaina ble fisheries, green sustainable 
aquaculture and inclusive territo rial development pillars. ..............................37 
6.5. IMP, RFMO and governance ..........................................................................37 6.6. Intended allocation of EMFF funds per area of activity .................................39 
7. METHODOLOGICAL APPROACH FOR THE ANALYSIS OF IMPACTS 
OF THE DIFFERE NT OPTIONS.............................................................................40 
 
3 8. ANALYSIS OF IMPACTS.......................................................................................40 
8.1. Option Status Quo: Continuation of  the current policy (including the 
current EFF).....................................................................................................40 
8.2. Option 1 “EFF +” ............................................................................................41 8.3. Option 2: EFF+ “Integration”..........................................................................44 8.4. Option 3: EMFF “Convergence”.....................................................................44 
9. COMPARING THE OPTIONS: CONT RIBUTION TO THE EUROPE 2020 
STRATEGY ..............................................................................................................46 
9.1. Comparison of impacts....................................................................................46 
9.2. Contribution to the Europe 2020 strategy .......................................................47 
10. THE PREFERRED OPTION....................................................................................47 
11. MONITORING AND EVALUATION.....................................................................48 
LIST OF ANNEXES:........................................................................................................52 LIST OF ACRONYMS.....................................................................................................53 ENDNOTES......................................................................................................................5 9 
 
 
 
4 COMBINED IMPACT ASSESSMENT AND EX -ANTE EVALUATION REPORT CONCERNING 
THE COMMISSION 'S PROPOSAL FOR A FUTURE FINANCIAL INSTRUMENT FOR FISHERIES 
AND MARITIME POLICIES (2014-2020) 
Lead DG : DG MARE 
Other services involved:  AGRI, BUDG, ECFIN, EMPL, ENTR, ENV, ESTAT, 
HOME, HOME-JUST, JRC, REGIO, RTD, SANCO, SG, TRADE,  RELEX, 
COMP, MOVE and CLIMA 
Agenda planning reference: 2011/MARE/005 
1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
This report commits only the Commission's serv ices involved in its preparation and does 
not prejudge the final form of any decision to be taken by the Commission. 
1.1. Organisation and timing 
This document is an impact assessment (IA) and ex-ante evaluation of different options 
for the design of the financial support to the implementation of the Common Fisheries Policy (CFP) and the Integrated Maritime Policy (IMP)
1 in the years 2014-2020. 
Accordingly, its scope includes the following financial instruments being currently in 
use: (i) European Fisheries Fund (EFF), ( ii) IMP financial regulation proposed by the 
Commission to support the IMP between 2011 and 20132, (iii) Community financial 
measures for the implementation of the CFP and in the area of th e Law of the Sea 2007-
20133 (so-called Second Instrument) including data collection, control, the voluntary 
financial support provided to Regional Fish eries Management Organisations (RFMOs) 
and governance, (iv) the budgets lines concerned by the Common Market Organisation (CMO) for fisheries and aquaculture products including market intervention and the scheme to compensate for the additional costs incurred in the marketing of certain fishery 
products from the outermost regions of the Azores, the Canary Islands, French Guiana 
and Reunion. In accordance with the Co mmission's Communication on A Budget for 
Europe 2020
4, two other currently used instruments have been excluded from the scope 
of this IA: (i) the Fisheries Partnership Agreements and (ii) the obligatory financial support provided to RFMOs.  
The Impact Assessment of CFP reform
5 provided key conclusions on the role of a 
financial support for the reformed CFP. These conclusions, together with the evaluations 
carried out so far, the IA accompanying the CMO6 regulation, the initial IA7 and the 
Progress Report8 for IMP, the Europe 2020 strategy and the Commission's 
Communication on a Multiannual Financial Framework (the MFF Communication)9 
form the point of departure for this IA. Furt hermore, the results of an ex-post evaluation 
of the Financial Instrument for Fisheries Gu idance (FIFG) and of an interim evaluation 
of the EFF finalized in February 2011 have also been used, as well as an interim 
evaluation of the Second Financial Instrument. 
1.2. Internal consultation 
An Impact Assessment Steering Group (IASG ) was established in September 2009 and 
met 5 times10. It involved the following DGs: AGRI, BUDG, ECFIN, EMPL, ENTR, 
ENV, ESTAT, HOME, HOME-JUST, JRC,  REGIO, RTD, SANCO, SG, TRADE,  
 
5 RELEX, COMP, MOVE and CLIMA. At the last of these meetings the current IA report 
(IAR) was presented to the IASG.  
1.3. Consultations with stakeholders  
The reform of the CFP started with the adoption of the Green Paper11 in April 2009. The 
Green Paper was the basis for public consu ltations which lasted until the end of 2009. 
The outcome of the consultations, concerning public support, was as follows: 
¾ Many contributions ask for the continua tion of public funding for fisheries, 
although a few MS and most NGOs insist on the elimination or phasing out of 
subsidies – in their view they preserve unviable structures, contribute to overcapacity and maintain industry dependence on public support.  
¾ There is an agreement that any future support should accompany the 
implementation of CFP reform and ease adjustment of the industry, aiming at 
long-term economic and social sustainab ility, or alleviating the possible negative 
consequences of the reform.  
¾ EU support should focus on research and innovation, enhancing marine 
protection, and supporting fishermen’s orga nisations and local development.  
¾ The link to the IMP is considered impor tant: maritime policies can no longer act 
in isolation, and the coherence of the CFP with the IMP needs to be reinforced. In 
fact, regional, business and NGO actors supported the need for joining up EU 
policies affecting seas, maritime sectors and coastal regions already at the time of the public consultation in 2007
12. 
¾ More conditionality between EU financ ing and reaching CFP's objectives is 
needed. Compliance with rules/targets should have a bearing on fund availability.  
¾ A more sectoral approach to the allocati on of funding (linked to the size of the 
fisheries sector instead of the level of economic development, as it is the case 
today) is strongly supported by a group of  MS while the European Parliament 
opposes this.  
¾ There is general agreement on the importa nce of the small-scale coastal fleets 
(SSCF) which remain a significant source of jobs in coastal communities. Some 
MS support the idea of a privileged access of this fleet to financing, while others 
do not favour a specific approach.  
¾ An overwhelming majority of industry and MS consider that common services 
(such as control and data collection) should continue to be supported under EU 
funding. 
¾ Regarding aquaculture most of the c ontributions voiced opinions on whether it 
should or not be part of the CFP. A majo rity was in favour of its inclusion and 
aquaculture was mentioned frequently as a potential beneficiary of public 
support.  
 In addition to this public consultati on, around 200 meetings with MS, Advisory 
Committee on Fisheries and Aquaculture (A CFA) and Regional Advisory Councils 
(RACs), the fishing industry, the processi ng and marketing sector, trade unions, NGOs, 
and the research community were organized. A number of meetings took also place in 
2010 and 2011, during which concrete options fo r the CFP reform, including its financial 
dimension, were presented by the Commission a nd discussed with the stakeholders. In 
particular: (i) two meetings with the Memb er States, during which future funding was 
discussed, took place in Gent (12-14 Sept ember 2010) and Noordvijk (9-11 March 
2011). (ii) A dedicated seminar on the future E FF with the participation of stakeholders 
from industry, trade unions and Member  States was organised on April 13
th, 2010, in 
 
6 Brussels. (iii) A conference on the future of  local development in fisheries areas took 
place in Brussels, 12-13th April, 2011.   
1.4. Dissemination of the results of consultations with stakeholders 
The results of the consultations on the C FP reform are published on DG MARE's website 
(http://ec.europa.eu/fisheries/reform/sec(2010)0428_en.pdf) and are summarized in a Commission's Staff Working Document "Synthesi s of the Consultation on the Reform of 
the Common Fisheries Policy"
13. The results of the consultations on the IMP are 
published on DG MARE's website and summa rized in a Communication from the 
Commission: Conclusions from the Consultation on a European Maritime Policy14. A 
more detailed list of the consultations, covering also the financial instrument can be found in Annex 1. 
1.5. Incorporating comments from the Impact Assessment Board 
A first draft of the IA report (IAR) wa s discussed by the IAB on 7 September 2011 by 
written procedure. In its opinion of 13 September 2011
15, the IAB recommended to 
strengthen the analysis of implementation probl ems, to strengthen the analysis of value-
added of individual components of the new inst ruments, to improve the analysis of co-
ordination with other funds and to clar ify further the monitoring and evaluation 
arrangements. These recommendations have been taken into account in the final version of the IAR. The request for improved analysis  of co-ordination with other funds was too 
a large extent addressed by the adoption of the common regulation for funds under the Common Strategic Framework (CSF), on October 5
th , which defined the scope of co-
ordination and common rules and mechanisms  to be used by all the CSF funds. The 
request to add more quantitative analysis wa s only party complied with because of the 
absence of reliable data concerning the impact s of public financing on the fisheries sector 
(not least due to lack of common indicator s and consistent monitoring and evaluation 
framework, identified as a serious deficiency  of EFF in this IA). Some data and 
calculations done in the context of the CFP refo rm IA have been re-used in this IAR in 
order to better illustrate the problems. Fina lly, the section on monitoring and evaluation 
has been improved and developed. Starting, mile stone and target values for some of the 
indicators would be available in the next 1- 2 years, linked to improvements in the quality 
and coverage of economic and social data and of scientific advice. This should allow to 
fully integrate this data in the EMFF Operational Programmes. 
2. THE STRUCTURE , PERFORMANCE AND PROBLEMS OF THE PUBLIC FINANCIAL 
SUPPORT OF THE CFP  AND THE IMP 
2.1. Structure 
2.1.1.  Current funding of the CFP 
The CFP is supported by a set of public financial support tools: 
1) The European Fisheries Fund (EFF) – under shared management-  is the major 
financial pillar of the CFP with a total budget of €4.304 million for the period 2007-13.  
The EFF consists of five priority axes (a ta ble with EFF allocations per axis and MS is 
included in the annexes):  
 
7 • Axis 1 (28.49% of the total allocation) c overs the adaptation of the EU fishing 
fleet: scrapping premiums, temporary cessation, investments on board, small-
scale coastal fishing, socio-economic measures;  
• Axis 2 (28.38%) covers aquaculture, inland fishing, fish processing and 
marketing;  
• Axis 3 (26.49%) covers measures of common interest: producers' organisations, 
fishing ports, new market and promotion campaigns, pilot operations;  
• Axis 4 (12.92%) covers territorial devel opment of fisheries areas by the creation 
of local partnerships in fisheries dependent areas;  
• Axis 5 (3.72%) covers technical assistance. 
The 5 largest current recipients are Sp ain (26.29%), Poland (17.05%), Italy (9.86%), 
Portugal (5.73%) and Romania (5.36%). Together they account for close to 65% of the total allocation of funds.  
2) The Second Financial Instrument (EC 861/2006) – under direct management-  
provides support for a series of actions not covered by the EFF: 
a) Control and enforcement:  support is provided to national fisheries control 
programmes which enable MS to fulfil th eir role in relation to control and 
enforcement of the CFP. The total budget is €345 million for 2007-2013.  
b) Data collection and scientific advice:  funds are used to support the establishment of 
complete datasets by the MS (under so ca lled Data Collection Framework) and used 
for the evaluation of fisheries resources  and decision making. The total budget is 
€360 million for 2007-2013. 
c) Governance of the CFP:  providing funding for consultative/advisory bodies, 
Advisory Committee on Fisheries and Aqu aculture (ACFA), the Regional Advisory 
Councils (RACs), and for communication a nd dialogue with stakeholders and the 
public. Expenditure for 2007-2013 is €45 million. 
d) International relations : voluntary and compulsory contributions to Regional 
Fisheries Management Organisations (RFM Os) and UN bodies dealing with fisheries 
and law of the sea amounted to €9.8 milli on in 2010; €11 million are programmed for 
2013. It has to be noted that although Fisher ies Partnerships Agreements (FPAs) are 
mentioned in the Second Financial Instrume nt, it does not constitute the basic act for 
such expenditure because each FPA is covered by a Specific Council Regulation. 
3) The European Agriculture Guarantee Fund (EAGF) – under direct management-  
finances intervention and compensation fo r production and marketing planning in the 
Common Market Organisation for fisher ies and aquaculture products (about €12,5 
million per year). The EAGF also supports th e scheme to compensate for the additional 
costs incurred in the marketing of certain fishery products from the outermost regions. 
The total amount of the compensation is around €15 million per year. 
2.1.2.  Funding of the IMP  
4) The Integrated Maritime Policy (direct management)  was financed on the basis of 
Article 49 (6) (a) and (b) of the Financial Regulation funding pilot projects and preparatory actions. The total volum e for 2008-2010 was €20.4 million. A financial 
regulation has been proposed by the Commission to finance the further development of 
the IMP between 2011 and 2013 with a budget of  €50 million. The regulation is currently 
discussed in co-decision and is likely to be adopted before the end of 2011.  
 
8 2.2. Performance and problems 
The conclusions of the CFP reform IA repor t were that, notwithstanding progress made 
with the reform of 2002, the CFP had failed to ensure a sustainable exploitation of fish 
resources on its three dimensions: environmental, economic and social16. 
The identification of problems and drivers for these problems was difficult because of 
their interdependence. In spite of that  interdependence, the following ranking of 
problems was set: 
• The main problem of the CFP is the lack of environmental sustainability ; that is the 
existence of overfishing, or of an excessive fishing pressure. Out of the 93 stocks for 
which sufficient scientific advice exists, onl y 21.5% are exploited at levels delivering 
maximum sustainable yield (MSY), 35% ar e over-exploited and 43% are outside safe 
biological limits17. That means that 78.5% of Commun ity stocks for which there is 
scientific advice are fished unsustainably. Fleet's overcapacity was found to be one the 
main drivers for overfishing. The high level of discards, poor compliance and the lack 
of sufficient scientific advice were found to be important additional ones. 
• The second major problem of the CFP is the poor economic sustainability.  Economic 
performance, in particular of the catchi ng sector, is poor. Gross Value Added (GVA) 
per vessel has been diminishing over the last  few years and no more than half of the 
fleets cover all of their costs.  As a result,  fleets are vulnerable to external shocks (in 
particular to the evolution of fuel prices which, at current prices of €0.6/l, represent on 
average 25 to 30% of total revenues) a nd dependent on public support (FIFG and EFF 
funds could represent on average around 5 to 10% of the total turnover). The situation 
as regards processing and aquaculture is generally speaking better. However, as further explained below, aquaculture is hampered by the lack of innovation, 
particularly as regards marketing and commercialisation activities and by the very small average size of firms (98% are SMEs). 
• The third major problem is the lack of social sustainability
. From a demand 
perspective, low wages and high safety hazards  mean that the catching sector is not an 
attractive enough source of employment to new generations of local fishermen. From a supply perspective, the poor environmenta l sustainability together with the poor 
economic sustainability mean that employment,  particularly in the catching sector, has 
been declining at least for the last 15 years at a rate of 4 to 5% per year. The decline 
of employment in the catching sector risk  affecting the medium term viability of 
coastal communities; in particular of t hose where there are not obvious employment 
alternatives to the catching sector.  
• The external dimension of the CFP
 has also performed less well than expected, 
particularly as regards environmental sustai nability, but also in terms of international 
governance. In spite of improvements in de sign and delivery, Fisheries Partnerships 
Agreements (FPA) are still perceived as a source of subsidies for the EU fleets and not necessarily in line with environmental sustai nability in the waters of the beneficiary 
countries. For their part, the Regional Fish eries Management Organisations (RFMO) 
are generally considered as unable to revert the decline of international fish stocks. 
• Finally, the CFP has been affected by a numbe r of external factors such as pollution, 
climate change and the increased use of th e marine space by other users, which affects 
fisheries and development of new aquaculture farms. 
As outlined in the CFP reform IA report, part of  that failure can be attributed to the very 
complex and cumbersome framework of the CFP, which makes implementation and 
 
9 compliance difficult, and to the design of ma nagement tools (notably TAC, quotas and 
relative stability). However, to the extent  that the overarching objective of the CFP 
financial instruments was " to support the common fisheries policy so as to ensure 
exploitation of living aquatic resources and support aquaculture in order to provide sustainability in economic, environmental and social terms
18" it appears evident that part 
of the failure can also be attributed to the policy funding.  
 How can this be explained? First, there ar e serious problems linked to the design of the 
CFP financial instruments, the EFF in partic ular. Second, these problems acted as drivers 
for the lack of effectiveness in supporting t hose CFP objectives that were intended to be 
achieved with the help of the financial meas ures.  These two categories of problems are 
developed below. 
 
2.3. Problems linked to the design of th e CFP and IMP financial instruments 
…. 
The complexity of financial support under the CFP  
According to CFP reform IA report, the regul atory framework of the CFP is particularly 
complex
19. Complexity affects also the financial tools of the CFP, as shown by the above 
description. Linkages between the CFP and the financial instruments supporting its 
implementation are lacking. Each of the CFP and IMP financial instruments has its own implementation systems (including progr amming, financial decisions, monitoring, 
evaluation and control), comitology  and is negotiated separately. As a result there is little 
possibility of co-ordination between these inst ruments and of building synergies. It is 
also difficult to ensure cross-compliance between the mainstream EFF funding and the 
obligations of the Member States regarding control and data collection. Integration of 
CFP into IMP is also problematic.  
 As an example of the weak coordination, Producer's Organisations (POs) can receive 
support under the current EFF for their crea tion or the implementation of plans to 
improve the quality of products. On the other hand, the European Agriculture Guarantee Fund (EAGF) finances operational expenses of POs, i.e. intervention and compensation for production and marketing planning. As f unds can come from two sources, avoiding 
duplication entails an additional burden to administrations and beneficiaries of the 
support, since both instruments have different administrative procedures. 
 
