SEC(2007) 470

COMMISSION STAFF WORKING DOCUMENT

SCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF)Analysis of derogations and non-conformitiesof Member States’ data collection National ProgrammeProposals for 2006Brussels, December 2005

The Scientific, Technical and Economic Committee for Fisheries (STECF) evaluated

and endorsed this report by correspondence in January 2006

This report does not necessarily reflect the view of the European Commission and in no way anticipates the Commission’s future policy in this area

.

TABLE OF CONTENTS

1. Introduction. 3

2. STECF comments 3

3. STECF Conclusions and Recommendations 3

4. Annex I: SGRN Report 5

1 Introduction

The STECF-SGRN met in Brussels from November 28th till December 2nd, 2005, to:

(a) Evaluate the derogations and non-conformities in the MS' NP Proposals for 2006, based on the Report by the External Evaluators.

(b) Discuss the Stockholm Workshop results on Eel Data Collection and provide advice on eel sampling for 2006, taking into consideration the Commission Proposal of a Regulation for Management Plans on Eels (COM 472 of 6.10.2005). The group is requested, in particular, to assess whether the current obligations under the data collection programme are suitable to measure the silver eel escapement rate for each river basin (escapement target of 40%) and, if otherwise, what changes are needed to the sampling protocol.

(c) Set up of Guidelines and templates for the submission of National Programmes for 2007.

The Report of the SGRN evaluation of MS' NP Proposals for 2006 and on the other TOR is given in Annex I.

2 STECF Comments

STECF reviewed the SGRN report on Analysis of derogations and non-conformities

of Member States’ data collection National Programme Proposals for 2006. The report is extensive and detailed and contains numerous suggestions and recommendations in response to comments from the independent Evaluators and on observations by the SGRN Sub-group participants.

The report is structured in two main parts:

A section with general comments that apply to all or to particular Modules of the DCR.

Separate sections by MS (Sections 2.3-2.22), from Belgium to the UK. Each of these has sub-sections by Module of the DCR, with SGRN's comments on the queries raised by the Evaluators.

There are further sections dealing with the additional Terms of Reference.

3 STECF Conclusions and Recommendations

STECF agrees with and endorses the observations, comments and recommendations contained in the SGRN report on Analysis of derogations and non-conformities

of Member States’ data collection National Programme Proposals for 2006.

To reproduce all of the suggestions and recommendations here would largely imply repeating much of the associated text in order to put each into context. Therefore the SGRN report should be considered in its entirety and accepted as the definitive statement from the STECF on the National Programme Proposals for 2006.

STECF would like to take the opportunity to express its sincere gratitude to the retiring Chairman of the SGRN Sub-group, Mr Frank Redant who has expertly guided the work of the SGRN since 2003. The work of the Sub-group over this period has been extensive, having dealt with 52 NP Proposals, 39 Technical Reports on National Programmes and 19 Technical Reports on Pilot Studies. Some of the issues that SGRN has had to deal with have been particularly difficult.

The data collection regulation is currently under review and the successor to Mr Redant as Chair of the SGRN Sub-group will have an equally demanding and difficult task. SGRN has proposed that Mr Joël Vigneau be appointed as Mr Redant’s successor and STECF fully supports this proposal. STECF therefore recommends that the Commission formally approach Mr Vigneau to confirm his willingness to accept the Chairmanship of the SGRN Sub-group.

Annex I

COMMISSION STAFF WORKING PAPER

SCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF)

SUB-GROUP ON RESEARCH NEEDS (SGRN)

Analysis of derogations and non-conformities

of Member States’ data collection National Programme

Proposals for 2006

Brussels, 28 November - 2 December 2005

TABLE OF CONTENTS

1 Introduction 9

1.1 List of participants 9

1.2 Terms of Reference 9

2 Evaluation of derogations and non-conformities 9

2.1 Evaluation process and structure of the report 9

2.2 General comments 9

2.2.1 Comments not linked to particular Modules of the DCR 9

2.2.2 Module D 9

2.2.3 Module E 9

2.2.4 Module F 9

2.2.5 Module G 9

2.2.6 Modules H and I 9

2.2.7 Modules E, H and I 9

2.2.8 Module J 9

2.2.9 Module K 9

2.3 Belgium 9

2.3.1 Module C 9

2.3.2 Module D 9

2.3.3 Module E 9

2.3.4 Module F 9

2.3.5 Module G 9

2.3.6 Modules H & I 9

2.3.7 Module J 9

2.3.8 Module K 9

2.4 Cyprus 9

2.4.1 Module C 9

2.4.2 Module D 9

2.4.3 Module E 9

2.4.4 Module F 9

2.4.5 Module G 9

2.4.6 Modules H & I 9

2.4.7 Module J 9

2.4.8 Module K 9

2.5 Denmark 9

2.5.1 Module C 9

2.5.2 Module D 9

2.5.3 Module E 9

2.5.4 Module F 9

2.5.5 Module G 9

2.5.6 Modules H & I 9

2.5.7 Module J 9

2.5.8 Module K 9

2.6 Estonia 9

2.6.1 Module C 9

2.6.2 Module D 9

2.6.3 Module E 9

2.6.4 Module F 9

2.6.5 Module G 9

2.6.6 Modules H & I 9

2.6.7 Module J 9

2.6.8 Module K 9

2.7 Finland 9

2.7.1 Module C 9

2.7.2 Module D 9

2.7.3 Module E 9

2.7.4 Module F 9

2.7.5 Module G 9

2.7.6 Modules H & I 9

2.7.7 Module J 9

2.7.8 Module K 9

2.8 France 9

2.8.1 Module C 9

2.8.2 Module D 9

2.8.3 Module E 9

2.8.4 Module F 9

2.8.5 Module G 9

2.8.6 Modules H & I 9

2.8.7 Module J 9

2.8.8 Module K 9

2.9 Germany 9

2.9.1 Module C 9

2.9.2 Module D 9

2.9.3 Module E 9

2.9.4 Module F 9

2.9.5 Module G 9

2.9.6 Module H & I 9

2.9.7 Module J 9

2.9.8 Module K 9

2.10 Greece 9

2.10.1 Module C 9

2.10.2 Module D 9

2.10.3 Module E 9

2.10.4 Module F 9

2.10.5 Module G 9

2.10.6 Modules H & I 9

2.10.7 Module I 9

2.10.8 Module J 9

2.10.9 Module K 9

2.11 Ireland 9

2.11.1 Module C 9

2.11.2 Module D 9

2.11.3 Module E 9

2.11.4 Module F 9

2.11.5 Module G 9

2.11.6 Modules H & I 9

2.11.7 Module J 9

2.11.8 Module K 9

2.12 Italy 9

2.12.1 Module C 9

2.12.2 Module D 9

2.12.3 Module E 9

2.12.4 Module F 9

2.12.5 Module G 9

2.12.6 Modules H & I 9

2.12.7 Module J 9

2.12.8 Module K 9

2.13 Latvia 9

2.13.1 Module C 9

2.13.2 Module D 9

2.13.3 Module E 9

2.13.4 Module F 9

2.13.5 Module G 9

2.13.6 Modules H & I 9

2.13.7 Module J 9

2.13.8 Module K 9

2.14 Lithuania 9

2.14.1 Module C 9

2.14.2 Module D 9

2.14.3 Module E 9

2.14.4 Module F 9

2.14.5 Module G 9

2.14.6 Modules H & I 9

2.14.7 Module J 9

2.14.8 Module K 9

2.15 Malta 9

2.15.1 Module C 9

2.15.2 Module D 9

2.15.3 Module E 9

2.15.4 Module F 9

2.15.5 Module G 9

2.15.6 Modules H & I 9

2.15.7 Module J 9

2.15.8 Module K 9

2.16 Netherlands 9

2.16.1 Module C 9

2.16.2 Module D 9

2.16.3 Module E 9

2.16.4 Module F 9

2.16.5 Module G 9

2.16.6 Modules H & I 9

2.16.7 Module J 9

2.16.8 Module K 9

2.17 Poland 9

2.17.1 Module C 9

2.17.2 Module D 9

2.17.3 Module E 9

2.17.4 Module F 9

2.17.5 Module G 9

2.17.6 Modules H & I 9

2.17.7 Module J 9

2.17.8 Module K 9

2.18 Portugal 9

2.18.1 Module C 9

2.18.2 Module D 9

2.18.3 Module E 9

2.18.4 Module F 9

2.18.5 Module G 9

2.18.6 Modules H & I 9

2.18.7 Module J 9

2.18.8 Module K 9

2.19 Slovenia 9

2.19.1 Module C 9

2.19.2 Module D 9

2.19.3 Module E 9

2.19.4 Module F 9

2.19.5 Module G 9

2.19.6 Modules H & I 9

2.19.7 Module J 9

2.19.8 Module K 9

2.20 Spain 9

2.20.1 Module C 9

2.20.2 Module D 9

2.20.3 Module E 9

2.20.4 Module F 9

2.20.5 Module G 9

2.20.6 Modules H & I 9

2.20.7 Module J 9

2.20.8 Module K 9

2.21 Sweden 9

2.21.1 Module C 9

2.21.2 Module D 9

2.21.3 Module E 9

2.21.4 Module F 9

2.21.5 Module G 9

2.21.6 Module H & I 9

2.21.7 Module J 9

2.21.8 Module K 9

2.22 United Kingdom 9

2.22.1 Module C 9

2.22.2 Module D 9

2.22.3 Module E 9

2.22.4 Module F 9

2.22.5 Module G 9

2.22.6 Modules H & I 9

2.22.7 Module J 9

2.22.8 Module K 9

3 Data and sampling requirements for European eel 9

4 Guidelines for National Programme Proposals 9

5 Revised version of the Guidelines for the Technical Reports 9

6 Appointment of a new chair for SGRN 9

Introduction

List of participants

STECF members

Max Cardinale (chair of eel sub-group)

Peter Ernst

Invited experts

Enrico Arneri

Claude Belpaire (part-time)

Liam Costello (part-time)

Willem Dekker (part-time)

Ole Folmer

Rob Grift

Ryszard Grzebielec

Jordi Guillen

Aaron Hatcher (chair of economists sub-group)

Myrto Ioannou

Ernesto Jardim (part-time)

Rainer Klepper

Manos Koutrakis

Paloma Martin

Helen McCormick

Richard Millner

Arina Motova

Andrew Newton

Mike Pawson (part-time)

Wojciech Pelczarski (part-time)

Maris Plikshs

Jukka Pönni

Iñaki Quincoces Abad

Frank Redant (chair)

Evelina Sabatella

Jochen Trautner (part-time)

Joël Vigneau

European Commission

Olle Hagström, DGFish (part-time)

Philippe Moguedet, DGFish (part-time)

Juan-Pablo Pertierra, DGFish (part-time)

Iain Shepherd, JRC (part-time)

Robert Ziegler, JRC

Terms of Reference

The STECF Sub-Group on Research Needs and Data Collection, hereafter named SGRN, met in Brussels from 28 November to 2 December 2005, to:

(a) Evaluate the derogations and non-conformities in the MS' NP Proposals for 2006, based on the Report by the External Evaluators.