2.3.1.  Financial instruments under shared management 
Financial instruments under shared management represent the bulk of the funding. They 
present a number of problems related to the l ack of strategic approach towards achieving 
the CFP objectives, to the lack of coordina tion with other funds and with a monitoring 
system that not only impedes a good follow up of  the instruments but that exacerbates the 
lack of focus on the achievement of the CFP objectives. 
Lack of alignment between EFF allocation cri teria and the size of the fishing sector: 
low absorption of the EFF 
 
10 Currently, the EFF is allocated on the basi s of dual criteria. For convergence regions 
(regions with the GDP per capita below 75% of  the EU average) funding is allocated on 
the basis of the historical share of the fish eries instrument in the cohesion policy. This 
method accounts for 75% of the overall EFF envelope. The remaining 25% is distributed among non-convergence regions on the basis of a num ber of criteria, such as the size of 
the production of the fisheries sector in the MS (including employment) and the scale of 
adjustment needed to reduce the fishing effort.  
As a result, the allocation of the funding is  predominantly aligned with the level of 
economic prosperity – the lower the latter the higher the funding. However, the distribution of fishing activities does not follo w the same logic. There are a large number 
of major fishing nations in the EU whic h belong to the non-convergence category. This 
results in huge disparities among the MS in  terms of the support per capita, to the 
detriment of the fishing sector in richer MS . These disparities measured at the level of 
the MS are as high as 30 to 1.  
As a consequence, the allocation method is one  of key factors responsible for the current 
delays in EFF absorption (certified interim payments sent by MS by October 2011 amount to 19,4% of the overall EFF allocation), as some MS combine a huge allocation under the EFF with a small fishing and aquaculture sector eligible for this support.  
This absorption problem is not unique to the EFF. According to the MFF 
Communication, many MS have difficulties in ab sorbing EU funds not least due to their 
fiscal situation which made it more difficu lt to release funds to provide national co-
financing. For EFF this was further complicat ed by the late adoption of both the EFF and 
the implementing regulations. Moreover, the launch of EFF overlapped with the 
finalisation of the implementation of the pr evious Financial Instrument for Fisheries 
Guidance (FIFG) 2000-2006 which put an additiona l strain on a relatively small fisheries 
administration. Finally, some MS had difficultie s in putting in place the Management and 
Control System (MCS) for the EFF, necessary  for the certification and reimbursement of 
payments made by MS to beneficiaries. The reason was that  MS gave priority to MCS 
required by other, larger EU funds. 
Lack of strategic approach in the EFF 
This is a recurrent problem already pres ent in the context of the previous FIFG
20, which 
lacked clarity in strategy and priorities regard ing the type of investment to promote. The 
EFF is programmed at the level of axes and MS can choose their own priorities from the 
"menu" of measures available under each of  them. This often leads MS to giving 
preference to investment facilitating absorption rather than focusing on key CFP priorities. This resulted, for instance, in overinvesting in some types of infrastructures. The EFF introduced the National Strategic Pl ans (NSP) to avoid this type of the 
approach. The NSP sets out the priorities, obj ectives, estimated public financial resources 
required and deadlines for its implementation, w ith particular regard to the objectives set 
out in the CFP.  
However, unlike for other EU funds under sh ared management, there is no EU-level 
strategic framework setting-up references leve ls and targets for strategic orientations. 
Moreover, the Commission does not approve NSP which gives it a very limited impact on its final shape. Finally, while some MS re garded the NSP as an important first step 
enabling a focus on the strategic priorities, most of them considered it as redundant with the Operational Programme (OP) and not wort h the administrative effort. As a result, 
most of NSPs have been disregarded once the OP is in place. In this way the lack of 
strategic approach remains unaddressed. 
 
11 Insufficient use of the EFF for achi eving environmental sustainability 
An example of the consequences of lack of the strategic approach is a low uptake of EFF 
measures related to the environment. Accord ing to the mid-term evaluation of the EFF21, 
measures to reduce the impact of fishing a nd aquaculture on the environment are hardly 
used: just €25 million has been committed so far by a few MS. Some types of 
investments eligible under the measure "investments on board fishing vessels and selectivity" are also relevant for the environment but MS tend to use it rather for the modernisation of fishing vessels. Furtherm ore, only a few MS use aqua-environmental 
and animal health measures.  
The EFF can also support measures of common interest intended to protect and develop 
aquatic fauna and flora while enhancing the aquatic environment. These measures relate to the construction or installation of static  or movable facilities, the rehabilitation of 
inland waters, or the protection and enhancemen t of the environment in the framework of 
NATURA 2000. However, the commitment rate of th ese measures is also very low. Axis 
4 appears to have a high potential for suppor ting environmental projects locally, but its 
current state of implementation does not allow having a sufficiently clear picture of this 
type of investments. 
Weak coordination of the EFF with the other funds intervening in the area of 
fisheries and maritime policy 
There are mechanisms available to coordinate  with the other structural funds and rural 
development fund. This is the objective of the so-called "demarcation lines", an informal 
inter-service document which specifies whic h fund should support a certain type of 
investment. However, MS found that Commissi on's guidance too general and focused too 
much on the demarcation, at the expense of co-ordination. In addition, as OPs are written 
at a stage when there is little ability to foresee the measures that will subsequently be 
implemented, it was difficult to fix clear de marcation lines. Further problems emerged 
during the implementation phase, due to some differences in the definition of eligible measures (e.g.: in-kind contributions, salary costs and VAT). Finally, subsequent modifications of the OP can result in the lines being obsolete. 
Weak co-ordination of local development implemented under EFF and rural development 
is an example of potential synergies which mi ght be exploited to a larger extent. Local 
groups created under both funds often exist in the same areas and face similar problems; 
yet the possibilities of co-operation between them  existing in the legislation in force are 
limited.    
Moreover, there is a large but unexploited pot ential for the co-ordination with centrally 
managed EU funds, such as LIFE. 
Lack of critical mass of projects 
As a consequence of the lack of strategic approach and the weak co-ordination with other 
funds, there is little concentration of EFF e xpenditure on strategic priorities, such as 
aforementioned environmental sustainability. A specific issue linked mainly to the sustainable development of fisheries areas is the size of the budgets of local partnerships. Some of them are as small as € 100,000 which means that local group cannot have a real 
impact on the economic situation in the fisher ies area - the experience shows that optimal 
budget should be around 2-3 million per group. This is made worse by the lack of alignment between allocation criteria and the size of the fishing sector. 
A weak monitoring and evaluation syst em that lacks focus on results and 
performance  
 
12 The monitoring and evaluation functions with in the EFF have various weaknesses that 
prevent high quality reporting and limit an effective impact on the results and performance of the programmes. The EFF does not have any common framework for monitoring indicators on results and impacts. DG MARE produced a guidance document covering these aspects
22. However, in the end each MS has set up its own indicators. The 
resulting heterogeneity impedes aggregation and comparisons across MS. 
Data based on a common list of 170 categories of data related to measures (as defined in 
Annex III of Regulation (EC) No 498/2007) ar e to be communicated on request to the 
Commission. MS consider that indicators re quired by EFF implementing regulation are 
too numerous and redundant. Furthermore, desp ite being compulsory output indicators, 
these data are no longer collected on a regular  basis by the EU as the Infosys system 
created for the 2000-2006 programming period and that was used to consolidate data 
received from MS is no longer operational under the EFF. The existing system is 
ineffective whilst it entails a high administrative cost at both national and EU level. 
Furthermore, the issue is not limited to the l ack of coherence. The interim evaluation of 
the EFF has shown also that both existing i ndicators and reporting at mid-term period are 
focused on operational level and financial abso rption, and that less attention is given to 
results and impacts. Impact indicators are also less developed and difficult to follow. This exacerbates the negative consequences of the lack of strategic approach. 
The above shortcomings explain the lack of focus on results. With the exception of 
scrapping where the combined use of the m onitoring system and the Fleet Register 
allows an overview of the evolution of the fleets, it is very difficult to know to what 
extent the money spent has actually contributed to achieving the objectives of the CFP.  
The insufficient use of conditionalities 
No conditions, sanctions or incentives can curre ntly be attached to the achievement of 
objectives. Furthermore, conditionalities are seldom used in the current CFP in general and in its financial instruments in particul ar. They take the form of general condition 
such as " operations financed by the EFF shall not increase fishing effort
23" or of very 
specific conditions attached to the eligibility of certain measures (exclusion of the retail 
sector from the support under Axis 2 for example). Some formal conditions are also present such as the need to carry out an ex-ante evaluation (including an environmental 
impact assessment), the use of a specific template for presenting the OPs, etc.  
Beyond these, there are neither general cond itions such as a strategic fit of the 
programme with the objectives of the CFP, nor specific requirement for compliance with 
other CFP-related legislations such as contro l, IUU or data collection regulations which 
could foster compliance and coherence of the whole policy.  
2.3.2.  Financial instruments under direct management 
The financial instruments under direct manage ment have also some design and delivery 
problems, often similar to thes e of the shared management instruments. In particular, 
delivery and design mechanism was a key factor  leading to an inefficient functioning of 
the CMO in fisheries and aquaculture pr oducts. These issues, however, have been 
addressed by the new CMO regulation adopted by the Commission within the framework of CFP reform
24: current intervention mechanisms have been simplified (one intervention 
instrument instead of six) and the role of Producers Organisations (PO) have been 
significantly reinforced.  
The main outstanding problem stemming fr om direct management relate to 
administrative constraints internal to the Commission. This translates into heavy 
 
13 administrative costs and burden for the EU and the beneficiaries, which are mainly 
administrations in the MS. This, for exampl e, is one of the reasons for the delayed 
implementation of control expenditure. 
The Comitology  attached to financial instrument s under the direct management is 
different, leading to a multiplication of meetings and a lack of awareness of the stakeholders that are not involved in the discussions held in each Committee.  
A related issue is the fact that these st rands of funding are generally managed on an 
annual basis, which is incompatible with th e longer term strategic approach required for 
the CFP reform. This also renders achievi ng consistency with the mainstream EFF 
funding very difficult, if not impossible.  
Similarly, the fact that data collection is implemented through a separate instrument 
prevents it from ensuring better policy enforcement – as the financial sanctions for those MS which do not provide required data are seriously limited.  
The adoption of the IMP funding instrument is still pending; therefore no conclusion 
about its functioning can be formulated at this stage. For voluntary contribution to RFMOs and the governance expenditure, the majo r conclusions of evaluations concerned 
legislative arrangements rather than deliver y mechanism; those were addressed by the 
CFP reform. 
Finally, the scheme to compensate for the a dditional costs incurred in the marketing of 
certain fishery products from the outermost regions has provided MS with a significant 
degree of flexibility to confront changes in  demand affecting the marketing of seafood 
products from these regions in terms of eligible products and levels of compensation. However, transparency regarding compensati on is not fully guaranteed because there are 
not always lists of eligible additional costs.  Furthermore, there are coordination problems 
with other EU funding instruments related to  fisheries and aquaculture (e.g. funding for 
aquaculture development in the EFF) or to other policies (e.g. POSEI Agricole ). 
2.4. ….limit their effectiveness in achieving CFP and IMP objectives 
This section focuses on these CFP problem s the solution of which requires public 
financial support. None of them is new. Th eir persistence over the years shows the lack 
of effectiveness of the public support tools so far (notably the FIFG and the EFF). 
2.4.1.  Environmental sustainability 
Public financial support has not eliminated the problem of overcapacity  
The CFP Reform IA report
25 identifies overcapacity26 as one of the key drivers of 
overfishing. Notwithstanding almost 30 year s of EU financial support to scrapping, 
overcapacity remains significant in many fl eets. Over time, the financial amounts 
allocated to scrapping have actually increased: €374 million for the period 1994-1999, 
€559 million (2000-2006) and €720 million for ecasted in the current programming 
period (2007-2013). Yet, nominal fishing capacity  (expressed below as a continuous line) 
is removed at the constant rate of ca 2%  per year (1.8% for 2007-2013), which barely 
corresponds to the increase in actual fishing capacity (dotted line) due to technological 
progress (2-3%).  
 
14 Figure 1 – Capacity development over the last 16 years in EUR12 MS 
0246810
1992 1994 1996 1998 2000 2002 2004 2006 2008Fishing Power (m illion k w
Multi Annual Guidance
Programmes III & IVEntry/Exit regime
under revised CFP
 
Source: EU's Fleet register 
Scrapping premiums can have the perverse eff ect of encouraging fishermen to continue 
fishing, even though fishing cannot provide them with viable income27.  
The above view was emphasized by the Court of Auditors (ECA)28. In its report it 
concluded that the measures taken to date to reduce fishing overcapacity by adapting the 
fishing fleet to fishing resources have b een unsuccessful. Moreover, according to the 
report, the effect of scrapping was fu rther reduced by investments linked to 
modernisation aboard which was very likely to lead to increases in fish catches. 
The effectiveness of scrapping premiums is further put into question because 50% of 
recent reductions of capacity (in terms of number of vessels) was achieved without EFF 
support and seems to be the result of increases of fuel costs and reductions of income. 
Finally, other management tools have proven effective in reducing capacity without 
public funding. This is the case of transferable  fishing rights implemented in a number of 
world fisheries and, increasingly, in the EU its elf. In Denmark, for example, in the first 
two years after the introduction of the system , the demersal fleet was reduced by about 
35% in terms of active vessels. A recent assessm ent of the capacity of the Danish fishing 
fleet showed a good balance between the capacity  of the active part of the fleet and the 
fish resources presently available for Denmark.  
Fishing has a high environmental impact 
The existence of high levels of discards  is identified in the CFP Reform IA as an 
important driver of the lack of environmen tal sustainability of the CFP. Based on FAO 
data, it can be estimated that in EU fisherie s discards could reach 23% of total catches. 
As TACs are based on landings; discarded fish are not taken into account. This 
unaccounted mortality reduces the effectiven ess of the TAC system as a conservation 
tool and undermines scientific advice.  
The reformed CFP proposal includes ban on di scards. As shown in the CFP Reform IA, 
such policy should induce a change in sel ectivity of gears and fishing techniques. 
However, in the short term (2013-2015) it may imply significant negative impacts, both in terms of increased cost of fishing (resu lting from the acquisition of selective fishing 
gear) and reduced income from fishing (lower first sale prices).  
Another issues which needs to be addressed concerns a by catch of protected species. 
There are also scientific and public concer ns about the environmental impacts of the 
fisheries from a broader perspective of mainta ining biodiversity and the health of marine 
ecosystems. Some forms of fishing (bottom tr awlers for example) have a strong impact 
on vulnerable marine ecosystems, which need better protection. Small scale coastal fleets 
(SSCF) often (although not always) fish with  less negative impacts in a non-intensive 
 
15 manner, using a range of seasonally diverse fi shing methods on a range of species, have a 
relatively low impact on the ecosystem. 
Environmental impacts of aquaculture 
Extensive and some types of intensive aquaculture (such as closed recirculation systems) 
may have very low or no environmental impacts (apart from high electricity consumption in recirculation systems). However, some othe r types of intensive fish farming may have 
negative environmental impacts such as sedimentation, water pollution, genetic interaction with wild organisms or spread of diseases and parasites
29. 
Carnivorous fish farming, as other animal production sectors (e.g. poultry, pig 
production)30, imply a demand for fish meal and fish oil which may add itself to the 
fishing pressure on wild stocks for hum an consumption. In recent years, new 
knowledge31 and technologies have been develope d which may limit the future needs on 
fish meal and fish oil of the aquaculture  sector. However applied innovation is still 
required in these areas. Furthermore, the small size of the aquaculture sector acts as a disincentive for firms to invest more in  research and innovation, whereas the small 
average size of aquaculture firms limits their access to existing technologies. 
Furthermore, there are many cases where compliance with higher, standards (in 
particular in the phytosanitary field) in crease production cost and make farms less 
competitive in the market place. 
Aquaculture production is also highly depe ndent on a high quality environment – above 
all the water quality. This is an increasing concern for most aquaculture sectors.  
On the other hand, aquaculture often play s an important role in environmental 
conservation and enhancement of biodiversity, retention of water in the landscape and flood protection. In some cases aquaculture is instrumental in restoring wetlands for sustainable exploitation. These extensive or semi-intensive aquaculture systems can be 
compatible with sensitive habitats and can generate environmental benefits.  
One clear example of the above is that of extensive fishponds, especially in Central and 
Eastern Europe. They provide a very important  habitat for large numbers of water birds. 
They were created in the 1940s and 1950s, mo stly for carp farming. Very often such 
fishponds developed on the site of former natural wetlands and, due to the extensive 
management, have evolved into semi ‐natural wetlands supporting high biodiversity. In 
this way inland aquaculture has replaced na tural marshes in hosting high diversity of 
aquatic plants and animals. At the moment, many of these aquaculture facilities lie close to/in NATURA 2000 sites. In countries such as the Czech Republic, Romania and Hungary sites with fishponds makes up a quarter  or more of all special protection areas 
(SPAs) in the country
32. 
In economic terms, on the one hand, the provision of these environmental services results 
in higher production costs which make these firms less price-competitive. On the other 
hand, many consumers are not willing to pay a hi gher price for these products, in spite of 
their positive environmental role. As a result a quaculture activities in these areas risk not 
being profitable. Intensification of production in fishponds or the pure abandonment of traditional fish farms would severely decreas e their role as a wildlife habitat. Their 
drying up, encroachment by scrub and trees or replacement with other land use will lead to the decline of biodiversity. 
According to the EFF interim evaluation. th e lack of strategic approach, of clear 
priorities and of focus on performance and results seriously limits the contribution of the 
 
16 EFF in the environmental areas (see section "Insufficient use of the EFF for achieving 
environmental sustainability" ) 
  