(b) Discuss the Stockholm Workshop results on Eel Data Collection and provide advice on eel sampling for 2006, taking into consideration the Commission Proposal of a Regulation for Management Plans on Eels (COM 472 of 6.10.2005). The group is requested, in particular, to assess whether the current obligations under the data collection programme are suitable to measure the silver eel escapement rate for each river basin (escapement target of 40%) and, if otherwise, what changes are needed to the sampling protocol.

(c) Set up of Guidelines and templates for the submission of National Programmes for 2007.

ToR (a) is dealt with in Chapter 2 of the present Report, ToR (b) in Chapter 3, and ToR (c) in Chapter 4.

In addition, SGRN discussed:

(d) The revised version of the Guidelines for the 2005 Technical Reports (version 2005 of the Guidelines).

(e) The appointment of a new chair for SGRN.

These issues are covered in Chapters 5 and 6 of the Report.

Evaluation of derogations and non-conformities

Evaluation process and structure of the report

- Evaluation process

As in the previous years, SGRN used the External Evaluators' Report as a starting point in its evaluation of the NP Proposals. Besides replying to the queries raised by the Evaluators, SGRN also discussed a number of issues of general interest.

Unfortunately, there were no experts from Estonia, Malta and Slovenia at the December 2005 meeting of SGRN. In their absence, SGRN tried to reply to the Evaluator's comments on the Estonian, Maltese and Slovenian NP Proposals to the best of its abilities. However, a reply was not always possible, amongst others because SGRN did not have all the essential technical information to judge on the validity of the Evaluators' comments. For the future, SGRN insists that all MS send experts to the meetings of SGRN .

- Structure of SGRN's report on Derogations and Non-conformities

SGRN's report on the evaluation of derogations and non-conformities comprises two main parts:

- A section (2.2) with general comments that apply to all or to particular Modules of the DCR.

- Sections by MS (Sections 2.3-2.22), from Belgium to the UK. Each of these has sub-sections by Module of the DCR, with SGRN's comments on the queries raised by the Evaluators.

General comments

Comments not linked to particular Modules of the DCR

- On the Preparation and the logistics of SGRN meetings

SGRN was not pleased with the preparation of its December 2005 meeting, nor with the logistics during the meeting itself: participants were notified of their expected attendance only a week or so before the meeting (which caused problems with bookings of flights and hotels), the meeting room was much too small to accommodate the plenary sessions, there was no access to the internet in the meeting room, etc.

For the future, SGRN insists that participants to the meeting are informed at least one month in advance of their expected attendance, and that meeting facilities are up to modern, 21st century standards.

SGRN also insists that the chair's introductory notes and any draft documents to its meetings are no longer posted on the open access pages of the STECF website, but on limited access pages, with access restricted to the meeting participants.

- On the Adjustment of NP Proposals to RCM recommendations

The Regional Co-ordination Meetings (RCMs) were established to improve the overall quality of the data collected in support of the CFP, through task and cost sharing, data pooling and, in general, all bilateral, regional and pan-European initiatives that can help increasing the accuracy, effectiveness and cost efficiency of data collection. As such, the RCMs are an integral part of the DCR-machinery, and it is in the MS' general interest to duly consider the RCM's recommendations and to closely follow up their initiatives and concerted actions.

Usually, the RCMs meet in autumn, i.e. well after the submission of the NP Proposals by MS in May of the same year. During the RCMs, however, recommendations and agreements are often made that impact on the execution of the NPs in the year to come. For example, in 2005, several RCMs have suggested adjustments to the discard sampling programmes for 2006, but since the MS already have submitted their NP Proposals long before that, these adjustments are not taken into account in their NP Proposals. So far, there is no mechanism that enables MS to retroactively incorporate the adjustments suggested by the RCMs in their NP Proposals.

In an attempt to resolve this problem, and to establish the necessary level of flexibility to enable MS to take into account the RCM recommendations, SGRN suggests the following:

- In case the adjustments suggested by the RCMs have no implications on the cost of the NPs , MS should be allowed to adjust their NPs to the RCM recommendations without having to re-write their NP Proposal or re-submit their Budget Proposal. In their Technical Report, MS should then give all the necessary information on the adjustments made, with reference to the relevant RCM recommendations.

- In case the adjustments suggested by the RCMs do have implications on the cost of the NPs , the changes (and their financial implications) should be discussed and agreed during the bilateral negotiations between the Commission and the MS. If needed, the agreed adjustments could be laid down in an annex to the NP Proposal.

Several RCMs also have suggested extra workshops in the year to come, on issues that require priority attention. Since these workshops do serve the general purpose of the DCR, it seems logical that they would be eligible under the DCR, just like the workshops, study and planning group meetings which are on the list of eligible meetings that is put together each year by the Commission. Again, there is need for flexibility, and SGRN recommends that the final list of eligible meetings be put together after the Liaison Meeting between the Commission, the chairs of the RCMs and the chair of SGRN in January-February. In SGRN's opinion, this is sufficiently early in the negotiation process between the Commission and the MS to enable all parties to adjust the Budget Proposals to the updated list of eligible meetings.

Module D

- On Fishing effort for passive gears

SGRN notes that in the Kavala meeting on Small Scale Fisheries, it was agreed that the effort unit requirements for passive gears appearing in Appendix IX (EP) of the DCR should be upgraded to the mandatory MP, and recommends that MS take this into account already in their 2006 NPs.

Module E

- On Reporting of landings abroad

The Evaluators commented that several MS did not provide text on the landings of fish either in other MS or in countries outside the EU. SGRN reminds MS of the following articles in Council Regulation (EC) 2847/1993:

Article 9.1

Auction centres or other bodies or persons authorised by Member States, which are responsible for the first marketing of fishery products landed in a Member State shall submit, upon the first sale, a sales note to the competent authorities of the Member State in whose territory the first marketing takes place.

Article 11.1

Without prejudice to Articles 7, 8 and 9, the master of a Community fishing vessel who:

- tranships to another vessel, hereinafter referred to as "the receiving vessel", any quantities of catches of a stock or a group of stocks subject to a TAC or quota irrespective of the place of transhipment, or

- directly lands such quantities outside Community territory,

shall at the time of the transhipment or of the landing, inform the Member State whose flag is flying, or in which his vessel is registered, of the species and quantities involved and of the date of transhipment or of landing and of the location of catches by reference to the smallest zone for which a TAC or quota has been fixed.

Article 15.1

Before the 15th of each month, each Member State shall notify the Commission by computer transmission of the quantities of each stock or group of stocks subject to TACs or quotas.

Article 15.2

The Commission shall keep available to Member States on computer the notifications received pursuant to this Article.

SGRN regards these articles as fully covering the requirement to report landings abroad and expects that MS comply to this requirement, regardless as to whether this is explicitly mentioned in their NP Proposals or not.

Module F

- On the Upgrade of Priority 2 surveys to Priority 1 status

Several MS have applied for an upgrade of one or more of their Priority 2 surveys to Priority 1 status, based on the argument that the surveys are targeting species which are likely to be subjected to a Commission Recovery Plan in 2006.

SGRN wishes to remind MS of para. 1 of EC Regulation 1581/2004 (the revised version of the DCR), which says that " With regard to the data collection of stocks subject to a recovery plan pursuant to a Council Regulation, sampling requirements for the extended programme shall become mandatory under the minimum programme for the year following the Regulation’s adoption and during the applicable period of the recovery plan. The same shall apply to surveys where the main objective stock is subject to a recovery plan ."

SGRN recognizes that there might be good scientific reasons for upgrading the status of a survey proactively , i.e. before a Recovery Plan has actually been installed. SGRN is unclear however, on what should be considered as "proactive". Would "proactive" be restricted to the year in which the Recovery Plan is installed (i.e. one year earlier than under the current provisions of the DCR) or would an even further extension of the principle be equally acceptable? In order to avoid endless discussions on the issue, SGRN has decided to advise against all requests by MS to upgrade Priority 2 surveys to Priority 1 status any earlier than foreseen by the DCR.

Module G

- On the MEDITS survey

The objective of the MEDITS survey is to provide abundance indices for a number of key demersal species, for the whole surveyed area. To that aim, surveys across the Mediterranean are to be conducted as far as possible simultaneously , within the second quarter of the year (Appendix XIV of the DCR). SGRN was concerned that the timing of the surveys by a number of MS is extending beyond the period specified by the DCR. Therefore, SGRN recommends that the MEDITS Steering Committee takes the necessary steps to ensure that (a) the surveys are conducted within the most appropriate period of the year, and (b) any further shifts in time are avoided, so as to guarantee the continuity of the time series.

- On Tuna tagging

In June 2005, SGRN extensively discussed the Report of the Planning Group on Tuna Tagging (Report of the First Meeting of the Planning Group on Tuna Tagging in the East Atlantic and Mediterranean Sea, Bari, April 2005), and as it was not satisfied with the answers obtained, it requested a new document (see Chapter 4 of the June 2005 Report of SGRN).

SGRN is aware that MS' NP Proposals for 2006 were sent to the Commission before the June 2005 meeting of SGRN, but sees no reasons why, through negotiation between the Commission and MS, amended versions of the NP Proposals should not be produced that take into account SGRN's concerns.

Modules H and I

- On the Reference period for average landings for the Mediterranean

The RCM for the Mediterranean (September 2004, Madrid) agreed " to complete a table where the list of species included in the amendment of Regulation (1639/2001) will be reviewed by each MS, taking into consideration the average Mediterranean production in the period 2000-2002 or when possible in 2001-2003. This will be used to make comments on the possibility to sample according to the rules mentioned in the Regulation ." Moreover, the RCM " recommended the establishment of an EU website for data collection issues ."