Insufficient scientific advice and data and lack of co-ordinated approach to marine 
data do not allow for a fully fledged knowledge based policy.  
The CFP Reform IA report33 identifies the lack of sufficient scientific advice and 
economic data as an important driver for th e lack of environmental sustainability and a 
risk for the success of the CFP reform. Reliable scientific information (allowing for knowledge-based management) is available fo r just 45% of the 208 commercial stocks 
for which the EU is responsible. The situa tion is even worse for the Mediterranean, 
although this is partly explained by the fact that there are no TACs set at EU level. 
Furthermore, according to the Communication from the Commission " Consultation on 
Fishing Opportunities for 2011"
34, the number of stocks the state of which is unknown 
due to poor data has been steadily incr easing for the period 2003-2010 (from 48 to 60 
stocks in the North-East Atlantic and adjacent waters). 
Significant amounts of additional funding w ould be required (estimated at around €20 
million/year). This should be also considered  in the light of potential risk that the 
capacity of the MS to co-fund data collec tion expenditure may be reduced, in the 
aftermath of the current budgetary austerity programmes. 
Knowledge is not only necessary for fisheries but also for the wider maritime economy. 
Member States spend approximately €1.5 b illion a year collecting marine data. The 
impact assessment35 for "marine knowledge 202036" found that a better-organised marine 
data infrastructure would not only save €300 million a year to existing users but open 
new opportunities for innovation worth a nother €60-200 million a year. The co-
ordination between data collection done unde r the Data Collection Framework (which 
largely supports collection of data) and th e European Marine Observation and Data 
Network (which largely assembles data that  has already been collected in order to 
facilitate their distribution to users) is insufficient at the moment. 
Insufficient compliance with the CFP rules  
Since 1996 EU provides funding to control progr ammes which enable MS to fulfil their 
role in relation to control and enforcement of the CFP. As concluded by the CFP IA, the 
control and IUU Regulation se t up new framework which properly addressed weaknesses 
detected by, inter alia, the report of the EC A. However, the implementation of this 
framework, in particular in terms of new technologies (including those made obligatory 
by the EU control regulation) requires si gnificant amounts of funding. The increased 
frequency of the control – a main reco mmendation of the evaluation of the second 
instrument – will have similar consequences. Finally, as in the previous case the capacity 
of the MS to co-fund control expenditure may be reduced, in the aftermath of the current 
budgetary austerity programmes.  
The lack of common tools to regulate spat ial deployment of economic activities at 
sea and collaboration in the implementation of environmental policy 
Competition for space among human maritime activ ities and in the marine environment, 
combined with no or limited coordination increases pressure on the marine environment. The current state of development of Maritim e Spatial Planning (MSP) is insufficient to 
achieve environmental sustainability. It can  also have negative effects on economic 
sustainability, in particular for the marine  aquaculture sector, as the lack of MSP 
 
17 providing investors with a business certainty is  considered to be an important bottleneck 
for the development of the sector. 
The Marine Strategy Framework Directive requires Member States to achieve good 
marine environmental status by 202037. Member States are required to cooperate where 
they share a marine region or sub-region. E xperience so far demonstrates EU led co-
operation – such as EU strategy for the Baltic S ea - is much more efficient in this respect. 
Such coordination needs to be developed in other sea basins which require the set-up of 
steering mechanisms and stakeholder involvement.  
2.4.2.   Economic sustainability  
EU fisheries and aquaculture are char acterised by low innovation level and 
insufficient economic viability 
According to the MFF Communication, the EU  faces a significant innovation gap that 
needs to be addressed if the EU is to compete with other developed economies and 
emerging, developing economies38. 
These innovation gaps exist also in the fi sheries sector. The CFP reform IA report39 
points out that, on top of overcapacity, low le vels of innovation explain part of the poor 
performance of the catching sector and the stagnation of the aquaculture production in 
the EU for the last 15 years. Available data  shows that labour productivity (measured in 
terms of gross value added per employee) in the fisheries and aquaculture sector in the EU is 25% lower than the EU average. Neither  the FIFG nor the EFF have been able to 
significantly fill that gap, in spite of the significant amounts of public financial support 
vested to the sector (FIFG and EFF account for some 10% of the value of landings in 
some coastal areas)
40.  
The catching sector Although low innovation levels can have many effects, they certainly prevent the 
catching sector from adding more value to their products. It also means that production costs are higher than they could be.  
Figure 2 - Profitability of EU fishing fleets 
 
The issue of innovation is of a particular importance for the small scale coastal fleet  
(SSCF). 91% of fishing enterprises in this s ector own a single vessel, placing them in the 
micro enterprise category. This makes financ ing innovation particularly difficult, taking 
 
18 into account the risky nature of investment s in the sector and the difficult access to 
funding of SMEs in the current economic downturn. 
Aquaculture 
As stated above, the EU aquaculture production has not been increasing for the last 15 
years, and that in spite of a relatively high technological level and quality better than 
products imported from third countries.  
Figure 3 - Production of aquaculture (Worldwide and EU) 
Evolution of the total aquaculture production in EU-
27 and in the World                                
(reference year 1995: Index based on quantity produced) 
050100150200250
1995
1997
1999
2001
2003
2005
2007
2009IndexEU-27 production
G lobal production
 
The EU aquaculture is exposed to many important constraints such as competition for 
space and access to water, lack of level-play ing field and high administrative burden. As 
emphasized in the CFP reform IA, the high EU standards put EU aquaculture at the 
forefront of sustainable development in the world, but combined with higher production costs and the market which is not ready to compensate for more sustainable methods of 
production, aquaculture has a difficulty to comp ete price-wise with some third-country 
producers.  
Consumer awareness on aquaculture products  and their production methods are limited. 
They are not well informed about the sustainability and the high quality of the aquaculture production in the EU. Given this l ack of information the price factor remains 
the main driver of consumer choice. Furthe rmore, some European fish farming sectors 
have been facing repeated “bad press” in recent years, which has tarnished their image. 
New technologies, research, innovation and infr astructures in the aquatic environment 
are expensive. The results of the new know ledge and innovation projects are often not 
well disseminated, especially to SMEs (60% of the EU's aquaculture firms are micro-enterprises and 98% are SMEs). 
A significant proportion of the a ssets of a traditional aquaculture enterprise lie in the 
value of the stock, which makes any disease or abnormal mortality in the fish stock or the 
suspension of harvesting farmed molluscs a si gnificant risk to the economic viability of 
firms. The same goes for market closures related to the occurrence of marine bio toxins. 
The small size of most EU aquaculture firm s makes difficult their access to finance and 
to insurance (where it is available), possibly even more so than SMEs in other economic 
sectors. Aquaculture also has a long production cycle, which implies a significant time 
 
19 lag between a loan being taken out for site development and sufficient product sales to 
start making repayments. The long production cycles also make it more difficult for 
producers to cope with market price fluctuations. 
Finally, as stated above, another important bottleneck is the lack of certainty for 
economic investors, especially in the marine areas where spatial planning is lacking. 
The low economic viability of fisheries and, in particular, aquaculture, is largely the 
result of the organisation of supply and of  marketing and commercialisation. In that 
respect the CMO IA pointed to the fact that  EU supply is both diverse and fragmented 
while fisheries and aquaculture Producer Organisations (POs) lack the resources and the incentives to organise production efficiently and manage fishing. Furthermore, many EU 
producers do not sell their fish or aquacu lture products, but rather wait until buyers 
come. A large part of their economic fragility  comes from their poor understanding of the 
market and a lack of strategic marketing.  
The current EFF includes measures to addre ss some of these issues. However, these 
measures (linked to innovation and to f acilitating the adoption of environmental 
standards) are scattered over the differe nt axes and, with the exception of the 
Netherlands, are not addressed in a strategic manner by the MS. As stated above, in most 
MS the emphasis is put on "simple replacement"
41 investments. Axis 4 seems to have a 
high potential for fostering local innovation. In  those Member States where the local 
partnerships started early, there is alr eady evidence of a number of highly innovative 
projects42 in adding value to the local products (e.g.: marketing or processing of local 
catches including shellfish or seaweed). However, it is too early to see actual results. 
Understanding and tapping the  growth potential in maritime sectors   
Segmentation of maritime policies results in a lack of synergies and a lack of adequate 
support for research for technological innovation. This also impedes a clear 
understanding of where the real potential for marine growth exists.  
There are areas of potential technological i nnovation in martime activities which are not 
supported by sectoral or national instruments due  to their prospective nature. The lack of 
interoperability between sectoral, national and Community surveillance systems can be 
an example here. The current situation is th at whereas data stop at the national borders 
vessels and criminal activities do not. Duplicati on of efforts at regional, national and EU 
levels increase the economic costs, reduce th e overall effectiveness of surveillance and 
thus degrades security and safety at sea. This  is crucial considering that 90% of Europe's 
external trade is carried out at sea.  
Similarly, the lack of coordinated approach  results in conflicts between different 
stakeholders – often to the disadvantage of the fishermen or aquaculture farmers - and 
limits the potential for the economic growth. Hence the need for MSP which can balance 
different interests including the environmental aspects, and improve the predictability for 
planning of future investments.  
High fuel/energy consumption in fisheries  
Fishing, aquaculture43 and the processing sector contribute to CO 2 and other emissions 
and hence to climate change. Global fisheries represent around 1.2% of global fuel consumption. 
Based on Annual Economic Report data, it is estimated than on average consumption 
was 0.58 l of fuel per kg of landings in 2007. This figure has been worsening since 2002 
(0.38 l /kg) which most likely can be attributed to the deterioration of stocks.  
 
20 There are nevertheless very substantial differences between fishing gears. Pelagic 
trawlers & seiners (0.18 l /kg) and dredge s (0.24 l /kg) are those consuming less. 
Demersal (1.32 l kg) and –in particular – beam  trawlers (2.38 l /kg) are the most fuel-
intensive techniques. There are also signifi cant differences length categories. Generally 
speaking, the longest the vessel the lowest its  fuel consumption per kg of landed fish. 
Vessels over 40 meters consume far less than the average (0.32 l / kg); those in the 24-40m category consume 0.53 l /kg. Vessels up to 12 meters (SSCF) consume 0.81 l/ kg. 
Finally, the 12-24m category consumes 0.87 l /kg.  
If successful, the reformed CFP should signifi cantly improve the situation both in terms 
of absolute and relative fuel consumpti on and emissions – through the removal of 
overcapacity (less vessels fishing the same amount of fish) and through the rebuilding of 
the stocks (less time necessary for the catch ). With the introduction of market based 
system fleets should also become economically viable and more resilient to the increases 
in fuel costs. 
However, investments in energy efficiency re present a short term cost that will only pay 
in the long term, if fuel prices would be su fficiently high. The incentive for the sector to 
engage in such investments (e.g.: energy a udits and pilot projects which are possible 
under  the current EFF) seriously diminishes  as soon as fuel prices go down, with the 
result that sudden price surges take the s ector unprepared, which immediately threatens 
its profitability.  
The results of the evaluation, audits and th e ECA report, demonstrate that such energy 
efficient investments in particular with re gard to onboard modernisations need to be 
carefully framed in order to avoid increasing the ability of the vessel to catch fish in the 
current overfishing context. The same care has to be paid with financing engine 
replacement which very easily can increase the fishing capacity of vessels. 
2.4.3.  Social sustainability  
Low attractiveness of jobs in the catching  sector and the reduction of employment 
undermine the viability of fishing communities 
The CFP reform IA report referred to the low attractiveness of employment in the sector 
in particular for younger generations of local  people and to the threats the decline of 
fishing activities represent for many coastal communities dependent on fishing. The CFP in general and its successive public funding t ools have not avoided the decline of the 
employment and of the attractiveness of th e sector for new generations. From that 
perspective it seems clear that the role of  the public funding of the CFP in ensuring 
sustainable income has been poor at best. 
The decline of fishing activities is already a fact in many coastal areas as the employment 
in the fisheries, since 20 years, has been goi ng down at the constant rate 4-5% per year. 
This is also explained by wages that genera lly speaking remain below national averages 
and poor working conditions on board. 
Many of these communities are reacting and new activities are replacing fisheries as 
main sources of income and employment. However, some of these coastal areas may not have viable diversification alternatives  at hand. At the same time the employment 
potential in other maritime sectors in the area may not be exploited due to the lack of 
qualifications.  
In that respect, socio-economic studi es on fisheries dependent communities
44 have shown 
that in most cases, the alternative employment opportunities are not readily available or 
 
21 appropriate to the skill sets of fishers, a nd that the effects on employment will need time 
and adequate support (training, specific investments) to occur. 
Furthermore, the reduction of overcapacity th at should result from the CFP reform would 
bring about further employment losses. Acco rding to the CFP reform IA, these could 
amount to close to 24% of employmen t in the modelled fleets (2022 over 2012)45. Some 
further employment losses would take place in the ancillary services sector. Creation of some employment in processing would not be enough to compensate for the expected losses. 
Even though they represent 26% of employment in the fisheries sector
46 women are 
confronted with a series of challenges. There is a lack of visibility and recognition of the 
contribution women make to the sector and fishing communities: numerous women work in the family fishing enterprise (e.g. ta king up management, administration, marketing 
tasks etc.) or in ancillary activities such as  net mending, often without a legal status and 
the associated social security. In additi on women have faced obstacles in access to 
advisory and decision-making bodies (incl. resource management), as well as access to 
loans and there are no specific measures, outside Axis 4, under the current EFF.  
3. T
HE JUSTIFICATION FOR THE REFORM OF THE PUBLIC FINANCIAL SUPPORT 
INSTRUMENTS  
3.1. Who is affected by the public financial support instruments and how 
The public financial support instruments are tools to support the CFP and the IMP and 
contribute to achieving its objectives. As a successful CFP and IMP are the ultimate 
reason of being of public financial support, st akeholders affected are the same identified 
in the CFP reform IA report: 
Table 1 - Key stakeholders in the EU fishing industry  
Stakeholder Description of stakeholder Key interests 
Catching sector 
in the EU EU vessel owners, operators and crew. Maintaining profitability and livelihoods. 
Aquaculture 
sector Aquaculture producers Maintaining profitability and livelihoods 
Dependent 
businesses & 
communities  Business and communities dependent upon 
fisheries for their livelihoods. Maintaining profitability and livelihoods as 
well as the viability of communities in the face 
of the decline of fishing activities 
Processing 
sector Those processing raw material both imported 
and caught within EU waters Maintaining profitability and livelihoods. 
Increasing value added. Get access to stable 
supplies. 
Sector 
regulators National, regional and local bodies regulating 
fishing  Optimize public financial support as tool to 
achieve objectives of the policy. Guarantee 
food supply. 
Sector research Scientific research bodies contributing to the 
conservation and mana gement of stocks Contribution to an effective fisheries 
management regime through the timely access 
to high quality data. 
Consumers Those consuming fisheries products Availability, cost, quality and nutritional values 
of fisheries products with varying degrees of 
environmental scrutiny. 
Third countries Fishing sector in competition with EU fleets. 
Aquaculture producers, e xporters to the EU.   Conflicting interest between those who see the 
EU as export market and source of revenue and 
small local fishing communities that face 
competition from external fleets of the EU on 
access to local resources.  
NGOs, the civil 
society and EU 
citizens Non-governmental organizations advocating 
sustainable manageme nt of fisheries. 
The wider public with an interest in and 
concern for fisheries and the marine 
environment To maintain fish populations, marine bio-
diversity, and the amenity value of oceans, 
rivers and lakes together with an economically 
and socially sustainable industry. Adequate 
food supply. 
 
22 3.2. Has the EU the right to act? 
According to Article 3 (1) (d) of the Treat y of the Functioning of the EU (TFEU), the 
Union shall have exclusive competence in  the conservation of marine biological 
resources under the CFP. Other aspects of fisheries are, under Article 4 (2)(d) TFEU, 
shared competences between the Union and the Member States. Article 43(2) TFEU 
establishes the EU power to adopt the pr ovisions necessary for the pursuit of the 
objectives of the CFP.   
According to the draft IMP Financial Regul ation (2011-2013), the IMP objectives to be 
pursued through the future funding are linked to the following multiple legal basis: Articles 43(2) - Fisheries, 91(1) and 100(2) - Transport, 173(3) -Industry, 175 –
Territorial Cohesion, 188 – Research, 192(1) -Environment, 194(2) –Energy and 195(2) 
– Tourism of the TFEU
47. As regards Integrated Maritime Surveillance (IMS), it will be 
financed essentially on the basis of sectoral legislation.  
3.2.1.  Subsidiarity and proportionality tests 
According to the MFF Communication, the propos al for the future budget of the EU has 
strong in-built pan-European logic and focuses already on "the policy areas where the 
EU can be more effective by acting through the EU level in the current climate of 
national austerity and financial consolidation". In that respect there is strong subsidiarity 
logic in it as regards the areas and issues it proposes to cover and address.  
Regarding fisheries, the MFF Communication refers to a new European Maritime and 
Fisheries Fund (EMFF) structured around 4 pilla rs: Smart, Green Fisheries, Smart, Green 
Aquaculture, Sustainable and Inclusive territo rial Development and Integrated Maritime 
Policy. The first three pillars are under the shared management, the last one under the 
direct centralised management. In a ddition, the EMFF will include accompanying 
measures in the areas of data collection and scientific advice, control, governance, 
fisheries markets (including outermost re gions), voluntary payments to Regional 
Fisheries Management Organisations (RFMOs ) and technical assistance. Two further 
international instruments complement the policy: Fisheries Partnerships Agreements (FPAs) and the compulsory payments to RFMOs. As explained before, these two 
instruments will remain outside the scope of EMFF. 
The subsidiarity and proportionality for th e parts of the CFP falling under shared 
competence is as follows: 
Regarding the EMFF itself, its general objective is to support the objectives of the CFP. 
Given the structural problems of the fisheries sector (as explained in the present IA but 
also in the CFP reform IA and the CMO IA reports) as well as the limits on the financial 
resources of MS – in particular in the curre nt economic context - MS are not in a position 
to sufficiently achieve these objectives acti ng on their own. They can therefore be better 
achieved at EU level by multi-annual financing focussed on the relevant priorities.  
Achieving sustainable fisheries within the fi eld of the exclusive competence of the CFP 
may imply negative social impacts for coastal communities, particularly in the short to 
medium term. This is of particular im portance for coastal communities depending on 
fishing, as the viability of some of them is already precarious today.  
In this context, public intervention maximisi ng value added of the fisheries or allowing 
fishers to find alternative jobs, in particul ar in the expanding sector of maritime economy 
is expected to be of crucial importance. EU  financial support will also set the framework 
 
23 for national state aid, thus preventing di stortion to competition among the MS which 
might undermine the implementation of the CFP reform. 
Many factors related to the aquaculture sector  (e.g. allocation of space, issuing and 
renewing of licenses; red tape) have a strong subsidiarity dimension. On the other hand strategic choices made at national level ma y impact the development in neighbouring MS 
or in the whole of the EU. This is due to the fact that many aquaculture sites operate in marine ecosystems which go beyond national borde rs and due to the development of off-
shore aquaculture (which can be towed form one  marine area to another or, in the future, 
even to waters within EU competence) and to the increasingly global nature of market 
for some aquaculture products (such as salmon, sea bass or sea bream). 
Promoting the sustainable development of a quaculture is also essential to meet the 
growing demand for fish and seafood in the EU  and to ease the pressure on marine fish 
stocks. It can also divert demand from less sustainable stocks and increase the number 
and range of substitutes for these species. As stated above, all these factors become more 
important in the current context of nationa l austerity and financial consolidation and 
given the SME nature of most of firms in the EU aquaculture sector. 
In their conclusions with regard to the EU aquaculture strategy of 2009, both the Council 
and the European Parliament (EP) supported th e further financing of aquaculture both in 
the current EFF and the new, future financia l instrument.  The EP stated in its opinion 
that it:  
"29. Hopes that the future European Fisheries Fund in s upport of the reformed Common Fisheries Policy will provide 
for specific budget lines for sustainable aquaculture developm ent and support for investment in that sector, following 
best environmental practice, and to  promote economic activity and employ ment with a particular focus on 
technologically innovative plants with a lesser environmenta l impact (e.g. water purification systems for eliminating 
residues and pollutants), farms that promote fish he alth and welfare and sustainable forms of aquaculture; 
30. Hopes that this Fund will take into due account the need  to provide financial support fo r enterprises in the sector, 
particularly for SMEs and family-run enterprises, based on their contribution to the social and economic development 
of the coastal area and with the emphasis on remote and border areas ".48 
The Commission has taken on board these re quests and the proposal on the reformed 
CFP requires that MS prepare national strategic plans based on a set of strategic EU 
guidelines to create favourable conditions for aquaculture and to improve its competitiveness, to support its sustainable development and innovation, and to stimulate 
diversification. Open methods of coordination may take the exchange of information and 
best practices among Member States a step further. 
Control and enforcement  as well as data collection and scientific advice  are necessary 
pieces for the exclusive competence to be exercised and the general objectives of the CFP achieved. Data collection and scientific  advice are core element for efficient 
management of fisheries and marine resources; they are the key to a fully fledged knowledge based policy. Similarly, control activ ities co-ordinated and co-financed at the 
EU level provide for significant savings and synergies in terms of costs and compliance 
(for example through a joint purchase and use of control vessels). 
Regarding the CMO , according to the new CFP Regula tion, measures provided for under 
the CMO need to be consistent throughout the EU to maximize their effectiveness and to 
ensure the functioning of the internal ma rket. The compensation mechanism for the 
outermost regions is   
Finally, as regards the IMP , the rationale for action at EU level stems from the cross-
sectoral and trans-national nature of many of the activities involved. EU action is likely 
 
24 to produce clear benefits by reason of its scal e and effects, compared with activities and 
actions pursued only at the level of Member States and regions:  
• Marine knowledge will not imply investing EU money in data collection or data 
application, but limits itself to data assemb ly (i.e. pooling data that have already 
been collected) to create accessibility and inter-operability.  
• Even though the maritime surveillance activities are carried out by Member 
States, most of the activities and threats that they address are transnational in 
nature. Threat analysis done by one MS is  not shared on a systematic basis across 
borders thus identified threats regularly  remain without a global response. A 
Common Information Sharing Environment (C ISE) is expected to be developed 
in each MS, in each EU sectoral commun ity and across communities in the EU.  
Only the EU common/central component will be financed by the Integrated Maritime Surveillance (IMS)/IMP budget. The sectoral components (at EU level) will be financed by the respective sect oral funds. the national by the MS. The 
setting up of the CISE should allow fo r technical improvements, sectoral 
enhancements and better situational awareness. This process shall also not hinder the development of existing and planned s ectoral information systems, as long as 
the need for interoperability enabling info rmation exchange with other systems is 
taken into account. 
• Competence for the MSP process will remain at MS level, based on common 
standards in the context of a proposed EU initiative. However, EU action would ensure that MS implement MSP in EU waters and that they would do so more coherently through common objectives a nd through effective cross border co-
operation between Member States. Doing so  would allow to achieve the potential 
economic effects of MSP which are four fold: (i) enhanced coordination and 
simplified decision processes leading to re duced transaction costs, (ii) enhanced 
legal certainty for all stakeholders in the maritime arena, (iii) enhanced cross 
border cooperation and (iv) enhanced coherence with other planning systems. 
• From a maritime perspective, issues may be more often related to sea basin 
characteristics and are thus trans-nationa l by nature Given the highly integrated 
and globalised nature of most of the ma ritime economy, MS are often not able to 
address the trans-national dimension of the Blue Growth concept and hence to ensure full consistency with the Europe 2020 goals. However, it has to be noted that proposals to be brought forward concerning maritime economic sectors as a result of the on-going Blue Growth initiativ e will not necessarily imply additional 
investment but a better focus of interven tions on areas which are most promising 
in terms of growth and employment through innovation.  
In all cases, action at EU level will not go beyond what is required to achieve the 
objectives of the MEFF. 
4. W
HAT ARE THE POLICY OBJECTIVES ? 
In line with the CFP reform and the MFF Communication the general objectives of the 
EMFF are the following: 
• To support the objectives of the reformed Common Fisheries Policy.  
• To support the further development of the Integrated Maritime Policy.  
 
25 The future funding instruments is a tool to  achieve these objectives. In doing so, it will 
also contribute to the Europe 2020 strategy, in particular to three flagship initiatives: a 
resource efficient Europe, an innovation Union and the agenda for new skill and jobs49. 
As stated above, the focus of the EMFF w ould be put on market failures resulting in 
activities not sufficiently financed by private or national funding. 
It is also important to maximize the effectiveness and the efficiency of the instrument and 
of the available funds by addressing the desi gn issues identified above. On the basis of 
the problem analysis above, the following specific objectives have been defined. 
4.1. Objectives related to the design of the financial instrument 
Table 2 – Problems and specific objectives: design  
Problem  Specific objective 
Lack of alignment between EFF allocation criteria and 
the size of the fishing sector. Align allocation criteria with th e size of the fishing sector. 
Lack of critical mass and concentration 
Too much focus on investments unrelated to key CFP 
objectives and too many individual subsidies with 
limited impact and deadweight effects. Ensure thematic concentration on smart green investments and 
territorial development. 
 
Foster strategic thinking and favour collective approaches, 
without prejudice to other approaches that could develop. 
The ineffective strategic programming leads to a "pick 
and choose" strategy, lacki ng synergies and coherence.
A weak monitoring and evaluation system impedes 
focus on performance and results. 
Insufficient use of conditionalities linking financial 
support to the achievement of CFP objectives. Improve strategy & programming. 
 
Set up a consistent framework for monitoring and evaluation, 
based on common indicators. 
 
Reinforce conditionalities and enlarge the scope of cross 
compliance. 
Lack of co-ordination with other EU funds intervening 
in fisheries and maritime areas. 
Focus on demarcation instead of co-ordination.  Exploit synergies with other EU funds (ERDF, ESF, CF, 
EARDF), including with LIFE funding and prioritised action 
frameworks for NATURA 2000. 
The administrative burden of fund management and the 
complexity of managing se veral funding instruments. 
The low level of absorption in some MS. 
Problems linked to direct management. Exploit synergies between  CFP and IMP financial 
instruments. Simplify deliver y and reduce administrative 
burden. 
 
4.2. Objectives related to the content of the financial instrument 
Table 3 – Problems and specific objectives: content 
Problem Specific objective 
Public financial support has not 
eliminated the problem of overcapacity. Eliminate subsidies ineffective in 
reducing overcapacity. 
Fishing has a high environmental impact. Reduce environmental impact of 
fisheries.  
 
26  Contribute, in the context of the 
sustainable fisheries, to the sustainable management and preservation of marine ecosystems and to the objectives of MSFD and Natura2000. 
Aquaculture must contribute to high environmental standards.  Promote green growth in 
aquaculture. 
Insufficient supply of data and scientific advice and lack of co-ordinated approach to marine data do not allow for a fully fledged knowledge based policy. Improve the availability of high 
quality and timely data and scientific advice. Ensure compliance with Data Collection Framework, co-ordinate fisheries and IMP related data. 
Insufficient comp liance with the 
CFP rules. Ensure compliance with CFP rules. 
Lack of common tools to regulate 
spatial deployment of economic activities at sea and collaboration in the implementation of environmental policy. Promote an integration of policies 
enabling sustainable and cross-border/ecosystem-based management of European sea basins. 
EU fisheries and aquaculture are characterised by low innovation levels and insufficient economic viability. Increase innovation in particular in 
the value-added of fisheries and aquaculture products. 
Promote animal health and welfare. 
Insufficient understanding and 
tapping growth potential in the maritime sectors. Promote the use of cross-sectoral 
instruments tackling segmentation of maritime policies and contributing to the identification of new growth opportunities.   
High fuel/energy consumption in fisheries and some types of aquaculture Reduce energy consumption in 
fisheries and aquaculture. 
Low attractiveness of jobs in the catching sector and the reduction of employment undermine the viability of fishing communities  Improve attractiveness of jobs, 
(including gender equality) and support the viability of communities in areas dependent of fisheries, including reconversion to other maritime sectors. 
5. WHAT ARE THE POLICY OPTIONS ? 
The No Policy Option  - Options 2 and 2a analysed in the CFP reform IA report50 
included the elimination of all EU public fi nancial support (as well as of the CMO). The 
economic and social performance of options 2 and 2a was found to be significantly worse 
than these of options 1 and 1a (which tran slate into Option EFF+ in this IAR – see 
below). On the economic side this is due to short term negative economic impacts (stemming from the introduction of a discar ds ban and the transition to MSY) not 
 
27 compensated by public assistance targeting more selective gear, marketing and 
innovation in particular. On the social side, short to mid term reduction of employment in 
the catching sector would remain not addressed.  
In addition, the discontinuation of funding fo r data collection, scientific advice and 
control is not a feasible option, as it will m ean that the CFP would be deprived of any 
knowledge base for formulating policy. Sim ilarly, without co-ordinated and co-funded 
control policy, the efficiency of control w ould be drastically reduced with dramatic 
consequences for the compliance.  
In the same wake, lack of funding for IMP would amount to the discontinuation of the 
policy development so far and missed growth and job opportunities at a time when other countries, such as the US, dynamically develop this policy viewed as one of the most promising avenues driving future economic development.  
Furthermore, the lack of funding for governan ce would put an end to the dialogue with 
the sector, established in the aftermat h of the 2002 CFP reform. Finally, without 
voluntary contribution to RFMOs, the EU would lose credibility in this organisations and 
legitimacy to projects internationally the principles of sustainable fishing.  
For these reasons the "no policy option" is discarded and not taken any further into 
account in this IAR. This is in line with the conclusions of the CFP reform IA report 
where the preferred options include reformed  EFF and CMO as well as an IMP financial 
instrument. It is also in line with the MFF Communication. 
The No Policy Change Option . The Status Quo Option in the CFP reform IA explicitly 
included the continuation of the current EFF and IMP financial instruments under an unchanged CFP. The Status Quo Option wa s analysed but it was found to perform 
significantly worse than any of the CFP reform  also analysed. As a result it was not the 
preferred Option. It is nevertheless kept in  the present IAR as a baseline to help 
comparing the impacts of the different reform options.  
5.1. Elements common to all reform options 
The three reform options developed below are alternative avenues to achieve the general 
and specific objectives of the EMFF. There ar e nevertheless common elements to each of 
them. These common elements are to a la rge extent pre-determined by the MFF 
Communication as well as by the proposal for a regulation of the European Parliament 
and of the Council on the Common Fisher ies Policy (the new basic Regulation)
51. These 
common elements are the following:  
• The global financial allocation for the EMFF,  international fisheries and RFMOs is 
€6.7 billion, as stated in the MFF Communication. The key elements of EMFF architecture are also those implied by the MFF Communication (fisheries, aquaculture, local development and IMP).  
• The distribution of the global financial allocation between policy areas is the same in 
all the options, in line with the analysis contained in the ex-ante section of this 
document
52. 
• Most of the direct fleet subsidies (the  current EFF's Axis 1) are discontinued, 
including permanent (scrapping) and temporary cessation, in line with the conclusions of the CFP reform IA report and the ne w basic Regulation. The analysis of the 
Commission on this point coincides with th e criticism of some MS and many NGOs   
that these measures actually do not eliminate overcapacity. The MFF Communication 
 
28 foresees the re-deployment of inefficient direct fleet subsidies in line with the 
objectives of the Europe 2020 Strategy.  
• In line with the simplification objectiv e of the MFF Communication, the new CMO 
regulation will be integrated into the EMFF. Only one tool of market intervention (storage aid) is to be temporarily maintained (to be phased out until 2018) and the assistance to POs will be significantly increased.  
• The scheme to compensate for the additional costs incurred in the marketing of certain 
fishery products from the outermost regions of the Azores, the Canary Islands, French 
Guiana and Reunion will be integrated into  the EMFF and its amount maintained at 
current levels. 
• Critical mass, which is another aim of the MFF Communication, is to be achieved 
through more emphasis on collective actions, including through PO, and on increased budgets for FLAGs under the territorial devel opment pillar. In line with the views of 
stakeholders, more emphasis will also be put on projects requiring strategic plans – 
such as marketing and production plans impl emented by PO and local development in 
general (as it requires the preparation of integrated strategy of local development) . 
• For the IMP part of funding, as the overa ll objectives of the IMP remain unchanged 
and confirmed by Council
53 and the European Parliament54, the major issue tested in 
this IA is related to the need of greater integration of the CFP into IMP, which was 
also a repeated request during the consultation process. 
• All the objectives related to the ex-EFF part  of the funding are addressed in Option 1 
and the results of this analysis are included in other options. 
• Beyond these elements, the financial support for governance (dialogue with 
stakeholders, communication) will be adapted to the content of the new basic Regulation (in particular the replacement of ACFA by an Advisory Committee). The 
same holds true for the voluntary contribu tion to RFMOs. Therefore no alternative 
options are tested for these two instruments.  
• The allocation criteria will be aligned w ith the size of the fishing sector. The 
allocation method will take into account two criteria currently used for the allocation of the EFF envelope among non-convergence regions: (i) the value of the production 
of the fisheries, including aquaculture a nd processing and (ii) the employment in 
fisheries, aquaculture and processing indus try. Additional criteria will account for the 
importance of the SSCF in the fishing sector. This criterion is intended to reflect the importance of SSCF for fisheries communities in  terms of jobs, the fact that most of 
them are micro enterprises and their greater economic vulnerability in the current context (but also in view of the fact th at TFC, which increase economic viability of 
fishing operators will remain voluntary for these fleets). 
• There was near unanimous support in the c onsultation for the continuing involvement 
of the Commission regarding data collection and control. Allocation criteria for these 
items of expenditure stay the same as at present, although allocations will be made for 
7 years instead of one.  
• The need for improved conditionality was al so an important result of the public 
consultation and FIFG and EFF evaluati ons. Furthermore, the MFF Communication 
requires that conditionality is introduced into  all programmes and instruments so that 
MS and beneficiaries demonstrate that th e funding received is being used to the 
achievement of the EU policy priorities. Accordingly, the use of conditionalities will 
apply to all reform options and will be ba sed on the following elements: (i) the scope 
 
29 of eligibility and the content of the measur es – in particular the elimination of 
scrapping and temporary cessation, (ii) the co mpliance with the control obligations, in 
line with the proposal for new CFP Regul ation adopted by the Commission on July, 
13th - a beneficiary from the fisheries sector must have a clean control track, in terms 
of significant infractions as defined in the control regulation, at least one year before 
applying for EU assistance, (iii)  the compliance with the IUU Regulation – a vessel on the list of IUU vessels cannot receive aid from the Fund; if aid was received before 
the vessel was put on the list it should be repa id, on the pro rata basis (iv) compliance 
with  data collection obligations by MS - l ack of compliance will result in interruption 
and suspension of payments (v) ex ante conditionality for aquaculture part of the spending – MS should adopt National Strategi c Plan for Aquaculture, as described in 
the new CFP basic Regulation, aiming at the removal of obstacles for the development 
in aquaculture. If this is not the case MS  should make a clear commitment concerning 
preparation of such a strategy by 1
st of January 2016. 
• Finally, monitoring and evaluation of th e policy will be improved by setting up a 
common framework and by defining and using a common set of indicators to measure 
progress towards the EMFF objectives. 
5.2. Description of the options 
5.2.1.  The status quo option55 
The Status Quo (SQ) developed in the CFP re form IA report is taken here as the main 
baseline option. It amounts to the continuation of the current CFP, including the EFF, the 
CMO and the IMP financial instrument. Nevert heless, the Status Quo takes into account 
recent legislation, in particular LTMPs, in the pipeline, the Control Regulation and the IUU Regulation. That way, it amounts to the CFP as it will be in  place by the end of 
2012.  
5.2.2.   Option 1: “EFF +” 
Option 1 is equivalent to options 1 and 1a in the CFP Reform IA report
56. However the 
specific contents of the different axis ar e more developed. The Option addresses the 
problems related to the lack of policy links and synergies between CFP and IMP 
financial instruments under the existing financia l architecture. In that respect, this Option 
amounts as a supplementary baseline to assess the differential impacts resulting from the 
integration of all CFP and IMP financial instruments. 
Financial architecture :  
• CFP and IMP financial instruments continue  to be implemented separately; yet an 
effort is made to better co-ordinate their scope, objectives and delivery, in particular 
through the use of a similar timetable for their adoption for the period 2014-2020, 
coinciding with the adoption of new basic regulation. 
Content, programming and delivery of the new fund : 
• Common Strategic Framework and partne rships contracts allow strategic 
programming and focus on CFP and Europe 2020 objectives. 
• Thematic concentration and limits put on type s of eligible investment should move the 
funding away from "simple replacement" investment aid towards smart, green 
investments in fisheries and aquaculture; 
 
30 • Priority given to collective projects such as those implemented by local partnerships 
(under the current Axis 4), marketing and production plans implemented by POs, 
partnerships between fishermen and scie ntists and projects implemented by other 
collective bodies (groups of fishermen or aquaculture farmers, networks). This 
priority will be achieved by the design of the measures, financial allocations and 
eligibility criteria;  
• Preferential treatment for SSCF; 
• Current Axis 4 (territorial development) will be reinforced with the focus on value 
added and diversification and better coor dination with other Local Development 
initiatives.  
5.2.3.  Option 2: “EFF + Integration” 
Option 2 builds on Option 1 by proposing to me rge the financial instruments supporting 
the CFP into a single fund. IMP remains as a separate instrument. 
Financial architecture:  
• All financial instruments of the fisheries s ector are merged into one fund, but continue 
to be managed separately under the sa me budgetary methods of implementation  
(shared or direct management) as it is the case now.  
Content, programming and delivery of fund :  
• Same as EFF+.  
5.2.4.   Option 3: “EMFF Convergence” 
Option 3 takes the convergence of the funds one  step further via the extension of the 
scope of the fund under shared management . Actually, the integration of all existing 
fisheries and maritime instruments into a si ngle fund (with the exception of FPAs and the 
EU membership of RFMOs), is provided for in the Maritime and Fisheries Policy annex 
to the MFF Communication. 
Financial architecture:  
• Full integration of all CFP and IMP instru ments. Integration of data collection, 
control, CMO and the instrument for outer most regions under the shared management. 
All the shared management parts of th e single fund are covered by the scope of 
Common Strategic Framework (CSF) and Partnership Contracts. 
Content, programming and delivery of fund :  
• As Option 1 but expanding the scope to a ddress some elements of IMP under the 
territorial development pillar (current Axis 4). 
5.2.5.  Synthetic view of options 
The following table provides a synthetic view of the above three reform options against 
status quo. It also links the options with th e major problems and objectives of the future 
financial instrument. 
  