The agreed procedure however, proved impractical and was not implemented by the Mediterranean MS. SGRN recommends the creation of a web page hosted and managed by JRC, as an exchange forum for the above mentioned landings data. Moreover, JRC could, as a standard procedure, request the necessary data from each Mediterranean MS to update the web page each year, before the NP Proposals are to be submitted.

- On the Interpretation of biological sampling requirements

2006 is the first year when NP Proposals should reflect the amended version of the DCR (EC Regulation 1581/2004). In the new version of the DCR, it is stipulated that MS must apply a sampling strategy targeting the precision levels specified in para. 3,a,i,b for the biological sampling (length and age) of their catches. The sampling intensities defined in Appendix XV of the revised version of the DCR and calculated from the quantities landed, have since then become a "fallback option", in case the target precision level cannot be achieved.

According to the provisions of the new DCR, sampling intensities of the mandatory stocks must be set at least at the sampling levels of the "fallback option" and preferably at levels that allow reaching precision level 1, which is the lowest precision level defined in the DCR. SGRN is of the opinion that, for each sampled mandatory stock, MS should ensure a sampling design – either on their own or in co-operation with other MS – that covers the main fishing activities and the seasonality of the fisheries. Moreover, if the stock is under a Commission Recovery Plan, the sampling design should target precision level 2 instead of level 1.

In the light of the revised approach, a mandatory stock for which the exemption rules do not apply, must be sampled for length and, where appropriate age, according to the general principles set out in the previous paragraphs, and the low levels of sampling of the "fallback option" can never be used as an argument not to sample the stock.

Modules E, H and I

- On Accessibility and compensation of commercial fishing vessels

In the NP Proposals of several MS, the External Evaluators saw non-conformities with respect to the sea-going observers that did not have access to all vessels. As a consequence of these limitations in accessibility, MS may not be able to freely select vessels for catch sampling, which would prevent random sampling. The Evaluators also repeatedly commented on whether it is appropriate to make payments to vessels participating in catch and discard sampling programmes.

With regards to access, Council Regulation (EC) 2371/2002 includes the requirement for masters to take inspectors and observers on board vessels, but to SGRN's understanding, this refers specifically to pre-defined observer programmes (such as for small cetaceans, deep water fisheries, etc.) and not to the collection of samples under the DCR. However, within the revised DCR (EC Regulation 1581/2004), MS have an obligation to ensure access to any vessel for sampling purposes (Article 1 of EC Regulation 1581/2004). Despite this legal framework, SGRN recognises that it would be impractical in most situations for observers to sample effectively on a vessel without gaining co-operation from the skipper and crew.

SGRN reminds MS that they have the obligation to provide access for sea-going observers to any fishing vessel. SGRN recommends, however, that this should, if possible, be done through co-operation with the fishing industry, which has proven its effectiveness in many MS.

In relation to payments, SGRN distinguishes two situations in which ship owners and/or skippers may be paid by MS under the DCR:

- Ship owners and/or skippers receive a payment for assistance put into the sampling operations, and/or costs induced by the observers (safety equipment, food, etc.) or the sampling process (loss of value of landed fish owing to removal of otoliths, etc.) (= compensation); and

- A payment for having the observers on board (= reward).

SGRN recommends that the DCR should provide the opportunity for paying skippers compensations, because these can be considered as normal sampling costs . SGRN further recommends that the DCR should provide the opportunity for paying rewards by individual MS only if paying rewards serves the purpose of increasing the quality of the data collection through increasing the pool from which vessels can be randomly selected . SGRN recognizes, however, that this does not relieve MS from their tasks of providing access to any fishing vessel as is laid down in the DCR.

Module J

- On Population coverage and segmentation for economic data collection

SGRN observes that, as in previous years, some MS propose the exclusion of parts of the fleet from data collection under Module J of the DCR. MS are reminded that the definition of "commercial fishing fleet" is set out in Article 2.2 of the DCR, and that the coverage of data collection by segment should be as set out in Appendices III and IV to the DCR. SGRN insists that the MS follows the provisions of the DCR with regard to the definition of the population and segmentation.

- On Sampling information and precision levels for economic data

SGRN recognises the difficulty of achieving standard precision levels for fleet economic data. SGRN also notes that the calculation of precision levels requires that samples are random or at least, reflect some degree of randomisation. SGRN urges MS to provide full and clear information in their NP Proposals concerning sampling and survey procedures in order that the likely quality and reliability of the data can be assessed. SGRN however, does not expect information on precision levels in the NP Proposals – these should be given in the Technical Reports.

- On the Estimation of capital value

SGRN appreciates that the correct estimation of current capital asset values can be problematic and is aware that an external study has been commissioned in order to investigate this issue. In the meantime, SGRN observes that the requirement of the DCR is that an estimate of the current value of capital investment be made. Chapter IV, para. J,1,(a) of the DCR addresses this requirement and states that the insured value (of the vessel) is the preferred measure. SGRN recognises that this may overestimate current value in some cases and underestimate current value in other cases (for various reasons), but recommends that MS use this measure in conformity with the DCR. As stated in the DCR, replacement value may be estimated instead, but the need for this substitution must be shown, i.e. clearly explained. Note that for leased equipment, such as electronics and safety equipment, capital values should be estimated and lease/rental payments discounted from operational costs.

- On the Definition of "fixed costs"

SGRN recognises that in Appendix XVII of the DCR, the definition of fixed costs may be confusing. It is suggested that MS make clear their interpretation of this parameter in describing data collection under Module J.

- On the Definition of "employment"

SGRN recognises that in Appendix XVII of the DCR the definition of employment does not provide clear guidance concerning either the calculation of FTE or the necessity of providing both FTE and full-time/part-time employment measures. SGRN advises MS to provide both employment and FTE indicators, giving the methodology used to calculate FTE.

Module K

- On Parameter definition for economic data collection on the processing industry

SGRN recognises the difficulty of collecting economic data for the processing industry, also considering that the definition of several parameters in Appendix XIX of the DCR is not clear. SGRN was informed that a Workshop on the Processing Industry will be held in 2006 to propose precise definitions of the economic parameters to be adopted for the fish processing industry in the new DCR. In the meantime, SGRN suggests that MS provide clear information in their NP Proposals and Technical Reports concerning their interpretation of the parameters listed in Appendix XIX of the DCR.

Belgium

Module C

Evaluators' comments : Even though there is a Belgium fleet < 10 m LOA, Belgium does not have a national register for this fleet. Moreover, Belgium does not propose a particular sampling programme for this fleet segment. STECF to comment on this issue.

SGRN comments : SGRN was informed that all Belgian vessels < 10 m are recreational vessels, fishing almost exclusively for brown shrimp, Crangon crangon , in the near-shore waters. Although SGRN considers it useful to have an idea on the recreational fisheries for brown shrimp, it also recognizes that there is no formal obligation in the DCR to set up pilot studies for recreational fisheries other than for cod, salmon and bluefin tuna.

Module D

Evaluators' comments : Although Belgium declares that there is a fleet under < 10 m, this MS states there is not a national register for boats < 10 m. There is not a proposal of data collection plan for this segment. STECF to comment on this issue.

SGRN comments : See previous comment.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : SGRN in the "Analysis of derogations and non-conformities of Member States’ data collection National Programmes Proposals for 2005" (page 28) stated that " if the national study reveal any differences in discard pattern between the Belgian and the Dutch fleets, then SGRN recommends that Belgium sets up a routine discard sampling program for its own flatfish directed fishery in the North Sea. " To be evaluated by STECF.

SGRN comments : SGRN was informed that, owing to delays in its approval, the start of the national study mentioned in the Evaluators' comments, has been postponed until the first quarter of 2006. The national project has a two years' duration and will comprise extensive additional sampling for discards in the Belgian beam trawl fisheries in the North Sea and the Celtic Sea. SGRN recommends that the results of this project be communicated in due time, as part of the MS' future Technical Reports.

Evaluators' comments : Nephrops directed fishery in Functional Unit 5 (ICES Sub-area IVbc): Discard sampling will be done through a system of "self-sampling" by the fishermen of the only full-time Nephrops trawler (page 31 of NP). This is against the article 9, point 4 of the CR (EC) No 1639/2001, which states that " aggregated data may not include any evidence which could make it possible to identify individual vessels, natural or legal persons. " Moreover, the results of this estimate are statistically doubtful. In 2003, several unsuccessful attempts were made to establish self-sampling arrangements with the skippers of part-time Nephrops trawlers. CR (EC) No 1581/2004 states that on-board observers should be accepted on any vessels, therefore there can not be bias due to the lack of collaboration of skippers in the sampling scheme. Belgium pays under subcontracting for the self-sampling. It is not clear if this is appropriated. To be evaluated by STECF.

SGRN comments : SGRN was informed that the Belgian discard sampling programme on the Nephrops fisheries in FU 5 is facing serious problems and that the MS is reconsidering its sampling targets for 2006. In September 2005, the vessel that was contracted in the "self-sampling" programme went bankrupt and, in the absence of a readily available alternative, discards sampling in the Belgian Nephrops fishery came to an end. With the disappearance of the only full-time Nephrops trawler left, the Belgian Nephrops- directed fisheries in FU 5 are very likely to become a strictly seasonal activity and Nephrops landings are expected to drop below 100 t in 2006, i.e. to less than 10% of the total international Nephrops landings from FU 5. SGRN also notes that, so far, Belgium has been the only MS with a regular discard sampling programme in FU 5 and that e.g. the Netherlands, which take almost 60% of the Nephrops landings in FU 5, do not have a discard sampling programme in this area. SGRN suggests that all MS concerned (Belgium, Denmark, Netherlands and UK) enter into multilateral negotiations to ensure a minimum level of sampling on the Nephrops fisheries in the Southern North Sea in 2006 and beyond, through task sharing. Also see general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

Evaluators' comments : Belgium justifies the high cost on landings of its NP stating that its landings are low because does not have neither an industrial nor a pelagic fisheries, but the cost per unit weight is higher than other countries’ cost per unit of weight (page 10 of the NP). To be evaluated by STECF.

SGRN comments : Not in the remit of SGRN. Financial aspects of the NP Proposal to be discussed between the Commission and the MS.

Module F

Evaluators' comments : Belgium stated in the 2005 NP that the ICES Working Group on the Assessment of Southern Shelf Demersal Stocks (WGSSDS) at the 2003 meeting, did start the construction of a CPUE data series for sole in VIIIa,b for tuning purposes. This would be further investigated at the 2004 meeting of the Working Group. If this attempt was successful, then this CPUE data series would be included under the Belgian MP in the years to come. This CPUE series has been included in the 2006 Belgian MP, although it does not involve extra costs. To be evaluated by STECF.