 
31 Table 4 – Description of options 
Specific objectives 
related to delivery 
mechanism Specific objectives 
related to contentsOption 1 "EFF+" Option 2 "EFF+ 
integration" Option 3 "EMFF 
Convergence" 
Align allocation 
criteria with the size 
of the fishing sector Ensure thematic 
concentration on 
relevant objectives, 
linked to 
environment and 
innovation Increase 
funding for local 
sustainable 
development Allocation criteria 
for future funding instrument based on three criteria: (i) employment in the fishing sector (ii) the value of production of the fishing sector (iii) the share of small scale fleet  As Option 1  As Option 1 
Ensure thematic 
concentration key 
CFP objectives. Ensure thematic 
concentration on 
relevant objectives, 
linked to 
environment and 
innovation  The ex EFF funding 
reorganised around 3 pillars with refocused measures: (i) Green, sustainable fisheries (ii) Green, sustainable aquaculture (iii) Sustainable and inclusive local development  As Option 1 As Option 1 
Foster strategic 
thinking and 
collective/ grouped 
approaches Ensure thematic 
concentration on 
relevant objectives, 
linked to 
environment and 
innovation. 
Increase funding 
for local sustainable 
development  Priority given to 
collective projects 
based on strategies: 
(Producer 
Organisation) (ii) 
collective actions 
carried by other 
bodies (iii) local 
partnerships  As Option 1  As Option 1  
Improve 
programming 
process and develop 
delivery 
mechanisms based 
on objectives and 
results rather than 
absorption. 
Develop synergies 
between CFP and 
IMP funding and 
other EU funds 
intervening in 
maritime and 
fisheries sector. Develop further 
synergies with local 
development 
strands under other 
EU funds  Use of Common 
Strategic Framework 
and partnerships 
contracts for EFF 
part of the funding As Option 1 but 
Common Strategic 
Framework 
includes also other 
CFP instruments 
(without including 
them into 
partnership 
contracts) As Option 2 but 
stronger co-
ordination and the use 
of partnership 
contracts for 
instruments included 
into the funding 
under the shared 
management part 
(control, data 
collection, market 
measures, 
compensation for 
outermost regions 
Set up consistent 
framework for 
monitoring and 
evaluation, based on Ensure thematic 
concentration on 
relevant objectives, 
linked to Reinforced use of 
performance and 
monitoring for all the 
CFP and IMP As Option 1  As Option 1 but 
performance 
indicators, monitoring 
and evaluation for ex-
 
32 the same indicators 
for MS environment and 
innovation. 
Increase funding 
for local sustainable 
development  financial instruments EFF part, data 
collection, control 
and CMOs integrated 
in the same 
framework under the 
shared management. 
   Cross-compliance 
building on the 
existing links. Full cross-compliance 
under the shared 
management 
6. COST-EFFECTIVENESS AND EX ANTE EVALUATION  
The MFF Communication sets both the 2014-2020 financial allocation for maritime and 
fisheries (€6.7 billion in 2011 prices for the EMFF, including market measures, FPA and the RFMOs) and big pillars on the EMFF will focus. However it leaves leeway for the 
measures to be eligible under the EMFF. This section looks at these measures from the point of view of their cost-effectiveness. Th e analysis is not complete though. Only these 
measures or categories of measures for whic h there are some (quantitative or qualitative) 
data are addressed below.  
6.1. Environmental sustainability 
The problem description has shown that  the contribution of the EMFF in the 
environmental sustainability area can be useful  primarily in the reduction of discards and 
by catches, in the foregone income of a quaculture farms in Special Areas of 
Conservation under the Habitats Directive and Special Protection Areas under the Birds Directive (including Natura2000 sites), in scie ntific advice and data collection and in 
control.  
Regarding the reduction of discards , the proposal for the reformed CFP includes discard 
ban. Such policy should induce a change in sel ectivity of gears and fishing techniques in 
particular from 2015 onwards. However, in the short term, until 2015, the move to catch quotas, the obligation to land all the catch as well as other technical (such as the closure 
of zones) and market measures (confiscation of income) could entail significant increased costs and reductions of fleets income  (to be added to similar impacts resulting 
from the move to MSY and the discontinuation of fleet subsidies). 
The combination of all these effects could br ing about very serious short term difficulties 
for parts of the catching sector, with the risk that some of the fleets segments that discard 
most would become unviable in the short te rm. Such an evolution could jeopardise the 
success of the anti-discard policy and resu lt in a high social costs for coastal 
communities. 
In order to address these unwelcomed effects,   a short term push to these fleets with 
inherent high discard rates will be justified thus facilitating the quick entry into force of 
the discard policy by supporting the adoption of  selective gears. The possible evolution 
and the logic of such an intervention are shown in the graph below.  
 
33 Figure 4 Expected revenues for haddock quota 2009 – 2030; changes with regard to a CFP 
reformed, no discard policy 
-10 20 30 40 50 60 70 
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030Estimated Revenue (€ Millions)
Haddock no change (€) Haddock with discard reduction policy (€) Haddock with discard reduction policy 20% value undersize(€) 
Results of some pilot projects (in particul ar the South West England Project 50% to 
reduce discards of beam trawlers) show th e use of selective gears could immediately 
reduce discards by 40 to 70%, without re quiring any further changes in fishing 
behaviour57.  
Regarding cost, estimations show that the cost of gear replacem ent for the whole EU 
demersal and beam trawler fleets (excludi ng 250 UK vessels >12 m which have already 
acquired selective gears) would amount to circa €125 million for one gear's replacement 
per vessel of €250 million for two. In add ition, some development costs may be 
experienced by the industry to develop effici ent, selective gears. Estimations indicate 
that a maximum of €50 million for the whole of  the financial period would be sufficient, 
as the experience of other countries (Nor way) shows that in the mid term the 
implementation of a discard policy is sufficien t in itself to foster the development of 
selective gears by the industry.  
Regarding aquaculture farms in Special Areas of Conservation under the Habitats 
Directive and Special Protection Areas unde r the Birds Directive (including Natura2000 
sites),  they may provide environmental se rvices, such as wildlife conservation and 
biodiversity and landscape effects, water quality, recreation and even archaeological 
benefit, which society does not pay for and which can limit their economic performance. 
These are difficult to measure and value in the absence of harmonised EU data.  
In terms of cost and benefit only proxies can be used58. The evaluation of an agri-
environmental scheme in the UK show paym ents to farmers in the environmentally 
sensitive areas in the period 1994 to 2003 was around £212 million and that benefit 
estimates exceeded costs, sometimes by many times59. On the basis of that, an estimation 
of €300 million could be a reasonable amount. 
The CFP reform IA has already shown the crucial importance of improving scientific 
advice and data collection  for the success of the reform and the risk that not doing so 
will carry out. Estimations in the CFP reform IA indicate that an extra €20 million per year will be required to have a reasonably guarantee that needs will be covered.  
The costs of data collection and scientific advice  amount at present to circa 0.66% of 
the GVA of the catching sector. This is comp arable to the combined public and private 
sector costs of collecting all environmental data in the maritime sector within the EU. 
 
34 Importantly, the EU expenditure influen ces the way the national money on data 
collections is spent and ensures a better coor dination of the investments between MS and 
a better quality of data. It avoids duplication of  work and increases the efficiency of the 
investments carried out by MS. 
An efficient control  is crucial for the success of the reformed CFP through the 
consolidation and modernisation of control rules, through the widespread use of new technologies and through laying down new cont rol methodologies and procedures as well 
as effective and dissuasive sanctions. It is exp ected that some tools such as simplification 
of the CFP and the use of transferable fish ing concessions would have a positive impact 
on compliance; however, other tool such as th e discard policy would imply an increase in 
control activities at sea and at port, in particular in the short term. 
The EMFF will ensure that new technologies ar e effectively put into operation to allow 
data validation and cross-checks. It should in  particular help the equipment of fishing 
vessels and administrations with Vesse l Monitoring System, Electronic Reporting 
System, databases that are essential for the correct functioning of the EU control system and contribute to smart growth by prom oting innovation and knowledge transfer 
throughout the EU. This scheme is compleme ntary with national budgets and actions as 
it reduces the administrative costs related to the collection of these data in MS. It will 
also result in fully automated reporting mechanisms, which will replace many of the 
current TAC and effort reporting obligations by MS.  
Funding needs for control are estimated at €325 million for new technologies, €160 
million for joint acquisitions and €115 million for other activities.  
In terms of costs and benefits, the EU expend iture influences the way the money is spent 
by MS, avoids duplication and ensures a bette r coordination of the investments between 
MS (including the joint acquisition and use of  patrol vessels and aircraft by the MS 
belonging to the same geographic area) and a better quality of data. Important efficiency 
gains will also stem from the increased qua lity of data. The interim evaluation of the 
Second Financial Instrument (Regulation 861/2006) pointed out that the execution rate of control projects was significantly higher fo r projects having benefited from an EU 
contribution than that of projects for which co-financing was rejected by the 
Commission, thus indicating that the EU financ ial contributions are relevant and induce 
MS to implement projects they would otherwise not consider. 
Beyond these main areas, there are still some additional environmental measures which 
could be covered but which cannot be quantif ied at the moment, such as actions to 
reduce the environmental impacts of aqu aculture (e.g. by assisting to extension, 
modernisation, construction of the aquaculture  facilities with a view to substantially 
reduce the possible environmental impact in terms of water pollution, nature protection 
or improved energy efficiency; supporting conversion to some specific production 
processes, etc.)  or incentives for the fi shermen for contributing to the sustainable 
management of marine ecosystems (collec ting lost fishing gear and other debris, 
monitoring and collecting data in Marine Pr otected Areas, assisting in gear replacement 
to reduce the impact on the sea bottom).
 Beyond these there are public concerns about 
the environmental impacts of the fisheries from a broader ecosystem perspective of maintaining biodiversity and the health of marine ecosystems. 
6.2. Economic sustainability: innovation gap  
There is a deficit in innovation activities between  the fisheries sector and the rest of the 
economy. A rough estimation of such "innovati on gap", calculated by comparing labour 
productivity (measured in gross value added/  employee) in the EU fisheries sector 
 
35 (catching and aquaculture) with the EU average, would be around 25.7%. This is shown 
in the following table (using OCDE data).  
 
Table 5 – Estimation of innovation gap: Differences  between GVA/employee total and in fisheries 
(catching and aquaculture) in 2007 
Member 
State GAV/employee 
total GVA/employee 
fish Difference 
€ Diff % over 
total 
DE 52831 48000 4831 9,14% 
F 66033 54250 11783 17,84% 
BE60 68169 105714 -37545 -55,08% 
DK 498771 502112 -3341 -0,67% 
SF 57784 48000 9784 16,93% 
ESP 45756 32822 12934 28,27% 
NL 58596 63425 -4829 -8,24% 
GR 42495 30672 11823 27,82% 
HU 5577912 1494030 4083882 73,22% 
IRE 79701 36241 43460 54,53% 
IT 54902 26573 28329 51,60% 
UK 39528 32860 6668 16,87% 
SWE 604463 456667 147797 24,45% 
PT 25956 22111 3845 14,81% 
PL 67842 25143 42699 62,94% 
Slowakia 25487 35388 -9901 -38,85% 
Slovenia 31531 12491 19040 60,38% 
Austria 59148 23339 35810 60,54% 
Czech 608367 343798 264569 43,49% 
Estonia 325770 148779 176991 54,33% 
EU    25,72% 
Iceland 6181526 10463881 -4282355 -69,28% 
Norway 793436 854214 -60779 -7,66% 
Source: STAN database for structural analysis. OECD (values in national currency) 
By applying that result to the EUROSTAT  figure of labour productivity for the EU 
economy (€52,000/year/employee), the gap could be estimated at some €13,300/year/employee for the catching and aquaculture sectors together. The fact that labour productivity in the sector in landlocked c ountries (where most of the activity is in 
 
36 the aquaculture field) is also significantly below national averages (e.g.: Austria or the 
Czech Republic) demonstrate that the innovation gap in the aquaculture sector is also significant. 
It is interesting to note that in countries where transferable fishing concessions already 
exist (Denmark and the Netherlands toge ther with Iceland and Norway), labour 
productivity in the sector is actually above  national averages. For that reason, it is 
expected that the introduction of these concessions for industrial fleets would 
significantly contribute to closing the i nnovation gap. However these rights are not 
expected to be fully operational before 2017. In addition, they will not apply to the 
SSCF.  
According to the CFP reform IA report,  under Option 1, GVA/employee will increase by 
147% by 2022 when compared to 2012. However, the increase for the SSCF will be just 
65%. The increase for all industrial vessels t ogether would be 165%. Hence, there is a 
risk that the SCCF lags behind in terms of innovation. It is estimated that the SSCF 
account for circa 65% of total employmen t (around 40% in full time equivalent 
employments) in the catching sector or 93,000 employees. That leaves a maximum gap to fill in the region of €1,236 million for these fleets in the period 2014-2020 (assuming 
that the productivity of the rest of the economy remains stable).  
A similar result would be for the aquaculture sector which employs ca 55,000 people 
(2007). The cost of introducing innovative production processes and products in the 
aquaculture sector is particularly high. For example, intelligent fish tanks, allowing for 
cost reduction through control and water quality in each tank, amount to €40,000 per plant. Another example of innovation in the commercialisation phase - Modified 
Atmosphere Packaging keeping the products fresh and of better quality for longer period 
of time, costs ca €30,000 per plant. The cost  of marketing and promotion campaigns 
oscillates between €50,000 and 200,000.  
Furthermore, the contribution of the EU to some of the associated costs (e.g. 
Environment Impact Assessments for start-ups) and to create effective advisory services 
would help in restoring some form of level playing field.  
A very significant part of the required innovation rest with marketing related 
measures . The reformed CFP puts an enhanced emphasis on collective actions which so 
far have proven to be quite useful; POs in so  far as market measures are concerned. The 
238 existing Pos represent ca 50% value of the fi rst sale of fishery products, that is ca €4 
billion per year. If all the POs adopt mark eting and production plans they would be 
entitled to receive, in line with the recently adopted new CMO regulation, financial assistance equal to 4% of this value, €160 million. With the co-financing level at 50% 
this would mean €80 million annually or €560 million for the whole of the period 2014-
2020. This amount does not take into account the new POs which may be created in 
fisheries and aquaculture in the coming years. 
The current level of funding should be mainta ined for market intervention measures (€15 
million/year), even if the current six market intervention mechanisms will be simplified to one single storage aid mechanism. It is e xpected that this mechanism will be widely 
used and that the participation of new MS in the scheme will significantly increase. The 
compensation scheme for outermost regions should also continue (€15 million/year).  
In addition, it is foreseen to create a Eur opean Market Observatory for Fishery and 
Aquaculture Products which would provide a global overview of the European markets 
for fisheries products through harmonised econom ic information, data and analysis all 
along the supply chain. This would make po ssible to better plan producers' supplies 
 