SGRN comments : SGRN notes that the MS is collecting this information with no additional costs. Hence, SGRN does not see where the problem might be and agrees with the approach taken by the MS.

Module G

No comments.

Modules H & I

Evaluators' comments : Sampling intensity for the case of Nephrops norvegicus FU5: even if SGRN repeatedly stated that " Sampling in excess of the DCR requirements should be eligible for funding when it is justified to maintain the quality of CPUE data series under module F " Belgium is increasing the sampling intensity from 2005 Proposal with a decrease in the landings. To be evaluated by STECF.

SGRN comments : The evaluators seem to have missed a crucial detail while comparing the numbers for length sampling in the 2005 and 2006 NP Proposals. The figure for 2006 is indeed higher than the one for 2005 (despite the decrease in Nephrops landings by Belgian vessels) because it also includes sampling of Dutch Nephrops trawlers, landing their catches into Belgium for first sale in a Belgian auction. In 2005, no such sampling of foreign flag vessel landings was foreseen in the NP Proposal.

Evaluators' comments : Concerning length and age sampling of discards, Belgium does not give any data about the discard estimates of precedent years or the number of discarded fish to be sampled, making it impossible to know if DCR is being correctly implemented. To be evaluated by STECF.

SGRN comments : SGRN was informed that in the Belgian discard sampling program, targets are set in terms of (i) numbers of observer trips to be achieved, and (ii) numbers of hauls to be sampled per day at sea. In such a system, the numbers of fish measured strongly depend on the quantities caught, and therefore, are difficult to foresee. SGRN agrees with the approach taken by the MS, but insists that in future Technical Reports, details are given on the precision levels of the achieved discard sampling.

Module J

Evaluators' comments : With respect to the precision level any information is considered explicitly, but only the response rates to the questionnaires. The precision level obtained last year could have been interesting information. STECF is invited to comment on this issue.

SGRN comments : SGRN insists that the MS includes information of the precision levels achieved under Module J of the DCR in its future Technical Reports. Also see general comment on Sampling information and precision levels for economic data.

Module K

No comments.

Cyprus

Module C

No comments.

Module D

No comments.

Module E

- LANDINGS

Evaluators' comments : Cyprus proposes to divert the entire budget of the 2005 section J & K (41,240 €) to section E, due to the underestimation of the money involved in section E. It is not clear if the budget presented includes this figure or not. To be evaluated by STECF.

SGRN comments : Not in the remit of SGRN. Financial aspects of NP Proposal to be discussed between the Commission and the MS.

- DISCARDS

Evaluators' comments : Cyprus asks to remove discard programs from the 2005 NP (40,805 €) to the 2006 NP, it will not affect the application of the DCR regarding discards, since these data are required to be collected once over a three year period. It is not clear if the budget presented includes this figure or not. To be evaluated by STECF.

SGRN comments : Not in the remit of SGRN. Financial aspects of NP Proposal to be discussed between the Commission and the MS.

Evaluators' comments : Monitoring of discards will require a pilot scheme. Based on experience and sampling in previous years it has been verified that discard rates in passive gear fishery are insignificant. Therefore, no discard sampling of this fishery will be conducted (page 18 of the NP). To be evaluated by STECF.

SGRN comments : SGRN was informed that the discard rates of the small scale passive gear fisheries are negligible (10 kg on average per day for the last 5 years). SGRN considers that a derogation is justified.

Evaluators' comments : No data on fisheries operations are available from the areas which are not accessible to the Government Authorities of Cyprus, namely the North/North East shores of Cyprus (page 1 of the NP). To be evaluated by STECF.

SGRN comments : SGRN notes that since 1974, it has not been possible for the Government authorities of Cyprus to collect any data on the above mentioned fisheries operations, due to the inaccessibility of the Northern / North-eastern part of Cyprus.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

No comments.

Module G

Evaluators' comments : MEDITS is to be conducted during the second quarter of the year (Commission Regulation (EC) No 1581/2004). The timetable proposed in the NP for this survey is June to August. To be evaluated by STECF.

SGRN comments : See general comment on the MEDITS survey.

Additional SGRN comment : See general comment on Tuna tagging.

Modules H & I

Evaluators' comments : Nothing is said in the Proposal about the number of samples that are going to be taken, it is thus not possible to know whether the sampling is appropriate or not. To be evaluated by STECF.

SGRN comments : SGRN assumes that the DCR will be correctly implemented, but insists that full details on the issue be given in future NP Proposals.

Evaluators' comments : Cyprus is going to use the MEDITS survey (to be conducted during the second quarter of the year, using a non-commercial trawl gear) for age and length sampling and then apply the obtained ALK to the commercial landings. To be evaluated by STECF.

SGRN comments : SGRN was informed that Cyprus is going to use the MEDITS survey to collect complementary ALK-data, but that the length structure will be derived from the commercial landings. SGRN agrees with the approach taken by the MS.

Evaluators' comments : The reference landings used for the average catch production are those taken during 2001-2003, and not the average of the last three years, as the stated in the DCR. To be evaluated by STECF.

SGRN comments : See general comment on the Reference period for average landings for the Mediterranean.

Module J

Evaluators' comments : A good description of economic parameters is offered. A more concise and specific definition of each parameter compared to the ones in the DCR is provided. These definitions are based on the guidelines from Paris economist workshop, 2004. All of the parameters in Appendix XVII will be met, although the following two considerations must be done. Firstly, a pilot study is implemented to both calculate some parameters (opportunity cost) and to validate others (own and borrowed capital). STECF is invited to comment on this issue.

SGRN comments : See general comment on the Estimation of capital value.

Evaluators' comments : It is stated that total employment will be obtained in terms of the number of persons employed either full or part-time. There is nothing about a FTE, which is required by the DCR. STECF is invited to comment on this issue.

SGRN comments : SGRN was informed that Cyprus will get the data for both full and part-time employment. Also see general comment on the Definition of "employment".

Evaluators' comments : Parameters will be obtained according to the Appendix III of the vessel segmentation. However, in the Proposal it is poor mentioned whether the vessels will be grouped by geographical area covering the requirement level 3 of Appendix I. STECF is invited to comment on this issue.

SGRN comments : Based on the Appendix I of the DCR, Cyprus belongs only to one geographical division. The MS is reminded that level 3 disaggregation only applies to prices.

Module K

Evaluators' comments : Cyprus will conduct pilot surveys (through questionnaires) to asses the annual value of the sector and its parameters. It is reasonably argued the need for it, nevertheless STECF is invited to comment on this issue.

SGRN comments : SGRN agrees with the approach taken by the MS, since the processing industry is a relatively new sector in Cyprus and most of the data needed are not available. Also see general comment on Pilot studies by new MS in December 2004 Report of SGRN.

Denmark

Module C

No comments.

Module D

Evaluators' comments : Regarding boats < 10 m, Denmark states that it is possible to estimate effort in number of days based on sales registers. However, Denmark does not state if those registers detail the fishing area in which catching was done. STECF to comment on this issue.

SGRN comments : SGRN was informed that the sales slips on which Danish effort data collection is based, also contain information on fishing area and landing harbour, and that it is therefore possible to allocate effort to fishing area. Further, boats < 10 m are fishing on licenses that restrict them to fish within a specific area, and therefore it is possible to specify effort by area.

Module E

- LANDINGS

No Comments.

- DISCARDS

Evaluators' comments : There is no authority in Danish law, which gives the possibility to enforce the observers’ participation on a fishing trip. Therefore, the vessels will not be sampled randomly among all vessels performing a given fishery but only among the vessels where the skipper beforehand has agreed in having observers on board (pages 14 & 15 of the NP).The amendment states that observers should be accepted on any vessel in order to avoid biased estimates. Non conformity.

SGRN comments : SGRN was informed that the Danish sampling scheme is carried out in close collaboration with the fishermen's organisations and that a formal obligation to take sea-going observers could jeopardise the good working relationship between observers and skippers. Also see general comment on Accessibility and compensation of commercial fishing vessels.

Evaluators' comments : Skippers will be compensated for allowing observers to work on their vessels (see financial forms). According to the CR (EC) No 2371/2002 and the amendment the master shall accept observers on board and cooperate with them. It is not clear if compensations are appropriated in these cases and if they should be paid by the NP. To be evaluated by STECF.

SGRN comments : SGRN was informed that the compensations are not for allowing the observers to work on-board, but for the crew's co-operation with handling the catch and for the inconveniences of having to change working procedures to accommodate the sampling procedures. Also see general comment on Accessibility and compensation of commercial fishing vessels.

Evaluators' comments : In the Annex II, the table with discard sampling indicates that there will be no discards of salmon in the Baltic in 2006. Due to the dioxin problem, sell large salmon has been forbidden at least in part 2005. Denmark should have explained in the NP why, despite this, does not expect discard of salmon in the Baltic in 2006. To be evaluated by STECF.

SGRN comments : According to the MS, there is no indication that the discards of salmon in 2006 are going to be above the limit of either 10 % in weight or 20 % in numbers. In the absence of clear evidence however, SGRN was unable to judge the validity of this statement. SGRN also reminds the MS that, regardless of the quantities actually discarded, triennial estimates of the salmon discards in ICES Sub-area III are a requirement of the DCR (Appendix XII of the DCR). SGRN insists that the MS follows the provisions of the DCR.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : Denmark will continue to produce CPUE data for assessment purposes. Nevertheless, no mention is done about CPUE series for salmon within Danish NP. Non conformity.

SGRN comments : SGRN was informed that the MS will continue to produce the CPUE series for salmon, and that the omission of this CPUE data series from the NP Proposal is an oversight.

Module G

Evaluators' comments : This is the first time that Denmark includes within their NP a budget for the participation in the Herring Acoustic Survey (3rd and 4th Q.; IIIa, IIIb-d). Denmark indicates that they have agreed in participation in this survey and Danish staff will participate on the vessels. To be evaluated by STECF.

SGRN comments : SGRN was informed that the MS has participated in the Herring Acoustic survey for a number of years. The omission from the NP in previous years has been an error.

Modules H & I

Evaluators' comments : Even if the Regulation is covered, it is necessary to mention, as last year, that sampling within section I will be done by sampling in surveys except for herring and sprat which are also sampled in the commercial catches. As mentioned above, sampling during seasonal surveys can give biased results especially when the data is used for maturity, fecundity and/or sex ratio and the survey period does not match with the spawning season. To be evaluated by STECF.