37 (fishing), production (aquaculture) and sales with  a view to increase income. The cost of 
such service has been estimated at €5 milli on a year. Finally, in order to amplify the 
expected positive effects of the observatory it should be complemented by other actions 
in the field of fisheries markets such as seminars, publications, external assessments, studies, evaluations of market policy and EU-level communication campaigns. 
6.3. Social sustainability: territorial development of coastal areas 
According to estimations done on the basis of the Leader programme and experience 
with the EFF until now, the above amount could allow creating some12,500 jobs by 2022 
plus 4,500 extra jobs in processing and marke ting. These should compensate for at least 
most of the job losses in the catching and ancillary services sectors resulting from Option 1 in the CFP reform Impact assessment.  
For the period 2007-13 the EFF budget for Ax is 4 is €567.4 million with ca 260 local 
action groups created (€2.2 million EFF per local action group). As this was a new 
measure some MS made very limited use of this axis (France €5 million, Ireland – €1.5 million). Taking account of predicted need s and assuming the establishment of 310 
partnerships an amount of the order of €1,057 million would be needed. This means an average budget per FLAG of €3.4 million. 
6.4. Allocation between green sustaina ble fisheries, green sustainable 
aquaculture and inclusive territorial development pillars.  
The lacking elements of the ex-ante calculations and the fact that ultimately the 
allocation of the money between pillars will be  the matter of the negotiations between the 
Commission and the MS, make very difficult su ch an estimate. Indicatively, the local 
development pillar, in line with the calcu lation above should account for ca 25% of the 
ex EFF envelope. 
For aquaculture, the allocation under EFF am ounts to 11% of the overall allocation – 
taking into account the needs for financing, in particular linked to environment and 
innovation, this allocation should increase to  ca 25%. This increase should be possible 
through (i) broader and focused measures targeting environment and innovation and 
removing spending items such as scrapping a nd (ii) the introduction of the ex ante 
conditionality linked to the aquaculture strate gy defined in the new CFP regulation, with 
the focus on the removal of bottlenecks impe ding investments in the aquaculture. The 
adoption of guidelines for aquaculture and Natura2000 may further clarify the rules for 
aquaculture farmers and public authorities and may be also helpful in that respect
61. 
Sustainable fisheries would account for the remaining 50%.  
6.5. IMP, RFMO and governance 
IMP: Sustained and increased funding for the IM P is necessary to fully implement it. 
The estimate of the financing needs for cross-cutting instruments is that these activities would require roughly €360 million to €420 million over 7 years.  
By 2013, only a limited part of the marine know ledge architecture will have been set up. 
The EU spends more than €1 billion a year on collecting public marine data. Yet professionals who require the data are confronted with barriers when they try to find and get permission to use existing public data. By assembling standards, nomenclatures, 
classifications and formats from different  sectors and Member States, EMODNET makes 
marine data accessible and enhance knowledge and innovation for industries that exploit marine resources. In Ireland, an expenditure of €70 million on marine mapping has been 
 
38 shown to result in benefits of €415 million to the fisheries, aquaculture, biodiversity, 
renewable energy, energy exploration and aggreg ate industries– a return of a factor of 
six62. The IA for EMODNet concluded that the full implementation of the programme, at 
a cost of €20 to €30 million per year, woul d result on a minimum annual benefit of €60 
to €200 million in increased competition and in reduced operational costs of €300 million per year
63. For instance, a 25% reduction in uncertain ty in sea-level rise would result in 
€100 million of direct savings in coastal defence infrastructure for public authorities. 
The purpose of funding of the IMS is to rem ove sectoral policy barriers and to overcome 
the current lack of interoperability be tween sectoral, national and Community 
surveillance systems, the limited capacity to  face transnational threats and to avoid 
duplication. Sharing surveillance informati on across sectors of activities and Member 
States will lead to significant saving as it w ill reduce directly the operational costs of the 
Member States. The current estimate is that an expenditure of €15 million per year for the establishment of the CISE will maximise the efficient use of existing data and avoid costly duplication
64. It will generate a better situati onal awareness of activities at sea, 
impacting on maritime safety and security, bor der control, maritime pollution and marine 
environment, fisheries control, general law enforcement, defence as well as the economic interests of the EU, so as to facilitate sound decision making. 
IMP funding will also be necessary to support the implementation of MSP in MS and the 
development of a common approach to MSP in  the EU. For instance, a reduction of 1% 
in transaction costs is estimated to lead to positive economic effects ranging from € 170 million up to € 1.3 billion by 2020. Especially, accelerating investments in wind-farm 
and aqua-farm activity would generate up to € 600 million by 2020
65.  
A major component of a common framework on MSP will be cross border co-operation. 
It is therefore essential that EU action ( possibly including legislation) on MSP will be 
accompanied by cross-border projects in the diffe rent sea basins in the EU where MS can 
test in practice the implementation of MSP in shared sea areas in order to build up expertise based on practical experience. Ba sed on the expected costs for similar MSP 
projects already launched and those planne d to be launched for period until 2014, there 
would be a need for around €8.5 million for the period 2014-2020. 
Also other forms of supporting capacity-buildi ng and exchange of best practices would 
be necessary for an effective implementati on of MSP within a common framework, such 
as setting up expert networks and organi sing stakeholder events. The financial 
requirements for such activities are curren tly estimated at around €0.5 million. Further 
work on developing MSP should include, inte r alia, studies and projects on how to 
address MSP in the high seas and on data use for MSP implementation. These projects 
are estimated to require around €1 million during the period 2014-2020.  
In order for the IMP to deliver fully on the objectives of Europe 2020 untapped sources 
of sustainable growth derived from marine living and non-living resources (Blue Growth) need to be identified and a policy framework at EU level conducive to growth, 
innovation and employment needs to be devi sed. In that respect, some €10 million per 
year would be devoted to:   
• Calls for proposals for projects on maritime innovation. Projects should be of a cross-
cutting nature, involving at least two maritime sectors. 
• Awareness building: workshops, conferences and other dissemination actions. 
• Support for maritime cluster development. 
 
39 • Other specific measures to be identified on the basis of the findings of the "Blue 
Growth" study, the key elements from the Europe2020 flagship projects and feedback 
from Member States and economic stake holders, including analysis of regulation. 
Finally, there will be a need for financial suppor t to the sea-basin approach of the IMP. It 
is very difficult at present to obtain reliable facts and figures that would make it possible 
to assess the status and changes of the econom ic, environmental and social conditions in 
Europe's sea basins. Identifying the strengths of the maritime activities within a sea basin 
would facilitate the development of sea-basi n specific maritime policy in an integrated 
manner and would be of high relevance to the Europe 2020 objectives. The activities to 
be financed would include studies and stak eholder activities, including the building-up of 
sea-basin specific stakeholder platforms, awareness raising, information dissemination, 
communication activities and tools. Financia l needs are currently estimated at around 
€30 million during the period 2014-2020. 
Non obligatory contributions to Regional  Fisheries Management Organisations 
(RFMOs): There should be an increase in the contributions made to these organisations: 
€11 million are programmed for 2013 and an incr ease by €2 million per year is foreseen 
in the following years. The increase will support scientific research and enhance control and compliance, notably by developing count ries, through projects in cooperation with 
these partners, either bilaterally or regionall y. This increase is necessary to enhance the 
environmental sustainability aspects of the new CFP in external waters. 
Governance (including RACs):   No significant increase of expenditure is expected with 
regard to that under the current period (€50 – 60 million for the whole period).  
6.6. Intended allocation of EMFF funds per area of activity 
The above discussion would justify an allocati on of funds per area as that shown in the 
table below: 
Table 6 – Areas of expenditure EMFF 
Areas of expenditure Approximate % of total EMFF allocation 
2014-2020 (without allocations to FPAs and 
obligatory contribution to RFMOs )  
Ex - EFF part (out of which) 67 - 70% 
  -  Fisheries 30 – 35% 
  -  Aquaculture 15-17,5% 
   - Local development 15-17,5% 
Voluntary contribution to international 
organisations including RFMOs 1,5 -2,0% 
Data collection and scientific advice 7 -8% 
Control - contribution MS 10 - 11% 
Market Policy including compensation to outermost regions 2,5 – 3% 
Governance 0,8-1% 
IMP 6 – 7% 
 
40 7. METHODOLOGICAL APPROACH FOR THE ANAL YSIS OF IMPACTS OF THE DIFFERENT 
OPTIONS  
The analysis of impacts below is based on a methodology which to the extent possible 
builds on the one developed for the CFP reform IA.  However, the impacts of subsidies 
were not systematically analysed there b ecause it was not possible to separate their 
impact in terms of income or contribution to profitability.  
These difficulties remain in the current IA. In view of that, 3 indicators were selected to 
deal with differential impacts which are then assessed from a qualitative point of view:  
Table 7 - Indicators 
Impact Main impacts Indicator 
Environmental impact Reduction of impact of fisheries on 
the environment Evolution of discards 
Economic impact Closure of the innovation gap in 
fisheries and aquaculture GVA per employee in the fishing  
and aquaculture sectors 
Social impact Creation of jobs outside the 
fisheries sector in communities dependent on fisheries Number of jobs created in 
fisheries-dependant areas  
8. ANALYSIS OF IMPACTS  
8.1. Option Status Quo: Continuation of the current policy (including the 
current EFF) 
As stated in the CFP reform IA report, th e SQ option results in modest, insufficient 
progress towards achieving the objectives. 
Environmental sustainability  is not achieved. Environmental indicators improve slowly 
over the period 2013-2020 and targets are not me t as a consequence of discarding, poorly 
assessed stocks and unaddressed overcapacity. Fish stocks will experience even more 
modest improvements if the control regulati on is less effective at reducing unreported 
catches than what it is assumed in the opti on. Relatively high levels of departure from 
scientific advice are likely to continue. The absence of an active discard policy and of 
actions intended to facilitate the transition to more selective fishing practices allow concluding that the level of discards would not get reduced significantly. 
Regarding overcapacity, modeled fleets will reduce in size (in number of vessels) by 
only 6.6% in 2017 and by 15.1% by 2022 (compared with estimated number of vessels in 
2012). Fleet size reduction would be larger for those MS that decide to adopt TFCs.  
Economic sustainability:  There would be a small, gradual improvement in economic 
performance, associated with the improvement  in fish stock status and the reduction in 
fleet size; however the economic viability of many fleets would remain under threat.  
GVA per employee will see a modest grow of 31.3% by 2022 (all vessel categories 
together). Looking at fleets sizes, GVA/ em ployee for the SSCF will increase by just 
18% in 2022. That of industrial vessels (> 12 meter) will grow by 30.3% These figures 
are sufficiently low to argue that most likel y there would not be any significant progress 
in closing the innovation gap in the fisheries,  in particular as regards the SSCF; on the 
contrary, the gap might become wider. It is not possible to make any calculation 
regarding aquaculture. However, as tools do not change it is expected than the current problems will remain. 
 
41 Social sustainability : Employment in the catching sector  is predicted to decline by 10%, 
allowing that crew wage per FTE would in crease by negligible 3% in 2017 and 6% in 
2022. Crew wages are expected to remain  below national averages, so that ceteris 
paribus the attractiveness of the sector would rema in constant or continue to decline. 
Employment trends in ancillary services are negative in view of the expected fleet size reductions. Many coastal communities would continue to suffer from the decline in the importance of fisheries, although some might benefit from an incremental improvement 
in the status of some fisheries. In the light  of the experience so far it is likely that the 
current Axis 4 of the EFF would allow creati ng some employment alternatives in coastal 
communities. This impact, however, will be limited by the small overall size of Axis 4 and insufficient budgets allocated to many FLAGs. 
The generalized failure to achieve objectives  allows concluding that maintaining the 
current EFF would not be cost-effective. 
8.2. Option 1 “EFF +” 
To a large extent, impacts of EFF+ are larg ely the same as those of options 1 and 1a 
described and analysed on the CFP reform IA report. Emphasis will be put here on additional positive impacts that could reasonably be attributed to a) the content of the 
EMFF reflecting the strong link to CFP objectives implying concentration on green, smart investment and local development and more synergies with IMP b) better coordination of the different fi nancing tools of the CFP.  
In terms of environmental sustainability , the financial support to the transition towards 
selective gears should speed up the entry into  force and effects of the discard policy. 
Pilot projects show that reductions in the region of 40 to 70% of discards can be 
immediately achieved by introducing selective g ears in beam and demersal trawler fleets, 
at the costs referred to in Section 6 above. 
As regards economic sustainability , section 6 above explains already the gains expected 
from options 1 and 1a) in GVA per employee in fi sheries. It is reasonable to expect that 
the introduction of TFC for industrial fleet s would close the innovation gap for such 
fleets, at the latest towards the end of the period. The increase in GVA per employee for 
the SSCF (+65% for the period 2012-2022) does not  appear to be high enough to ensure 
closing entirely the innovation gap for this fleet segment. However, the support to 
innovation, in particular in processes and pr oducts closer to the market, including in 
marketing and commercialisation activities, should allow reductions in production cost and increases in income that should acceler ate the pace at which the SSCF closes the 
innovation gap. According to rough estimations  reductions of over 20% in productions 
costs and similar increases in income could be achieved. 
Regarding aquaculture, strengthened support to  environmental-friendly aquaculture, to 
the development of new production technique s and to product and market innovation will 
contribute to an increase in GVA and productiv ity. The lack of reliable and complete 
statistics on aquaculture does not enable imp acts to be accurately quantified, however it 
is realistic to consider they would be in the same range as those obtained in fishing, i.e. a 
reduction of 20% of production costs in 2022 and an increase of + 25% in income. 
As regards social sustainability , options 1 and 1a of the CFP reform IA resulted in a 
contraction of the catching employment in th e modelled fleets of close to 24% in the 
period 2012 to 2022 (slightly over 14,000 jobs) plus an additional reduction of 17% 
(1,500 jobs) in ancillary services. Employment in processing was expected to increase by 
4% (1,200 jobs)
66.  
 
42 The increased focus on value added within the equivalent to the current Axis 4 will allow 
creating alternative job opportunities for fisheries communities and developing new activities in areas dependent on fisheries (m ain opportunities are in other sectors of 
maritime economy, tourism, processing and mark eting, ancillary industry). It should also 
support fishermen to access these new sources of employment thus mitigating the negative impact on the social situation in communities dependent on fisheries by promoting diversification and supporting the crea tion of alternative jobs. It is estimated 
that the territorial pillar will create around 12,500 new jobs together with an additional 4,500 jobs in the marketing and processing sector thanks to the marketing measures under the green fisheries pillar. This is expect ed to compensate for most of the losses in 
the catching and ancillary services segments, taking also into account that a part of the 
employment reduction in the fisheries will result from demographic processes. 
Management costs should remain similar to those related to the current EFF 2007-2013, 
although some minor “investment costs” might  not occur again. Indeed the shift in 2007 
towards producing a single OP and strengthe ning the MCS brought new costs, some of 
which were “one off” costs (need to modify the management system and rules, need to 
recruit and train new staff, misunderstandings  and misinterpretation of new rules in 
relation to audit requirements, etc.). Given the current estimated costs and gains due to 
increased experience and potential further simp lification, it could be expected that the 
administrative costs (calculated as the shar e of technical assistance out of the total 
budget) would represent around 3% of future EFF+ budget. This amounts to a small saving over the current EFF (around 3.72% of the EFF budget). 
The reduction might be limited if new actions are launched requiring some new skills 
and adaptations of existing management systems. For example, an increased focus on innovation might lead to the need for a st rong technical assistance and high-level 
expertise within the management structures at MS level (which will have to assist 
beneficiaries in developing relevant projects). 
At EU level, the administrative costs would al so remain at a similar level to the EFF, 
after the 2007 simplification of programming st ructure (27 OPs at the level of the MS 
instead of 60 OPs at the regional level).  
Regarding the co-ordination of CFP and IMP financial instruments some piecemeal 
progress could be achieved due to the fact th at all these instruments enter into force on 
January 1
st, 2014, following the entry into force of  a new basic regulation. In practice 
however, as all these financial instruments w ould be negotiated and adopted separately – 
sometimes as part of the negotiations of a much more important envelope, as in the case of the CMO for fisheries and aquaculture products funded under EAGF, they would have 
a clear tendency to follow their own logic and possible gains of initial co-ordination could hence be watered down.  
The use of the Common Strategic Framework (C SF) and the Partnership contracts (which 
will replace the NSP) will address the lack of strategic approach  and allow for a refocus 
on EU2020 objectives. The CSF will replace th e current approach of establishing 
separate sets of strategic guidelines and define specific objectives and performance 
indicators for the funds covered. The Pa rtnership Contracts will quantify these 
commitments for the MS; Operational Programme s can then be focus on how to translate 
the strategic directions contained in CSF a nd on the quantified commitments made in the 
Partnership Contracts into the concrete fina ncial allocation and use of specific measures. 
Such an approach will bring programming into  the same timeline thus avoiding current 
problem of MS focusing first on the adoption of OP under larger funds, to the detriment 
of EFF Operational Programmes. 
 
43 The CSF and the Partnership contracts are expected to radically enhance the 
coordination between funds . The "demarcation line" currently used to define the scope 
of each fund would be replaced by a strong co -ordination mechanism. The potential for 
such a co-ordination can be demonstrated on two examples.  
Firstly, the future funding should seek to further develop the use of the financial 
engineering. However, for a relatively sma ll amount of funding and taking into account 
the financial mechanisms developed for regional and rural development policy, it does not make much sense to set up new mechan isms for the purposes of fisheries or 
aquaculture. Instead, the existing ones should be used, in particular under the rural development policy where lending to agricultu re and fisheries sector (aquaculture in 
particular) is quite similar.  
Secondly, Local Development strands of the EMFF will be aligned with similar strands 
foreseen within the EAFRD (Leader), the ERDF and the ESF. A common "Community-
based" approach will be defined for the 4 Funds  and the local partnerships will be offered 
the possibility to utilise all th e four funds in a complementary way in the framework of 
an integrated local strategy. When appropriate , a "lead fund" could be established, linked 
to the main policy domain(s) of the progra mme. The lead fund's interventions would be 
complemented through specific priority axes by interventions from the other fund. This would allow the local partners to develop an  integrated strategy for their area where the 
role of each fund would be specified.  Th e EMFF intervention would remain focused on 
fisheries and maritime-related projects, but  in the framework of a larger strategy, 
ensuring a better coordination of the different interventions at local level. 
 