SGRN comments : SGRN agrees with the approach taken by the MS. Also see general comment on Sampling of biological parameters - Use of survey data, in SGRN's Report of December 2003, and SGRN's comments on the same issue in SGRN's Report of December 2004.

Module J

Evaluators' comments : For fixed cost, the opportunity cost is not provided. For the crew cost, it is not mentioned if labour costs include the expenditures paid by employers. Finally, for the investment, the insured value is considered the second best to the replacement value, while the DCR specifies that the insured value is preferred. STECF is invited to comment on this issue.

SGRN comments : SGRN insists that the MS follows the provisions of the DCR. Also see general comments on the Estimation of capital value, and on the Definition of "fixed costs".

Evaluators' comments : Denmark will not meet the vessel segmentation according to Appendix III. Firstly, it is only considered those vessels with a yearly sale of fish above a threshold value (EUR 30,161 in 2004) (although states that statistics will cover 98% of the output from the Danish fishery and is otherwise segmented). This threshold is not considered by the DCR, but it establishes the obligation of considering all of the vessel population. Secondly, the vessel segmentation by type of fishing has not been done according to appendix III classification. STECF is invited to comment on this issue.

SGRN comments : See general comment on Population coverage and segmentation for economic data collection.

Evaluators' comments : Denmark offers a description of the sample selection and stratification. Denmark will be able to obtain statistical information of 407 vessels that participate on a voluntary basis, from a total of 1,243 vessels. Thus the allocation of the sample in the strata will probably no be sufficient to obtain the required precision level 1. Denmark does not mention any issue on this. STECF is invited to comment on this issue.

SGRN comments : See general comment on Sampling information and precision levels for economic data.

Evaluators' comments : Denmark will carry out the Extended Program (EP). However, pilot studies will be necessary to fulfil the requirements of Appendix XVIII. STECF is invited to comment on this issue.

SGRN comments : It is unclear what is meant by "pilot study" in this context. This should be clarified by MS. More information is required on the scope and contents of the EP in general.

Evaluators' comments : Some of the economic parameters will not be obtained –for example, the fixed costs, and the financial position. With respect to the production costs, there is no information about sub-divisions specified in DCR in terms of crew, fuel, repair and maintenance, and other operating costs. STECF is invited to comment on this issue.

SGRN comments : See previous comment.

Evaluators' comments : Disaggregation of vessels up to the level specified in Appendix IV will not be fully met in terms of different types of fishing technique differences. STECF is invited to comment on this issue.

SGRN comments : See previous comment.

Evaluators' comments : Regional differentiation will probably not be met for costs when vessels have fishing trips in several subdivisions. STECF is invited to comment on this issue.

SGRN comments : See previous comment.

Module K

Evaluators' comments : The procedure followed by Denmark is based on a pilot study reported in 2003. Denmark will meet the economic parameters specified in Appendix XIX on a yearly basis except for the capacity utilization, which is not estimated for the fish processing industry. The complexity of measuring it is referred to and Denmark recommends removing it from section K. STECF is invited to comment on this issue.

SGRN comments : SGRN appreciates the problem and suggests that the issue be taken into account in the revision of the DCR. Also see general comment on Parameter definition for economic data collection on the processing industry.

Estonia

Module C

No comments.

Module D

No comments.

Module E

- LANDINGS

No comments.

- DISCARDS

No comments.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : Estonia has included within their NP the collection of two CPUE series.

- CPUE of herring trap net fishery in the Gulf of Riga.

- CPUE of shrimp trawlers in NAFO area (3M, 3L).

The inclusion of the first one was recommended by the SGRN in 2005 Report. Estonian NP indicates that the Shrimp Trawlers CPUE series is used by the NAFO SC assessment group. In any case, Estonia does not request funds within their MP. To be evaluated by STECF.

SGRN comments : SGRN notes that the MS is collecting this information with no additional costs. Hence, SGRN does not see where the problem might be and agrees with the approach taken by the MS.

Module G

No comments.

Modules H & I

Evaluators' comments : The non-conformities found to be evaluated by STECF are presented in the table below.

Species | Stock | Comments | STECF |

Recurrent | Clupea harengus | IIId | Over-sampling of 125% to be checked at whose expenses | Accepted |

Recurrent | Sprattus sprattus | IIIb-d | Over-sampling of 100%, to be checked at whose expenses | Accepted |

Recurrent | Salmo salar | IIIb-d | Over-sampling, but only 100 lengths and 100 ages, not clear if it is going to improve the evaluation of the stock | Accepted |

Recurrent | Salmo trutta | IIIb-d | Over-sampling, only 100 lengths and 100 ages, not clear if it is going to improve the evaluation of the stock | Accepted |

Recurrent | Gadus morhua | IIIb-d | Over-sampling (recovery plan). Only 100 lengths and 50 ages, not clear if it is going to improve the evaluation of the stock | Accepted |

NEW | Anguilla anguilla | IIIb-d | Over-sampling (250x) |

SGRN comments : SGRN considers that "over-sampling" is not against the spirit of the DCR, as long as it is justified to achieve necessary precision level for stock assessment purposes.

Evaluators' comments : From Estonian NP it is not possible to know what is the level of over-sampling for Pandalid shrimp in NAFO area 3M and at whose expenses. To be evaluated by STECF.

SGRN comments : To be clarified by MS.

Evaluators' comments : The species studied covered by the Regulation in the EP are systematically over-sampled (see table below). To be evaluated by STECF.

Species | Stock | Comments | STECF |

Recurrent | Platichtys flesus | IIIb-d | Over-sampled at 480 %, to be checked at whose expenses | Accepted |

Recurrent | Coregonus lavaretus | IIId | Over-sampled at 2500%, to be checked at whose expenses | Accepted |

Recurrent | Sander lucioperca | IIId | Over-sampled at 1200 %, to be checked at whose expenses | Accepted |

Recurrent | Perca fluviatilis | IIId | Length over-sampling | Accepted |

NEW | Esox lucius | IIId | Over-sampled at 3000%, to be checked at whose expenses | - |

SGRN comments : Firstly, SGRN notes that flounder should be in the MP (since the mid-term revision of the DCR, flounder in the Baltic has been moved from the optional to the mandatory list). With regards to the other species, see general comment on the Interpretation of biological sampling requirements.

Module J

Evaluators' comments : Estonia will not fully meet the vessel segmentation according to the Appendix III because, among other issues, Estonia considers as part of population those vessels operating only in the Estonian Economic Zone, while Estonia also operates in other areas (e.g. NAFO, NEAFC). Additionally, considered population is classified by fishing technique but not according to the specified classification in Appendix III. In particular, demersal and pelagic trawler are jointly provided. STECF is invited to comment on these issues.

SGRN comments : SGRN recommends that the MS follows the provisions of the DCR. Also see general comment on Population coverage and segmentation for economic data collection.

Evaluators' comments : No information is given about the precision level. STECF is invited to comment on this issue.

SGRN comments : See general comment on Sampling information and precision levels for economic data.

Module K

Evaluators' comments : No information is provided in the Proposal in relation with the economic parameters of Appendix XIX, or the precision level to reach. STECF is invited to comment on this issue.

SGRN comments : See general comment on Parameter definition for economic data collection on the processing industry.

Finland

Module C

No comments.

Module D

Evaluators' comments : Finland states that, for vessels < 10 m devoted to coastal fishing, fishing effort can be calculated by gear not by vessel. However, according to Regulation fishing effort must be measured by fishing days (related to nominal fishing power as KW or GT), area and specific period. Finland argues that there is not a high correlation between effort and tonnage for fixed fishing gear. Finland argues that during winter fishing may be carried out by fixed gear under ice cover. This supports its argument that there is not a correlation (for this particular case) between boat tonnage and fishing effort. The polemic that arises is if this argument is also valid for estimating fishing effort during summer, spring and autumn. STECF to comment on this issue.

SGRN comments : SGRN is of the opinion that the MS' approach assures a higher level of accuracy in the collection of effort data than is required by the DCR. SGRN also notes that the approach taken by Finland has been proposed by the Kavala meeting on small scale fisheries to become the standard for measuring fishing effort of static gears. Therefore, SGRN agrees with the approach taken by the MS. Also see general comment on Fishing effort for passive gears.

Module E

No comments.

Module F

Evaluators' comments : Finland specifies that 12 fleets will be studied for the provision of CPUE series. Nevertheless, concerning the long line data series for salmon in area 32, the SGRN stated in 2004 that the assessment in Sub-division 32 is not making use of these CPUE data as it is based on tagging and information from the trap net fishery. The data series does not comply with any of the criteria for funding under the MP. It is however, used to provide general background information on the fisheries, and as such, it helps to improve the overall assessment process. Therefore this data series should be eligible under the EP. Last year SGRN reiterated its earlier recommendation that this CPUE series be moved to the EP. Non conformity.

SGRN comments : SGRN was informed that there are no additional costs involved in recording the effort (number of lines and hooks) associated with the catches from this fishery. Since the proposed action is, however, not eligible under the MP, SGRN re-iterates its earlier recommendation that this CPUE series be moved to the EP.

Module G

Evaluators' comments : Regarding the acoustic survey for herring, Finland will follow the considerations of STECF-SGRN and the Regional Coordination Meeting for the Baltic (RCMB) concerning the Herring Acoustic Survey in the Baltic and will finally carry out this survey in coordination with other Baltic countries. Finland indicates that during first year/s the survey will be included as a pilot study and its usefulness for the herring stock assessment will be evaluated based on the results of the pilot phase. To be evaluated by STECF.

SGRN comments : SGRN agrees with the approach taken by the MS.

Evaluators comment : Finland is asking for not making surveys in SD 30 on herring. Finland argues that the assessment has been accepted by ICES. This is right but it is also said by ICES, that if the stock status should become less favourable, the lack of fishery-independent information can become critical to the ability to give proper advice. With the large behavioural changes of the herring fleet in Finland the CPUE series, which always is an uncertain abundance indicator for pelagic species, gets even more uncertain. To be evaluated by STECF.

SGRN comments : SRGN notes that the ICES Working Group on Baltic International Fish Surveys in 2004 re-iterated its recommendation that SD 29N, 30, 31 and 32 should be covered in future Herring Acoustic Surveys (3rd and 4th quarters). Meanwhile, ACFM in May 2005, has expressed concerns on the lack of fishery independent information on herring in Sub-division 30. SGRN recommends that the area coverage of this survey and the work allocation among MS should be resolved by the Regional Co-ordination Meeting for the Baltic and by relevant ICES working groups (i.e. WGBIFS, WGBFAS), and that both Finland and Sweden take into account the conclusions of these groups in their NP submission for 2007.