A much stronger focus on results and performance  would be built into programme 
design and implementation. Programmes would c ontain a clear articulation of the change 
sought, on how this would contribute to th e CFP objectives and the EU 2020 goals, and 
how spending the resources on particular inte rventions will contribute to change. It will 
also include critical milestones towards the achievement of objectives. These milestones would be agreed between the Commission and th e Member States in the context of the 
negotiation of the Partnership Contracts and Operational Programmes and provide 
rationale for the use of conditionalities. 
These milestones could be established on the basis of a number of indicators related to 
the CFP objectives and the EU2020 goals. The progress towards milestones should 
provide robust information on delivery. The ex istence of such a performance framework 
within the partnership contract or the OPs c ould form the basis for a number of different 
incentive/sanction mechanisms which should allow for better enforcing conditionalities 
for the use of the fund: 
– It could provide the basis for a peer review process in the context of a political debate. 
– Satisfactory progress could be linked to dis bursement at EU or national level. Where 
progress was unsatisfactory, resources could be held back and, in severe cases, reallocated between priorities or programmes. 
– It could form the basis for the allocation of a possible national or EU reserve. In this 
case, the main objective of the reserve woul d be to ensure that additional available 
resources are not allocated to poorly performing programmes.  
In view of the above, there would be a significant cost-effectiveness. 
 
44 8.3. Option 2: EFF+ “Integration” 
Given that the content of this option is  very similar to that of Option 1, the 
environmental, economic and social imp acts of Option 2 would in principle be 
equivalent. However, the strategic integrati on of the structural and market instruments 
should ensure better synergies, reduce the potential for duplication and trigger additional leverage effects. These effects are not quan tifiable but are not expected to be very 
substantial. It is also possible that thes e positive additional effects could liberate funds 
that could be invested in increasing the financial support with regard to discard 
reduction, accelerating the pace at which the i nnovation gap will be closed as regards the 
SSCF and aquaculture and for territorial de velopment. This will be possible if the 
integration allows for an increased efficiency of the policy as far as delivery is concerned (achieving the same results with less funds). 
Regarding the better co-ordination of CFP and IMP financial instruments some more 
progress could be achieved due to the fact th at all CFP instruments would be grouped in 
one fund adopted and negotiated with MS at the same time. Furthermore, these 
instruments would be covered by the CSF,  which would allow for better exploiting 
synergies with the other EU funds. However, the potential for such a co-ordination would 
be limited, as centrally managed funds would be covered only to a very little extent in the Partnership Contracts. Moreover, the major potential for such a co-ordination concerns 
IMP, which would remain outside the scope of the future fund.  
The merging of the current EFF with other fi nancial instruments in the fisheries sector 
might lead to a slight reduction of ad ministrative costs. Under this option, 
implementation and management modes will remain unchanged. Each instrument will 
continue to be managed separately and under the same budgetary methods of 
implementation: data collection, control a nd CMO measures will still be management 
centrally at EU level (direct management) whilst EFF measures will be managed by MS 
(shared management).  
Assuming that a saving of 3% could be achieved in managing the additional funding 
brought within the EFF after merging, it could be expected that the administrative costs 
(calculated as the share of technical assist ance out of the total budget) would represent 
around 2,91% of the future budget. 
Overall, this Option should bring about high cost-effectiveness. 
8.4. Option 3: EMFF “Convergence” 
The extension of shared management to the non-EFF instruments, adds a significant 
additional potential for policy co-ordination, simplification and reduction of 
administrative burden. In particular, for environmental sustainability , the integration of 
the IMP into the future fund would help to improve management of natural resources, notably through the development of the cross-cutting tools of the IMS and MSP. Better situational awareness in real time would im prove fisheries control and enforcement: by 
providing financial assistance for fisheries c ontrol and enforcement, that allows for 
cross-sectoral data exchange, it would be possi ble to enhance the use of (i) these data for 
other surveillance purposes and (ii) of surveilla nce data from other sectors for the benefit 
of fisheries control and enforcement. Data collection activities should also profit from this integrated approach, simplifying and re ducing administration costs for MS and the 
Commission, while at the same time allowing the latter to easily check implementation of data collection provisions.  
 
45 Moreover, MSP will facilitate the interactions of the fisheries sector with other sectors 
using the same maritime space and enhance the sustainable deployment of activities 
For economic and social sustainability,  the integration of th e CFP funding with the 
IMP might help fisheries communities to increasingly benefit from new opportunities 
generated in other maritime related activities, in particular those related to emerging maritime sectors. In particular fishermen a nd fish farmers are expected to increase 
involvement in data collection, in ecosyst em monitoring or in activities aiming at 
restoring the quality of marine and aquatic e nvironment (such as collecting waste at sea 
and lost fishing gears). Although it is impossi ble to quantify these in quantitative terms, 
closer integration will facilitate funding for a diversification of employment prospects in 
fisheries areas. 
This option allows for supporting the interopera bility of data gathered for the CFP with 
other marine data through the IMP European  Marine Observation and data Network. 
Using the same protocols and standards for fish eries data as for other marine data allows 
them to be processed using the same proce dures. The two types of data can then be 
combined in a way that allows the impact of  fisheries on other activities and vice versa to 
be determined more easily. This integration would reduce the costs of nearly all industries operating offshore and could make other activities such as cabling or pipeline 
tendering more economically viable. 
In terms of simplification, the increased in tegration of the CFP financial instruments 
under shared management is expected to: (a) allow for a reduction of the number of spending procedures and management and control systems and (b) facilitate investments the programming on a multi-annual basis, thus reducing the need for annual programming exercises for both the MS and th e EU. For example, for market measures 
shared management means no need for a nnual decisions of the Commission for each 
market intervention tool.  
In the mid term this new management methods  should lead to a signification reduction in 
administrative costs . Nevertheless this reduction might not  be visible in the short term 
due to potential new “one off costs” nece ssary to implement new management and 
control systems that cover the new scope of  measures. After such an adaptation period, 
the shift from separate management (each  instrument having it own management and 
MCS) towards unified management and pr ocesses should result in a decrease of 
management costs. These benefits can be obtained only if processes are effectively 
harmonised. 
The move to shared management should alleviate the administrative burden for the 
institutes responsible for data collection and scientific advice as financial administration 
for the whole OP will be done by a centralis ed managing authority. The possibility to 
pre-finance part of the total allocated budget for data collection will allow MS to better 
plan and carry out their activities at the star t of the OP because of difficulties to co-
finance the national contribution (in particular in the face of budgetary restrictions). 
Assuming that a saving of 10% could be ach ieved through full integration of all funding 
instruments, it could be expected that the ad ministrative costs (calculated as the share of 
technical assistance out of the total budget) would represent some 2.70% of the budget. 
In terms of monitoring and evaluation , bringing data collection and control under 
shared management would allow for us ing a single monitoring and evaluation 
framework, allowing for a much simpler creation of conditionalities linked to the 
compliance with these two policies. 
In the end the cost-effectiveness of this Option should be very high. 
 
46 9. COMPARING THE OPTIONS : CONTRIBUTION TO THE EUROPE 2020  STRATEGY  
9.1. Comparison of impacts 
The comparison of the three reform op tions (EFF+, EMFF integration and EMFF 
convergence) shows that in all cases positive impacts exceed these of the SQ Option. 
For environmental sustainability , Option 3 could bring additional small to medium 
improvements in terms of scientific advice and data coverage and quality compared to the other two options. One reason for this woul d be the integration between IMP, control 
and DCF databases. Most of the impact however, would come from the strongest 
conditionality covering the ex EFF part, data collection and control.  
In economic sustainability  terms, any option will imply a significant improvement in 
closing the innovation gap in fishing (partic ularly as regards the SSCF) and in the 
aquaculture sector with regard to the SQ Option. However models do not allow isolating 
these impacts from improvements due to th e transition to MSY and the introduction of 
transferable fishing rights. Option 3 could perform better in that respect, as the better integration of CFP into IMP might open up some exchange between fishing and 
technologies used in other maritime fields. 
In social sustainability terms , under all three options a focus on territorial development 
should compensate for al least most of the employment lost in the catching and ancillary services sectors. Option 3 has the highest potential in that respect due to the stronger synergies between different policy strands. Fo r example, in cases of projects conducted 
in a given area by Producers Organizations on the one hand and Fisheries Local Action 
Groups on the other, the integration of fina ncing should give more opportunities for both 
bodies to work together and ensure the cons istency of their marketing strategies and 
generate additional employment sources. The same  effect might be expected with regard 
to the outermost regions, where currently three instruments (CMO, the scheme to 
compensate for the additional costs incurred in  the marketing of certain fishery products 
and EFF) operate independently.  
Yet another example is a closer integration with the IMP under the local development 
pillar. It should better help fishing commun ities located in coastal areas to spot and 
benefit from additional income and/or ne w job opportunities, particularly in other 
maritime related activities. In general terms, integration will bring about better coherence 
with other polices and instruments. 
Finally Option 3 performs significantly better than the two other reform options in terms 
of simplification and reduction of administrative costs and burden . This is due to the 
fact that the implementation method would be radically modified as the data collection, 
control and market measures will be manage d together with EFF measures under shared 
management covering 90% of the expenditure (65% under the two other options). In the 
mid term this approach should significantly  reduce administrative costs and burden due 
to the unified approach in terms of management and control, including reporting, monitoring and evaluation. 
In terms of cost-effectiveness, all reform op tions will be cost-effective, but Option 3 will 
exceed the other two. 
 
47 9.2. Contribution to the Europe 2020 strategy 
In so far as the new financial instrument w ould contribute to achieve the objectives of the 
reformed CFP and a better integration of the IMP and the CFP, it will also contribute to 
achieving the objectives of the Europe 2020 strategy. 
The contribution would mainly focus on three fl agship initiatives: i) a resource efficient 
Europe, ii) an innovation union and iii) the agenda for new skills and jobs. 
Regarding the first initiative, the transiti on to sustainable fisheries (where the 
contribution of the new financial instrume nt will mainly focus in the reduction of 
discards) and aquaculture production, the reducti on of the impact of fisheries (including 
fuel consumption) and aquaculture on the eco systems, the improvement of scientific 
advice and data collection, a more effectiv e control and an increased coordination 
between fishing, aquaculture and other maritime activities would improve resource efficiency. 
Regarding the second initiative, the focus on innovation at all levels of the production, 
marketing and distribution chain in fisher ies and aquaculture, if successful would 
certainly contribute to closing the innovation gap in the EU. The improved availability, coverage and quality of data, resulting both from the focus on scientific advice and 
economic data and from the coordination be tween IMP (marine knowledge, IMS) and the 
CFP would improve the foundations for that. 
Regarding the third initiative,  an increased attractiveness of the fishing sector, together 
with actions in the field of diversification of skills and jobs in coastal areas, helped by 
actions in the IMP field (in particular in th e area of MSP), should help to the agenda for 
new skills and jobs. 
The above description of impacts shows th at three reform options would positively 
contribute to the Europe 2020 strategy. Howe ver, the additional positive impacts of 
Option 3 support the view that the contribu tion of Option 3 would exceed that of the 
other two. 
10. T
HE PREFERRED OPTION  
On this basis Option 3 seems to perform much better than the Status Quo and offer some 
advantages over the other two reform options so that, in the end, it is to be considered the  
preferred option . Although this result is to some exte nt anticipated in the Maritime and 
Fisheries Policy annex to the MFF Communicati on, the analysis carried out in this IAR 
confirms that view. 
Table 8 - Comparison of options 2 
 Level of achievement of target value under each option 
Indicator Status Quo EFF+ EFF+ 
Integration EMFF 
convergence 
Environmental sustainability     
Reduction of discards (%) 0 2 2 2 
Economic     
GVA/employee in the fishing sector 
(index), including aquaculture 0 2 2 3 
 
48 Social     
Number of jobs created in fisheries-
dependent areas (% of compensation / jobs reduction in the catching sector) 0 2 3 3 
Effectiveness and efficiency of delivery     
Reduction of management costs: share of 
Technical assistance (in % of total budget) 0 0 1 2 
Strategic fit, focus on results, simplification 0 2 2 3 
Cost  effectiveness 0 1 2 3 
TOTAL SCORING 0 9 12 16 
Legend 
3 Performance targets met and/ or very significant improvements of the 
situation 
2 Performance targets substantially met and/ or significant improvements of the 
situation 
1 Performance targets not met, but little change in the situation and small 
improvements 
0 Performance targets not met and/or worsening of the situation 
11. MONITORING AND EVALUATION  
As stated in section 2.3.1 above, the weak  monitoring and evaluation system has 
contributed to the lack of focus on resu lts and performance which explains the 
deficiencies of the current public financial support. 
Hence the EMFF should have a strong mon itoring and evaluation system, based on 
common performance indicators allowing assessi ng the extent to which its objectives are 
being achieved. The system would be based on following components: 
- A framework of common indicators:  
o linked to the structure of the policy framework; 
o allowing to assess policy implementation against priorities and targets; 
o leaving the possibility for MS to defi ne their own custom indicators in 
addition to those made compulsory by the Commission. 
- A set of agreed targets between EU and MS: 
o These targets will define the expected results on a specific set of results 
indicators;  
o They will be defined at the level of the EU in the Common Strategic 
Framework; 
o The translation of EU targets at na tional level will be defined in the 
partnership contracts and/or the operational programme. 
 
49 - Annual implementation reports including reporting information on progress made 
towards objectives measured by the indicators. These reports will be used to verify the conditionalities 
- Annual examination of programme implementation by the Commission. 
- Ongoing evaluation 
- Assessment of the quality of the national monitoring systems to be performed to 
assure the reliability of reported data on common indicators. 
- Capacity building, to support implementati on and evaluation of the fisheries and 
maritime policy. 
– Reinforced monitoring and evaluation at the level of Fisheries Local Action 
Groups, in line with the provisions made by the other funds, including a reinforced use of self-evaluation techniques. 
 The result (performance) indicators related to  key EMFF priorities should be included in 
the EMFF Regulation, whilst the output indicator s could be discussed with the MS in 
meetings with a sub-group of the existing EFF Committee before their inclusion in the Implementing Regulation.  
 The following table presents some potential indicators which may provide performance 
framework for the EMFF Regulation. Annual reporting on these indicators will provide 
an indication of the performance of each Op erational Programme and an input to the 
Annual Activity Statement. 
 
 
          
 
50 Table 10 – Monitoring indicators  
  
General 
Objective Specific objective Result indicators Current situation Target  
Achieve 
Environmental 
sustainability     
  Reduce the 
environmental 
impacts of 
fisheries  
Linked to the evolution of 
discards rate. 
Source: National monitoring 
system or Data Collection Framework Unknown, data will be 
available in 2012, with the next data call.  
Info available at the 
level of pilot projects shows that the use of selective gears allow decreasing discards by up to 50%,   
  Reduce 
environmental 
impacts of 
aquaculture  
Linked to the energy 
consumption per ton produced. Seriously limited use, as it does not capture the fact that some environmentally friendly types of aquaculture require increased energy supply. 
Source: National monitoring 
system or Data Collection Framework  
Unknown, data will be 
available in November 2011.  
  Improve scientific 
knowledge  Number of assessed stocks 
divided by total exploited stocks.  
Source: ICES Scientific advice 
exists for 45% of commercial stocks; trend decreasing or stable. As close to 
100% as possible for commercial stocks 
Achieve 
economic 
sustainability     
  Reduce the 
innovation gap in 
fisheries (SSCF)  GVA/FTE in fishing sector 
divided by average GVA/FTE national economy.  
Source: Annual Economic Report 
for EU fleets  
  Reduce the 
innovation gap in 
fisheries 
(industrial fleets)  GVA/FTE in fishing sector 
divided by average GVA/FTE national economy.  
Source: Annual Economic Report 
for EU fishing Fleets  
  Reduce the 
innovation gap in 
aquaculture GVA/FTE in aquaculture sector 
divided by average GVA/FTE national economy.   
Partly incomplete data 
for GVA/FTE in the fishing fleets exist. Data for aquaculture available November 2011. 
 
  Increase energy 
efficiency in 
fishing Fuel consumption in volume 
divided by volume of landings  
Source: Annual Economic Report 
for EU fishing Fleets.  670 litres per one ton 
of fish in 2008. 
  
 
51   Improve market 
organisation Number of POs / Number of 
associated fishermen and aquaculture farmers 
Source: National monitoring 
system.   
Achieve social 
sustainability     
  Promote viability 
of fisheries areas Number of jobs created by local 
partnerships (result indicator) 
Source: National monitoring 
system    
 Improve 
Compliance      
   Improvement of 
data quality   Degree of compliance with data 
calls from secondary users under the DCF as assessed annually by STEFC  100% 
compliance 
   Improve control   Serious infringements divided by 
n° of inspections     
 
 
     
 
     
 
52 LIST OF ANNEXES : 
1. List of meetings with stakeholders 
2. List of studies. 
3. INTERIM EVALUATION OF THE EUROPEAN FISHERIES FUND (2007-2013) 
FINAL REPORT FEBRUARY 2011Interim evaluation of the EFF (2007-2013).  
4. Repartition of the EFF per Axis and MS (2007-2013) 
 
53 LIST OF ACRONYMS  
Acronym Description 
ACFA  Advisory Committee on Fisheries and Aquaculture 
CFP Common Fisheries Policy 
CISE Common Information Sharing Environment 
CMO  Common Market Organisation  
DCF Data Collection Framework 
EAFRD European Agriculture Fund for Rural Development 
EAGF  European Agriculture Guarantee Fund   
EC European Commission 
ECA European Court of Auditors 
EFF European Fisheries Fund 
EMFF European Maritime and Fisheries Fund 
EP  European Parliament 
FAS Fleet Adaptation Schemes 
FEAP Fishing Effort Adjustment Plan 
FIFG Financial instruments for fisheries guidance 
FPA Fisheries Partnership Agreements 
GVA Gross Value Added 
IA  Impact Assessment  
IMP  Integrated Maritime Policy  
IMS Integrated Maritime Surveillance 
ITQ Individual Transferable Quotas  
IUU Illegal, Unreported and Unregulated fishing 
MA Managing Authority 
MC Monitoring Committee 
MCS Management and Control System 
MS Member State 
MSFD Marine Strategy Framework Directive 
MSP  Maritime Spatial Planning  
MSY Maximum Sustainable Yield 
NSP National Strategic Plan 
OP Operational Plan 
PO  Producer Organisations 
POSEI  Programme d'Options Spécifiques à l'Éloignement et l'Insularité 
RAC Regional Advisory Council 
RFMO Regional Fisheries Management Organisation  
TAC Total Allowed Catch 
TFC Transferable Fishing Concession 
TFEU Treaty of the Functioning of the EU 
 
54 ANNEX  1 
MEETING WITH STAKEHOLDERS  
COMBINED IMPACT ASSESSMENT AND EX -ANTE EVALUATION REPORT CONCERNING 
THE COMMISSION 'S PROPOSAL FOR A FUTURE FINANCIAL INSTRUMENT FOR FISHERIES 
AND MARITIME POLICIES (2014-2020) 
Draft 27 June 2011 
 
Conferences organised by the Commission 
• Conference on the future of local developm ent in fisheries dependent areas, April 12-
13, 2011, Brussels. 
• Conference on the CFP Reform 16 November 2010, Brussels. 
• Conference MARE/REGIO on innovation in the fisheries and aquaculture sectors, 19 
October 2010, Vigo. 
• Seminar with  the stakeholders, Member States and other Institutions on EFF and 
future financial Perspectives, 13 April 2010, Brussels 
• Meeting with the stakeholders, Member Stat es and other institutions on future EFF, 
Brussels, 19-20th January 2010. 
• Seminar with European Transport Federation, Split, November 4-5th  2009, on the 
future of the EFF. 
• THE FUTURE OF LOCAL DEVELOPMENT IN FISHERIES AREAS (POST -2013)  - “HOW TO 
IMPROVE THE IMPACT OF EU INTERVENTIONS AT LOCAL LEVEL ”: BRUSSELS , 12-13  
APRIL 2011   
 
Co-organised with the Presidencies 
• Under Spanish Presidency: Conference on the CFP Reform 2/3 May La Coruña, 
Spain (including Individual Transferable Ri ghts as an alternative way of managing 
capacity, replacing scrapping, and support to small scale fleet) 
• Under BE Presidency, meeting of Directors-  General responsible for Fisheries in the 
MS, on EFF implementation (including critical assessment of the implementation, best practices in line with Europe 2020, n eed for synergy with other EU funds and 
discussion on the future funding, 12-14 September, Gent. 
• Under BE Presidency: Improved Fisheries a nd Science Partnerships as Policy Drivers 
9/10 November Ostend. 
 
MS Fisheries Administrations 
• The issue of future financial instrument ha s been discussed in all official meetings 
organised with the MS in the framework of the partnership (Monitoring Committees, Annual Review meetings) and EFF Committee. 
• The future of Axis 4 (Local Developmen t) has been discussed with the Managing 
Authorities in charge of Axis 4 in the meetings organised regularly by the FARNET 
Support Unit. 
 
 
55 Others: 
• Seminar organized by European Transport Federation "Enhancing social dialogue in 
the fisheries sector of new EU member states", Split, Croatia, 4 - 5 November 2009. 
• Informal exchanges and meetings with representatives of environmental NGOs 
(PEW, Seas At Risk, Greenpeace, WWF and Birdlife) 
 
For IMP 
• A public consultation on the development of an IMP approach for the Mediterranean 
was conducted in 2008, whose results we re taken on board in the Commission 
Communication "Towards an Integrated Ma ritime Policy for better governance in the 
Mediterranean" COM (2009)466 of 11.09.2009. Th is work is followed by WG on 
IMP the Mediterranean. 
• The EU strategy for the Baltic Sea region is  based on consultations (109 replies from 
authorities, institutions or individuals), as well as an internet consultation hold 
between  November and  December 2008. 
• A two-month public consultation on Marine Knowledge in 20091 received 300 
replies. 
• Five stakeholder workshops (MS, regi ons, NGOs and industry) on the further 
development of Maritime Spatial Planning at EU level took place in 2009. 
• The Annual Forum on the EU Strategy fo r the Baltic Sea Region was held 14-15 
October 2010, Tallinn 
• Towards an Integrated Maritime Policy at the level of the Mediterranean Coastal 
Regions, 16/17 December 2010, Rome 
• The Annual European Maritime Day Stakehol der Conference took place in Brussels, 
19-20 May 2008 in  Rome, 19 & 20 May 2009 and in Gijon, 18-21 May 2010) 
• DG MARE has established a Technical Advi sory Group consisting of stakeholders 
(representatives of various 'user communities' ) for the development of an Integrated 
Maritime Surveillance. 
 
 
                                                 
1  "Marine Data Infrastructure Outcome of Public Cons ultation", Commission Staff Working Document, 22.1.2010, SEC(2010)73 
final 
 
 
56 ANNEX  2 
LIST OF STUDIES USED IN IA 
COMBINED IMPACT ASSESSMENT AND EX -ANTE EVALUATION REPORT CONCERNING 
THE COMMISSION 'S PROPOSAL FOR A FUTURE FINANCIAL INSTRUMENT FOR FISHERIES 
AND MARITIME POLICIES (2014-2020) 
o Report from the Commission - Second A nnual Report on Implementation of the 
European Fisheries Fund (2008), 21.12.2009, COM (2009) 696 final  
o Report from the Commission - Third Annual  Report on Implementation of the European 
Fisheries Fund (2009), 07.02.2011, COM (2011) 0037 final  
o Studies undertaken for the Impact Assessment  of CFP reform including four regional 
studies.  
o Regional social and economic impacts of  change in fisheries-dependent communities, 
main report and 24 case studies. Study published 15/03/2011  on the Fisheries web site: http://ec.europa.eu/fisheries/documentation/ studies/regional_social_economic_impacts
/index_en.htm  
o Interim evaluation of the European Fisheries Fund (2007-2013), Final report,  
Published in February 2011 on the Fisheries web site: http://ec.europa.eu/fisheries/documentati on/studies/eff_interim_evaluation_en.pdf 
o Report from the Commission to the Council and European parliament on the 
implementation of Council regulation on t he Common Organisation of the Markets in 
fishery and aquaculture products 
o Interim evaluation on establishing EU financia l measures for the implementation of the 
CFP and in the area of the Law of the sea 2007-2013 – August 2010 
o Impact Assessment Studies rela ted to the CFP available at 
http://ec.europa.eu/fisheries/reform /impact_assessments_en.htm-  
o Synthesis of the Consultation on the Refo rm of the Common Fisheries Policy – April 
2010 
o Ex-Post evaluation of FIFG (2000-2006)- March 2010 
o A Diagnosis of the EU fisheries sector, Commission Staff Working Document – April 
2009  
o Impact Assessment for an Integrated Maritime Policy for the European Union, 
SEC(2007) 1279, 10.10.2007. 
o Progress report on the EU's integrat ed maritime policy, COM(2009)540 final, 
15.10.2009. 
o Ex-Ante Evaluation for establishing a Programme to support further development 
towards an Integrated Maritime Policy, SEC(2010) 1097 final of 29.09.2010. 
o Impact Assessment for a European Marine Observation and Data Network SEC(2010) 
998 final, 8.9.2010. 
o Report on Integrated Maritime Policy - Evaluation of progress made and new 
challenges (2010/2040(INI)), European Pa rliament, Committee on Transport and 
Tourism, 21.10.2010 
o Evaluation of the Common Organisation of the Markets in Fishery and Aquaculture 
Products, December 2008 
o Monitoring and Evaluation system. By  Ernst & Young. Draft June 2011.  
 
57 ANNEX  3 
INTERIM EVALUATION OF THE EUROPEAN FISHERIES FUND (2007-2013)  
FINAL REPORT  
FEBRUARY 2011  
 
Not included. Available at: http://ec.europa.eu/fisheries/documentation/studies/eff_interim_evaluation_en.pdf  
  
 
58 ANNEX 4  
EFF BROKEN-DOWN BY PRIORITY AXIS AND BY MEMBER STATE 
PUBLIC AMOUNTS PROGRAMMED IN TH E LAST DECISION INTO FORCE  
 
 
 
For ease of reference, please refer to the legend below:   
Priority axis 1:  measures for the adaptation of the Community fishing fleet  
Priority axis 2:  aquaculture, inland fishing, proce ssing and marketing of fishery and 
aquaculture products   
Priority axis 3:  measures of common interest   
Priority axis 4:  sustainable development of fisheries areas   
Priority axis 5:  technical assistance  
 
 
59 ENDNOTES  
                                                 
1 The expressions "future fund", "Future funding instrument" or "EMFF" are used in the pres ent IA. They have to be 
considered as synonymous.  
2 COM(2010) 494 final of 29 September 2010, Proposal for a regulation of the European Parliament and of the 
Council establishing a Programme to support the furthe r development of an Integrated Maritime Policy. 
3 COUNCIL REGULATION (EC) No 861/2006 of 22 May 2006 es tablishing Community fina ncial measures for the 
implementation of the common fisheries policy and in the are of the Law of the Sea 
4 COM(2011) 500 final, 29 June 2011. 
5 SEC(2011) 891  - Impact assessment concerning the Commission' s proposal for the 2012 reform of the Common 
Fisheries Policy and SEC(2011) 892  - Summary of the Impact assessment, both published 13 July 2011. 
6 Impact assessment accompanying the document Regulation of the European Parliament and of the Council on the 
Common Organisation of the Markets in Fi shery and Aquaculture Products SEC(2011)883. 
7 SEC (2007) 1279, of 10.10.2007.  8Commission Progress Report on the EU's Integrated Maritime Policy – COM (2009) 540 final of 15.10.2009.  
9 COM(2011) 500 final of 29 June 2011on A Budget For Europe  2020 - Part II - Policy Fiches , pp. 80-82; SEC(2011) 
868 final chapter 10: Fisheries and Maritime Affairs.  
10 22/9/2010, 13/12/2010, 17/1/ 2011, 11/2/2011 and 30/6/2011 
11 COM(2009)163 final, Brussels, 22.4.2009. Green Pa per Reform of the Common Fisheries Policy 
12 "Marine Data Infrastructure Outcome of Public C onsultation", Commission Staff Working Document, 22.1.2010, 
SEC(2010)73 final. 
13 http://ec.europa.eu/fisheries/reform/sec(2010)0428_en.pdf. 
14 COM(2007) 574 final of 10.10.2007. 
15 Ares(2011)971305 of 13 September 2011. 
16 SEC(2011) 891. 
17 'Safe biological limits' are defined by a minimum safe st ock size and a maximum exploitation rate. These are known 
as reference points. The stock size is measured in terms of  'spawning stock biomass (SSB)' which represents the total 
weight of spawning fish each year. The exploitation rate is ca lled the 'fishing mortality (F)' which measures the rate at 
which fish are removed from the stock by fishing. If the st ock is either below the mini mum safe SSB or above the 
maximum safe F, the stock is said to be outside safe biological limits.  
18 Council Regulation (EC) n° 1198/2006 of 27 July 2006 on the European Fisheries Fund. OJ L223/1 of 15.8.2006. 
Article 4.  
19 SEC(2011) 891. Section 2.4 . 
20 Ex-Post evaluation of FIFG (2000-2006)- March 2010. 
21 Interim evaluation of the European Fisher ies Fund (2007-2013), Final report, February 2011. 
22 A list of potential result and impact indicators was sugge sted in a working paper “Indicators for monitoring and 
evaluation: a practical guide for the EFF”. However, th ese indicators were not used by all MS, whereas their 
characteristics were not sufficiently detailed to ensure co mmon use and interpretation within the national monitoring 
systems (some indicators being focused either on assessing trends or on measur ing absolute figures, which makes it 
difficult to aggregate or consolidate th e data provided) (see list in annex). 
 
60                                                                                                                                                  
23 An ECA report on overcapacity is in preparation, ra ising the question of the way this condition was made 
operational in the MS. Its publicati on is expected for October 2011. 
24 Proposal for a REGULATION OF THE EUROPEAN PA RLIAMENT AND OF THE COUNCIL on the common 
organisation of the markets in fishery and a quaculture products. COM(2011)416 final of 13 July 2011.  
25 SEC(2011) 891 . Section 2.1.1. 
26 Overcapacity is a biological and economic  problem. It means that too many ve ssels catch existing fishing resources, 
but also that there are too many vessels for the available fishing rights. 
27 The existence of a possible scrapping premium is factored  in the investment decisions  made by vessels owners. 
They might decide to build a new vessel even if its cost can  not be covered by the income generated only by fishing.  
28 ECA SPECIAL REPORT No 7/2007 on the control, insp ection and sanction systems relating to the rules on 
conservation of Community fisheries resources. 
29 See for example: http://www.euraquaculture.info/files/consensus_brochure_web.pdf   mentions the positive impacts 
of pond fish farming.  
30 Dhepherd J.: Linkage between farmed and wild  fish. http://www.oecd.org/dataoecd/20/62/45035118.pdf.  
31 Several research projects have been financed under FP5 – FP7 such as RAFOA, PEPPA, AQUAMAX, PUFAFEED.  
32 Birdlife International, BirdLife Europe:  Support for e nvironmental friendly aquaculture practices from European 
Fisheries Fund (April 2011).  
33  SEC(2011) 891  Section 2.1.5. 
34 COM(2010)241 final of 17 May 2010, In addition, for a further 42 stocks no scientific advi ce was available. As for 
the Mediterranean, there are some data for 16 species out of 102. These 16 species correspond to 60 stocks. The status 
of 18 out of these 60 was unknown in 2010 due to poor data.  
35 SEC(2010) 998 final COMMISSION STA FF WORKING DOCUMENT European Ma rine Observation and Data 
Network IMPACT ASSESSMENT. 
36 COM(2010)461. 
37 Directive 2008/56/EC of the European Parliament and of  the Council of 17 June 2008 establishing a framework for 
community action in the field of marine environmen tal policy (Marine Strategy Framework Directive) 
38 For an estimation of the gap, see Section 6 below.  
39 SEC(2011) 891.   
40 See Section 6.2 below for an estimation of the innovation gap.  
41 Investments not related to innovation and environment (i.e. port facilities, extension of production facilities in 
aquaculture, processing industry).  
42 The FARNET Support Unit has gathered information on G ood Practice projects which are presented on their web 
site, see https://webgate.ec. europa.eu/fpfis/cms/farne t/content/project-examples. 
43 Regarding aquaculture, its fuel consump tion is very small. However, as stated  above some forms of aquaculture (e.g. 
recirculation systems) are quite electricity consumption in tensive. The development of these production methods could 
increase the amount of electric ity consume but not to leve ls considered problematic. 
44 See in particular "Regional social and ec onomic impacts of change in fisheries-de pendent communities". Study published by DG MA RE 15/03/2011. 
http://ec.europa.eu/fisheries/doc umentation/studies/regional_soci al_economic_impacts/index_en.htm. 
45 The modelled fleets represent 80% of the global EU gross value added (GVA) of the catching sector and 70+% of 
employment.  
 
61                                                                                                                                                  
46 2003 figures (EU-25), sum of full time and part time em ployment, not Full Time E quivalent posts; (female 
involvement in catching sector: 4%; aquaculture: 31%; pro cessing: > 55%). source: Salz, P., Employment in the 
fisheries sector, current situation, study  commissioned by DG MARE, FISH/2004/4, 2006.  
47 In cases where the actions envisaged fall under more than one  Article of the Treaty, it is constant jurisprudence of 
the Court of Justice: (a) to opt for one single Article choos ing that which reflects the ma in or preponderant objective, 
purpose or component of the envisaged measures. See Ca se C-178/03 (att 42) Commission vs EP and Council; Case C-
36/98 Spain v Council [2001] ECR I-779, paragraph 59;  Case C-211/01 Commission v Council [2003] ECR I8913, 
paragraph 39; and Case C- 338/01 Commission v Council [2004] ECR I4829, paragraph 55 or (b) exceptionally to 
accept that two or more Articles are used as legal basis (m ultiple bases) under the condition that the objectives pursued 
are intrinsically linked without one being secondary and indirect in relation to the others. See C-211/01 (att 40) 
Commission v Council Case C-336/00 Huber [2002] ECR I-7699, paragraph 31;  Case C-281/01 Commission v 
Council [2002] ECR I-2049, paragraph 35, and Op inion 2/00 [2001] ECR 1-9713, paragraph 23). 
48http://www.europarl.europa.eu/si des/getDoc.do?type=TA&langua ge=EN&reference=P7-TA-2010-0243 . 
49 See Section 9.2 below.  
50 SEC(2011) 891. Sections 5.4 and 7.3.  
51 COM(2011)425 final of 13 July 2011.  
52 See Section 6 below.  
53 Council Conclusions of 16 Novemb er 2009, 14 June 2010 and 23 May 2011. 
54 Report on Integrated Maritime Policy - Evaluation of progress made and ne w challenges (2010/2040(INI)), 
European Parliament, 21.10.2010 
55 SEC(2011) 891. Sections 5.4 and 7.1. 
56 SEC(2011) 891. Sections 5.4 and 7.2.  
57 See Impact Assessment of discard reducing policies, available at 
http://ec.europa.eu/fisheries/documen tation/studies/discards/index_en.htm.  
58 The projects related to Natura2000 are usually costly. For example, environmental studies necessary to select 
optimal location of cages and minimi zation of impact with Natura2000 sites cost ca €20,000 per year and plant.  
59 Case study of agri-environmental payments: the United Kingdom. T.L. Dobbs, J. Pretty, available at 
www.sciencedirect.com. 
60 The results regarding Belgium are probably related to the very small active fleet and fishermen.  
61 This calculation can be further improved with the availability , for the first time, of aqu aculture data. The first EU-
wide report is scheduled for the publication in the autumn 2011.  
62 Price Waterhouse Cooper, INFOMAR Marine Mappi ng Survey Options Appraisal Report June 2008. 
63 European Marine Observation and Data Network Impact Assessment, SEC( 2010) 998 final of 8.9.2010. 
64 Further analysis of the corresponding savings will be pr ovided within the framework of the Impact Assessment 
exercise which is currently being launc hed. Nevertheless, a considerable savi ngs have been proved in studies at 
national level, in particular reduced human resources needs.  
65 Study on the economic effects of Maritime Spatial Planni ng,, Policy Research Corporation on behalf of DG MARE, 
2011.  http://ec.europa.eu/maritimeaffairs/study_msp_en.html. 
66 Calculations in the CFP reform IA regardi ng processing and ancillary services 15 EU MS.