Modules H & I

Evaluators' comments : The non-conformities found are: All the stocks in minimum program (Herring, Sprat, Salmon, Sea trout and Flounder) are over-sampled (i.e. 25,000% higher than what corresponds to the Regulation for Sea trout). To be evaluated by STECF.

SGRN comments : SGRN considers that "over-sampling" is not against the spirit of the DCR, as long as it is justified to achieve necessary precision level for stock assessment purposes. Besides, the evaluators seem to have mis-interpreted the NP Proposal concerning sea-trout, since Finland is not planning to take samples, but to use data derived from tagged fish instead.

Evaluators' comments : Finland is requesting an EP for some stocks. Some non-conformities are found concerning sampling intensity. As in the MP, all the EP stocks are over-sampled (see table below).

Stock | Comments | STECF |

Recurrent | Whitefish | Over-sampled | Accepted |

Recurrent | Pikeperch | Over-sampled | Accepted |

Recurrent | Perch | Over-sampled | Accepted |

SGRN comments : See general comment on the Interpretation of biological sampling requirements.

Module J

Evaluators' comments : The population for calculating the economic parameters does not include those vessels which annual turnover/catch value is below €9,134. This is contrary to the SGECA recommendations. The main reason provided is that those vessels are not considered to be operational units. The rationale for this population reduction should be elaborated further. STECF is invited to comment on this issue.

SGRN comments : See general comment on Population coverage and segmentation for economic data collection.

Evaluators' comments : The vessel segmentation will be done according to the Appendix III of the DCR. The time-disaggregation will be also met, but there is no guarantee the precision level 1 will be met in all the economic parameters. STECF is invited to comment on this issue.

SGRN comments : See general comment on Sampling information and precision levels for economic data.

Module K

Evaluators' comments : Finland will not fully cover all the parameters included in Appendix XIX. In particular, prices per product, income per product, and the capacity utilization will not be available. STECF is invited to comment on this issue.

SGRN comments : SGRN insists that the MS follows the provisions of the DCR.

Evaluators' comments : Finland will attempt the Extended Program on the area of aquaculture. The main reason is given by the high importance of the aquaculture for the primary production; and as a raw material in processing industry.

SGRN comments : SGRN notes that, for the time being, aquaculture is not covered by the DCR.

France

Module C

No comments.

Module D

Evaluators' comments : Regarding, specific fishing effort, France states that it will follow the recommendations on data collection of ICCAT and IOTC. France considers other notions on fishing effort as meaningless and adds that are not applied either by ICCAT and IOTC. No explanation is provided on the data collection on specific fishing effort targeting bluefin tuna in the Mediterranean (trans-shipments to marine farms). STECF to comment on this issue.

SGRN comments : For some species, SGRN notes that the disaggregation level is more precise than the one specified in the DCR. SGRN sees no contradiction between the MS's approach and the requirements of the DCR. SGRN agrees with the MS's point of view that it makes sense to collect species specific effort data for tuna according to the effort definitions agreed and used by ICCAT and IOTC, but only if these definitions use higher scales of resolution than the ones requested by the DCR.

SGRN notes that an explanation is given under Module E of the NP Proposal (page 8 of the Proposal) on the collection of landings and effort data for the bluefin tuna fishery in the Mediterranean, including catches for transhipment to marine farms.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : The STECF/SGRN and the Commission have refused in 2005 the exemption granted from 2002 to 2004 for not sampling the segment of demersal trawlers over 24 m long operating in the Celtic Sea and for industrial trawlers over 40 m in the Atlantic. Therefore in the 2006 plan these fleets are included in the sampling scheme. France stated that this might be reviewed in the light of the actual situation on the ground in 2005 (length of trips, advanced bases, make-up of discards). To be evaluated by STECF.

SGRN comments : SGRN was informed that the Celtic Sea discard programme was carried out along the lines of the NP Proposal in 2005, and that the programme will be continued in 2006. SGRN also was informed that France does not intend to sample demersal trawlers > 40 m in the Atlantic, as this component of the fleet is no longer active. Also see general comment on Adjustment of NP Proposals to RCM recommendations.

Evaluators' comments : Industrial trawling for saithe (vessels over 40 m) has practically disappeared since the end of 2004 at Boulogne-sur-Mer, as it has become unprofitable as a result of the market slump. It is therefore no longer included in the 2005 and 2006 sampling plans. To be evaluated by STECF.

SGRN comments : Sampling intensity must be a function of current landings. The best a priori estimate is the mean of the last three years, but in this case, the collapse of the saithe market can be considered as force majeure. SGRN agrees with the approach taken by the MS.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

No comments.

Module G

Evaluators' comments : No comments.

SGRN comments : See general comments on the MEDITS survey, and on Tuna tagging.

Modules H & I

Evaluators' comments : France is going to implement a sampling program based on precision levels but, as last year, nothing is mentioned about the methodology used to attain such precision levels. To be evaluated by STECF.

SGRN comments : SGRN insists that France gives a precise description of the methodology to assess the quality of the sampling for length and age in its Technical Report 2005.

Evaluators' comments : In the case of Mediterranean Bluefin Tuna, a sampling derogation is requested, as in 2004 and 2005. To be evaluated by STECF.

SGRN comments : From the Spanish NP Proposal, SGRN assumes that Spain will sample the French tuna catches that go into marine farms. The Spanish NP Proposal also mentions a bilateral agreement between France and Spain on sampling of bluefin tuna in the Mediterranean, but there is no mention of this in the French NP Proposal. To be clarified by MS.

Evaluators' comments : The non conformities found in the MP sampling if finally the precision level approach is not used are:

Species | Stock | Parameters | Comments | STECF |

New | Merluccius merluccius | Medit all areas | Length | Over-sampling of 1000% |

New | Sparus aurata | Medit 1.2, 3.1 | Length | Over-sampling of 2500% |

New | Dicentrarchus labrax | Medit 1.2 | Length | Over-sampling of 2500% |

Octopus vulgaris | Medit all areas | Length | Over-sampling of 1000% |

Mullus (2 species) | Medit all areas | Length | Over-sampling of 400% |

Lophius (2 species) | 1.2 not included | Length | Not a request for France |

Merluccius merluccius | Medit all areas | Age | Over-sampling of 200% |

Sparus aurata | Medit 1.2, 3.1 | Age | Over-sampling of 5000% |

Dicentrarchus labrax | Medit 1.2 | Age | Over-sampling of 2500% |

Lophius (2 species) | 1.2 not included | Age | Not a request for France |

SGRN comments : See general comment on the Interpretation of biological sampling requirements.

Evaluators' comments : In the special case of eel many doubts arise from the fact that France is using the 100 tonnes rule for asking an exemption of sampling French eel fishery and France is the country with the larger amount of glass eel landings. To be evaluated by STECF.

SGRN comments : See SGRN's comments and recommendations on the sampling of eel in Chapter 3 of the present Report.

Evaluators' comments : France does not sample Horse Mackerel while French fisheries are carried out in the Bay of Biscay and other areas of the Northern East Atlantic. To be evaluated by STECF.

SGRN comments : SGRN insists that the MS follows the provisions of the DCR.

Module J

Evaluators' comments : France will cover the economic parameters from Appendix XVII. However, no information is offered related to the concept and calculation method for the following parameters:

- Fixed costs (depreciation costs, opportunity costs, average cost from investment).

- Financial position (ratio between own capital and borrowed capital).

- Investment (insured value based).

STECF is invited to comment in this issue.

SGRN comments : See general comments on the Estimation of capital value, and on the Definition of "fixed costs".

Evaluators' comments : There is a good description of the stratified sampling process, but France does not explicitly say which precision level will be met, and it is not possible to calculate it from the description. It is only stated that the number of vessels for sampling will be around 1600, which is the minimum for achieving an "acceptable" level of precision. Given that it almost the same as the last year’s scheme, it would be useful if the precision level obtained last year was specified. STECF is invited to comment in this issue.

SGRN comments : SGRN insists that the MS follows the provisions of the DCR. Also see general comment on Sampling information and precision levels for economic data.

Module K

Evaluators' comments : The data obtained through a postal questionnaire let France to "seeks to obtain" only part of the parameters specified in Appendix XIX of Regulation. The parameters lacking are: prices per product, labour costs and other running costs, capacity utilization, financial situation, and fixed costs. To supplement the information compiled from questionnaires economic and accounting data will be cover only for enterprises with more than 20 wage-earners. The economic parameters that France could "potentially" cover are the fixed costs, financial situation and production costs (labour, purchases of raw materials, other inputs, depreciations, and financial charges). STECF is invited to comment on this issue.

SGRN comments : See general comment on Parameter definition for economic data collection on the processing industry.

Germany

Module C

No comments.

Module D

No comments.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : Despite of having prepared a legal text in 2005 for providing the legal basis for biological sampling on board of German fishing vessels, Germany states that the present status of a sampler on board of a German fishing vessel is a guest status. The possibility fro biological sampling depends on the hospitality of ship owners and companies. Based on the present situation, random sampling of the fleet is still difficult (page 15-16 of the NP). On-board observers should be accepted on any vessel in order to avoid biased estimates. Non conformity.

SGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

Evaluators' comments : It seems that only salmon is considered. Cod should also be included. To be evaluated by STECF.

SGRN comments : Concerning cod, SGRN was informed that the planned activities are represented extensively in the NP Proposal. The Evaluators' comment seems to be based on the absence of the words "Cod" and "Salmon" in the heading of the relevant chapter in the NP Proposal.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : Germany will maintain all CPUE series in 2006 as previously provided to assessment working groups. German includes within their MP the Greenland halibut in ICES Sub-areas V and XIV CPUE series, which is not included in the list of the STECF Report on CPUE data series evaluation. Nevertheless this series seems to fulfill the requirements to be eligible under the MP according to the Regulation. To be evaluated by STECF.

SGRN comments : SGRN notes that the Greenland halibut CPUE data series is not in the list of MP CPUE data series (see SEC 2003 551) and therefore these data are not eligible under the MP. Financial implications to be discussed between the Commission and the MS.

Module G

No comments.

Module H & I

No comments.

Module J

Evaluators' comments: The distinction between full/part time and FTE is not distinguished for the whole population. STECF is invited to comment on this issue.

SGRN comments: See general comment on the Definition of "employment".

Module K

Evaluators' comments : Germany offers information about economic parameters of Appendix XIX that will be covered, by showing the included information in the balance sheet assets, balance sheet with liabilities, and profit and loss statement of account. However, no information has been offered with respect to the prices/products, raw material (total and per species), and capacity utilization. STECF is invited to comment on this issue.

SGRN comments: SGRN insists that the MS follows the provisions of the DCR. Also see general comment on Parameter definition for economic data collection on the processing industry.

Greece

Module C

Evaluators' comments : According to the statements done in the Greek NP we have to say that precision level will be met. However, 90% of the Greek fleet is < 12 m, and must prove to be difficult to monitor. We would therefore recommend that the Commission further establish with Greece that all 20 000 vessels are on their vessel register with all data exhaustively collected. If all data are not exhaustively collected, then any sampling programme would need to be carefully examined for precision.

SGRN comments : SGRN was informed that all Greek vessels are on the Greek vessel register (KAM) and that all data will be exhaustively collected, according to the provisions of the DCR.

Module D

No comments.

Module E

- LANDINGS

Evaluators' comments : Sampling effort is planned to be distributed among the different types of fishing techniques, taking into account the types within <12 m passive gears separately (the same effort devoted to each one, 0.3% of the sampling working days). The <12 m vessels are the majority of the Greek fleet. It is not possible to assess whether this sampling effort distribution is correct, all the more when in section C Greece indicates that for vessels in the <12 m category, the different types of passive gears will be merged. An explanation on the expected coverage of the sampling should be given. To be evaluated by STECF.

SGRN comments : The sampling effort noted in Table 3.1 of the NP Proposal is for each month (left apart the periods during which fishing is prohibited for any of the fishing techniques) and for each of the 30 sampling sites. SGRN was informed that coverage in 2004 was around 800 vessels < 12 m (4.4 %) and that a similar coverage is expected in 2006. Moreover, according to the past Greek NPs, the required precision levels were met for each geographical area, as requested by the DCR. SGRN recommends that a specific annex be included in the MS's 2005 Technical Report, giving full evidence of the precision levels reached. SGRN expects that the coverage problem will be resolved when the DCR will be implemented according to the métier approach. Nevertheless, SGRN recommends an increase in sampling effort on the passive gears in 2006.

Evaluators' comments : Sampling stratification over time (Table 3.6 in the NP) is determined by the period of activity of the different fleets, sampling being carried out during 3 months distributed along the year. The assessment of overall production will be based on random observations of production per unit of effort (fishing days) at each site for each vessel category. To be evaluated by STECF.

SGRN comments : SGRN understands that sampling stratification for demersal trawls, seiners and large pelagic species takes into account temporal closures of these fisheries. However, SGRN sees no reason why particular quarters should be omitted from the sampling scheme for coastal vessels. SGRN insists that the MS follows the provisions of the DCR.

- DISCARDS

Evaluators' comments : Skippers will be compensated for allowing observers to work on their vessels (page 10 of the NP). According to the CR (EC) No 2371/2002 and the amendment the master shall accept observers on board and cooperate with them. It is not clear if compensations are appropriated in these cases and if they should be paid by the NP. To be evaluated by STECF.

SGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : Greece states that they will elaborate the CPUE series according the recommendations of STECF's Report in 2003. CPUE indices will be estimated from random catch-effort observations that will be gathered from the main (pilot) Greek large pelagic fleets. These included fleets involved in the fisheries of swordfish, bluefin tuna and albacore, although no CPUE series for albacore appears in the list of the STECF report on CPUE data series evaluation. To be evaluated by STECF.

SGRN comments : SGRN notes that data on albacore are already collected under Module D of the Greek NP (specific fishing effort for stocks of large pelagic species) at no extra costs.

Evaluators' comments : In relation to the sampling methodology, it will cover 50% of the total working days for all categories of vessels of the studied fleets, which also covers ICCAT demands for stock assessment studies. Based on the results of previous studies it is estimated that such a scheme will make possible to obtain CPUE estimates with precision of plus or minus 10% for a 95% confidence level. Although data collection will be carried out in the framework of Modules D & E, a high personnel budget in relation to the total number of CPUE series elaborate is included within Greece NP. To be evaluated by STECF.

SGRN comments : Not in the remit of SGRN. Financial aspects of NP Proposal to be discussed between the Commission and the MS.

Module G

Evaluators' comments : No comments.

SGRN comments : See general comments on the MEDITS survey, and on Tuna tagging.

Modules H & I

Evaluators' comments : The reference landings used for the calculation of the sampling intensities are the average for the period 2000-2002 from FAO statistics. It’s not easy to understand why Greece is still using FAO statistics since the DCR is enforced since 2002 for module E. To be evaluated by STECF.

SGRN comments : See general comment on the Reference period for average landings for the Mediterranean.

Evaluators' comments : No information is provided on the sampling methodology. Furthermore, Greece points out that the preparation of a sampling protocol is considered necessary, four years after the DCR implementation. To be evaluated by STECF.

SGRN comments : SGRN notes that the sampling protocol referred to by the Evaluators is for the "new" species that were included in revised version of the DCR. SGRN assumes that the DCR will be correctly implemented, but insists that full details on the issue be given in future NP Proposals.

Evaluators' comments : Concerning sampling intensity, it is not possible to know whether the minimum levels of appendix XV are going to be attained since NSP states the required minimum levels but not the proposed ones to be done. To be evaluated by STECF.

SGRN comments : SGRN assumes that the DCR will be correctly implemented, but insists that full details on the issue be given in future NP Proposals.

Evaluators' comments : The derogation for Micromesistius poutassou, Illex sp., Loligo vulgaris, Pagellus erythrinus, Mugil cephalus, Solea vulgaris , is not based in the reasons allowed in the DCR. To be evaluated by STECF.

SGRN comments : See general comment on the Interpretation of biological sampling requirements.

Module I

Evaluators' comments : Greece does not give any information, doing impossible to know if DCR is being correctly implemented. To be evaluated by the STECF.

SGRN comments : SGRN was informed that sampling for other biological data is not foreseen in 2006 but in 2007, since the previous 3-years reference period was 2002-2004 (NP Technical Report 2004, page 17-18 & Table 11.1). However, the NP Proposal should have included this information. SGRN insists that full details on the issue be given in future NP Proposals.

Module J

Evaluators' comments : Greece states that it will collect the economic information at thirty sampling stations, organized in three large groups. However, this information does not assure that Greece will comply with the geographical disaggregation level, according to level 3 of Appendix I of the DCR. STECF is invited to comment on this issue.

SGRN comments : The Evaluators seem to have mis-understood the NP Proposal. The 30 sampling stations are the same as in modules D and E, and the data analysis is proposed to be done according to the geographical disaggregation levels required by DCR. The three "control groups" are just the 3 institutes that collect the data. The MS is reminded that level 3 disaggregation only applies to prices.

Evaluators' comments : Given the percentage of vessels of the sample there are serious doubts of meeting precision level 1. STECF is invited to comment on this issue.

SGRN comments : SGRN was informed that the analysis of the 2004 data (which was concluded after May 2005), showed that there were parts of the fleet for which the required precision levels were not met (because of low response rates from the ship owners), and that a decision was taken to increase sampling effort. Also see general comment on Sampling information and precision levels for economic data.

Evaluators' comments : Economic parameters defined in Appendix XVII of Regulation will be met. There are some issues that need to be considered. Greece does not provide details about expenditures paid by employers in relation to crew costs, or offer details about investment value (insured value). STECF is invited to comment on this issue.

SGRN comments : SGRN insists that the MS follows the provisions of the DCR, and that full details on the issue be given in future NP Proposals.

Module K

No comments.

Ireland

Module C

No comments.

Module D

Evaluators' comments : Regarding vessels of < 10 m, a pilot survey will be carried out for boats using passive gears in 2006. This survey will try to deliver data with the required precision levels. However, it is not stated if there is a pilot survey for boats using other gears. Ireland does not detail a methodology for the < 10 m segment data collection. Neither does Ireland specify to meet disaggregation levels. STECF to comment on this issue.

SGRN comments : SGRN was informed that the MS is carrying out a pilot sampling programme at national expense, and that it will make the results of this study available in its 2006 Technical Report. The rationale behind the pilot sampling programme is that the MS is still working to finalise the methodology and to gain the trust of the fishing industry. At present, the data are collected by a combination (i) of sales slips in fish processors and fisheries co-operatives, and (ii) on-board observer programmes. SGRN agrees with the approach taken by the MS, but insists that the outcome of the pilot programme be used to set up routine sampling programmes under Module D for the fleet segment < 10 m from 2007 onwards.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : Ireland pays skippers for self-sampling of discards. It is not clear if this is appropriated. To be evaluated by STECF.

SGRN comments : SGRN was informed that the payments only apply to samples collected under the ECONEPH project, which is a nationally funded project. SGRN was also informed that no such payments to skippers are made for the sea-going observer trips that are part of the Irish NP in fulfilment of the DCR. Also see general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

No comments.

Module G

Evaluators' comments : Irish NP indicates that Ireland will also take part in 2006 in the joint EU bluefin tuna tagging programme, funded by the Data Collection Regulation, tagging adult fishes in the Irish coastal waters between August and November, according to the goals established at the Tuna Tagging Planning Group held in Bari in April, 2005. Nevertheless no budget has been requested by Ireland within their NP. To be evaluated by STECF.

SGRN comments : Not in the remit of SGRN. Financial aspects of NP Proposal to be discussed between the Commission and the MS. Also see general comment on Tuna tagging in the present Report, and SGRN's comments on the Report of the Bari Meeting (Chapter 4 of the June 2005 Report of SGRN).

Evaluators' comments : Regarding Western IBTS, Ireland states that some new modifications in agreement with ICES IBTS Working Group has been applied to this survey, including 4 additional survey days for inter-calibration purposes. To be evaluated by STECF.

SGRN comments : SGRN notes that Ireland will comply with the recommendations of the ICES IBTSWG and therefore, it agrees with the approach taken by the MS.

Modules H & I

Evaluators' comments : The sampling levels are based on the average of landing for the years 1999-2001, and not over the most recent three years. If Ireland is using the most recent data to increase the budget (third paragraph, page 20 of the NSP) is not easy to understand why these data is not used for sampling effort calculations. To be evaluated by the STECF.

SGRN comments : In its NP Proposal, the MS states that it is cognisant of the revised DCR and the requirement to calculate sampling intensities on average catches over the most recent three years. However, the wrong table was inserted in the Proposal. SGRN insists that the MS takes the necessary steps to remedy this omission.

Module J

Evaluators' comments : Vessel segmentation will not fully be done according to Appendix III of Regulation. The offshore fleet will be segmented based on the overall length, however, inshore fleet will be segmented based on the number of pots fished.

SGRN comments : The table describing the fleet segmentation (in accordance with Appendix III of the DCR), has been omitted from the NP Proposal. SGRN insists that the MS takes the necessary steps to remedy this omission and to make sure that the DCR is correctly implemented. Also see general comment on Population coverage and segmentation for economic data collection.

Module K

Evaluators' comments : Ireland affirms that it will continue with pilot surveys (National Funded) in 2006 year to assess the annual value of economic parameters specified in Appendix XIX. However, no details are offered with respect to the calculation of the parameters itself, and the time-disaggregation.

SGRN comments : SGRN was informed that the MS collects data on the following parameters: raw materials, income, labour costs, prices/product, employment and capacity utilization. The MS has yet to finalize the methodologies for collecting the remaining economic parameters, as specified in Appendix XIX of the DCR. SGRN was informed that Ireland will submit a modified NP Proposal for Module K in January 2006, outlining in detail the methodologies that will be used to collect the required parameters. SGRN expects that this modified approach will include all parameters required by the DCR, and that it will be implemented in 2006. Also see general comment on Parameter definition for economic data collection on the processing industry.

Italy

Module C

No comments .

Module D

Evaluators' comments : Regarding the EP and according to its Proposal, Italy will gather information on fishing effort for long lines, pots and traps taking into account number of days. It is worth recalling that according to the rules of the EP (1639/2001), for fishing gear other than traps (in this case long lines) fishing effort could be measured by operations. In such cases, basic units will refer to fishing operations not to fishing days. So it seems that there is an inconsistency between the NP and the Regulation. STECF to comment on this issue.

SGRN comments : The Evaluators seem to have mis-interpreted the NP Proposal: point 2.2.2 (a) on page 7 of the Proposal states that fishing effort for longliners will be measured as the number of hooks x time at sea, as requested by the DCR.

Evaluators' comments : Italy points out that vessels lengths classes < 12 m will not be separated into 10 and 10-12 m; the remaining disaggregation levels assumed to be as in Appendix IV. STECF to comment on this issue.

SGRN comments : Given the fact that (i) it concerns the EP, (ii) data are collected by a sample survey, and (iii) the separation between < 10 and 10-12 m vessels is likely to lead to excessive costs, SGRN agrees on the approach taken by MS.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : Discard sampling objective is to estimate annual discards (weight and number) for each species listed in appendix XII of the bottom-trawl commercial fishing segment. As in the 2003 pilot study no initiatives seem to have been undertaken for all other fisheries. To be evaluated by STECF.

SGRN comments : SGRN was informed that, following negotiations between the MS and the Commission, Italy is conducting a discard sampling programme for all other fisheries in 2005.

Evaluators' comments : Discard sampling survey is based on a voluntary participation of fishers (Borges et al., 2004) (page 9 of the NP). The amendment states that observers should be accepted on any vessel in order to avoid biased estimates. Non conformity

SGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : EP includes the CPUEs data series for catches and effort for demersal trawl fishery, as recommended by the SGRN. However, costs appear to be high. It appears that the specific survey devoted to this action largely overlaps with the collection of effort (modules D) and catch data (module E), in addition to the collection of biological (module H&I) and economic data (J). Being the standard procedure that eligible cost for this module are exclusively those coming from the analysis of the series, whereas the catch and effort data making them derive from modules D and E, it should be clarified the degree of overlapping of these actions and the splitting of costs among them. To be evaluated by STECF.

SGRN comments : Not in the remit of SGRN. Financial aspects of NP Proposal to be discussed between the Commission and the MS.

Module G

Evaluators' comments : No comments.

SGRN comments : See general comments of the MEDITS survey, and on Tuna Tagging.

Modules H & I

Evaluators' comments : An explanation on the sampling methodology and detailed tables with the foreseen numbers of samples and individuals for the length and age samplings is provided, by species, type of fishing, time of the year, and geographical area. However, it is not possible to know whether the proposed sampling intensity is correct since Italy does not specify the average landings of the last three years. To be evaluated by the STECF.

SGRN comments : Apparently, this is a mistake / omission in the NP Proposal. SGRN insists that the MS provides this information in future NP submissions. Also see general comment on the Reference period for average landings for the Mediterranean.

Evaluators' comments : Italy does not give any data about discards and recreational fisheries, so it is impossible to know if DCR is being correctly implemented. To be evaluated by the STECF.

SGRN comments : Information on sampling of discards for length and age is given under Module E of the NP Proposal, as part of the discard survey. Under the same Module, the MS also states that biological data on the recreational fishery for bluefin tuna will be collected by weight and number. SGRN assumes that the DCR will be correctly implemented, but insists that full details on the issue be given in future NP Proposals.

Module J

No comments.

Module K

No comments.

Latvia

Module C

No comments.

Module D

Evaluators' comments : Fishing effort by type of technique data will be aggregated according to the required disaggregation levels as specified in Regulation 1639/2001, Appendix VIII and geographical disaggregation as required in Appendix I. Latvia states have a register for vessels < 12 m, but do not specify if it will be aggregated according to Appendix I and VIII. STECF to comment on this issue.

SGRN comments : Apparently, this is an incomplete explanation in NP. SGRN assumes that the DCR will be correctly implemented, but insists that full details on the issue be given in future NP Proposals.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : For the collection of biological data on discards and catches at sea LATFRA is partly obliged to rely on the voluntary willingness of the fishing companies to take the scientific observer on board, therefore samples cannot be considered as truly random. This is against DCR: " on-board observers should be accepted on any vessels in order to avoid biased estimates " (in the amendment). Non conformity.

SGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : As last year, Latvia will include in their MP the CPUE data series for herring stocks in the Gulf of Riga and for salmon for both coastal and off-shore fishery. Additionally, Estonia includes two CPUE series for gillnet and trawl fisheries of cod. Estonia states that in 2005 ICES Baltic Fisheries Assessment Working Group used CPUE data of two countries for the assessment of cod in Sub-divisions 25-32. In the next years Latvian data could be used together with data of other countries. To be evaluated by STECF.

SGRN comments : See general comment on CPUE data series from new MS in the December 2004 Report of SGRN. SGRN considers that the NP Proposal establishes the usefulness of the CPUE data series for cod, and therefore concludes that it should be eligible under the MP.

Module G

No comments.

Modules H & I

Evaluators' comments : Like in 2005, disaggregation exceeds Regulation and almost all the stocks sampled are over-sampled again in the MP and in the EP, to ensure the quality of the stocks assessments.

SGRN comments : SGRN considers that "over-sampling" is not against the spirit of the DCR, as long as it is justified to achieve necessary precision level for stock assessment purposes.

Evaluators' comments : Latvia has started to collect biological data for Pandalid shrimp from NAFO Area 3M in 2005. In 2006 the sampling will continue, but not for discards. Latvia says that " the discarded shrimps are compressed and deformed specimens which are not possible to measure ". To be evaluated by STECF.

SGRN comments : SGRN agrees with the approach taken by the MS, but recommends that measurements be made of the volume and numbers of shrimps discarded. SGRN was informed that length measurements of the discards of all other species listed in Appendix XII of the DCR will be performed.

Evaluators' comments : In the case of salmon samples from offshore fishery, the sex is not determined because sampling is performed in fishing harbours on gutted fish, although they have observers on board for discards. To be evaluated by STECF.

SGRN comments : Apparently, this is a mistake in the NP Proposal. SGRN insists that the MS takes the necessary steps to remedy this mistake and to make sure that the DCR is correctly implemented.

Module J

Evaluators' comments : It is stated that total employment will be obtained in terms of the number of persons employed either full or part-time. There is nothing about a FTE, which is a requirement of the DCR. STECF is invited to comment on this issue.

SGRN comments : Apparently, this is incomplete explanation in the NP Proposal. SGRN was informed that part-time employees will be made equivalent FTE. Also see general comment on the Definition of "employment".

Evaluators' comments : It is not possible to assure the precision level 1 of Regulation, given the voluntary aspect of questionnaires. STECF is invited to comment on this issue.

SGRN comments : SGRN was informed that, at present, voluntary questionnaires are the only possible way to obtain fishery economic data in Latvia. Also see general comment on Sampling information and precision levels for economic data.

Module K

No comments.

Lithuania

Module C

No comments.

Module D

No comments.

Module E

- LANDINGS

No comments.

- DISCARDS

Evaluators' comments : There is no authority in Lithuanian law, which gives the possibility to enforce the fishermen to have observers onboard. Therefore, only vessels where the skipper has agreed in having observers onboard will be sampled (page 13 of the NP). The masters shall accept observers on board and cooperate with them [CR (EC) No 2371/2002]. Non conformity.

SGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.

- RECREATIONAL FISHERIES

No comments.

- OTHER ISSUES

No comments.

Module F

Evaluators' comments : Lithuania states that they do not collect CPUE data for stock assessment but that from 2006 they will start data collection like pilot study for further background. To be evaluated by STECF.

SGRN comments : See general comment on CPUE data series from new MS in the December 2004 Report of SGRN.

Module G

Evaluators' comments : Lithuania states: " Lithuania will ensure the continuation of previous surveys of stocks with its national programmes, using research-vessel "Darius", which will execute all necessary surveys at open sea. Twice per year (in spring and autumn), it will perform acoustic surveys of sprat and Baltic herring stocks within Lithuanian economic area ", but very short information about the sampling area or sampling procedure in different surveys is provided. Likewise, no mention about modification in the survey effort or sampling design is made. These are neither coordinated with other countries, which probably make them less useful than they otherwise could be. Non conformity.

On the other hand, Lithuania declares that the BITS will be conducted twice during a year, in the first quarter (2 days at sea, 5 trawl stations) and in the fourth quarter (2 days at sea, 5 trawl stations) with research vessel "Darius". The surveys cover LEEZ area. This is very few hauls. This can hardly be an optimal way of using resources compared to let other countries vessels do a few extra days. At least money to buy and maintain TV3 trawls can be avoided. The same can be said regarding the acoustic survey participation. To be evaluated by STECF.

SGRN comments : With regards to the a