Commission staff working document - Scientific, Technical and Economic Committee for Fisheries (STECF) - Analysis of derogations and non-conformities of Member States’ data collection National Programme Proposals for 2006 - Brussels, December 2005
Date: 2007-04-02
Institutions: European Commission
Subjects: EU Member State, application of EU law, conservation of fish stocks, derogation from EU law, fisheries policy, fishery management, fishing regulations, scientific committee (EU)













EUR-Lex - 52007SC0470 - EN






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52007SC0470

Commission staff working document - Scientific, Technical and Economic Committee for Fisheries (STECF) - Analysis of derogations and non-conformities of Member States’ data collection National Programme Proposals for 2006 - Brussels, December 2005  /* COM/2007/0470 final */  








SEC(2007) 470COMMISSION STAFF WORKING DOCUMENTSCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF)Analysis of derogations and non-conformitiesof Member States’ data collection National ProgrammeProposals for 2006Brussels, December 2005The Scientific, Technical and Economic Committee for Fisheries (STECF) evaluatedand endorsed this report by correspondence in January 2006This 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 CONTENTS1. Introduction. 32. STECF comments 33. STECF Conclusions and Recommendations 34. Annex I: SGRN Report 51 IntroductionThe 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 CommentsSTECF reviewed the SGRN report on Analysis of derogations and non-conformitiesof 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 RecommendationsSTECF agrees with and endorses the observations, comments and recommendations contained in the SGRN report on Analysis of derogations and non-conformitiesof 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 ICOMMISSION STAFF WORKING PAPERSCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF)SUB-GROUP ON RESEARCH NEEDS (SGRN)Analysis of derogations and non-conformitiesof Member States’ data collection National ProgrammeProposals for 2006Brussels, 28 November - 2 December 2005TABLE OF CONTENTS1 Introduction 91.1 List of participants 91.2 Terms of Reference 92 Evaluation of derogations and non-conformities 92.1 Evaluation process and structure of the report 92.2 General comments 92.2.1 Comments not linked to particular Modules of the DCR 92.2.2 Module D 92.2.3 Module E 92.2.4 Module F 92.2.5 Module G 92.2.6 Modules H and I 92.2.7 Modules E, H and I 92.2.8 Module J 92.2.9 Module K 92.3 Belgium 92.3.1 Module C 92.3.2 Module D 92.3.3 Module E 92.3.4 Module F 92.3.5 Module G 92.3.6 Modules H & I 92.3.7 Module J 92.3.8 Module K 92.4 Cyprus 92.4.1 Module C 92.4.2 Module D 92.4.3 Module E 92.4.4 Module F 92.4.5 Module G 92.4.6 Modules H & I 92.4.7 Module J 92.4.8 Module K 92.5 Denmark 92.5.1 Module C 92.5.2 Module D 92.5.3 Module E 92.5.4 Module F 92.5.5 Module G 92.5.6 Modules H & I 92.5.7 Module J 92.5.8 Module K 92.6 Estonia 92.6.1 Module C 92.6.2 Module D 92.6.3 Module E 92.6.4 Module F 92.6.5 Module G 92.6.6 Modules H & I 92.6.7 Module J 92.6.8 Module K 92.7 Finland 92.7.1 Module C 92.7.2 Module D 92.7.3 Module E 92.7.4 Module F 92.7.5 Module G 92.7.6 Modules H & I 92.7.7 Module J 92.7.8 Module K 92.8 France 92.8.1 Module C 92.8.2 Module D 92.8.3 Module E 92.8.4 Module F 92.8.5 Module G 92.8.6 Modules H & I 92.8.7 Module J 92.8.8 Module K 92.9 Germany 92.9.1 Module C 92.9.2 Module D 92.9.3 Module E 92.9.4 Module F 92.9.5 Module G 92.9.6 Module H & I 92.9.7 Module J 92.9.8 Module K 92.10 Greece 92.10.1 Module C 92.10.2 Module D 92.10.3 Module E 92.10.4 Module F 92.10.5 Module G 92.10.6 Modules H & I 92.10.7 Module I 92.10.8 Module J 92.10.9 Module K 92.11 Ireland 92.11.1 Module C 92.11.2 Module D 92.11.3 Module E 92.11.4 Module F 92.11.5 Module G 92.11.6 Modules H & I 92.11.7 Module J 92.11.8 Module K 92.12 Italy 92.12.1 Module C 92.12.2 Module D 92.12.3 Module E 92.12.4 Module F 92.12.5 Module G 92.12.6 Modules H & I 92.12.7 Module J 92.12.8 Module K 92.13 Latvia 92.13.1 Module C 92.13.2 Module D 92.13.3 Module E 92.13.4 Module F 92.13.5 Module G 92.13.6 Modules H & I 92.13.7 Module J 92.13.8 Module K 92.14 Lithuania 92.14.1 Module C 92.14.2 Module D 92.14.3 Module E 92.14.4 Module F 92.14.5 Module G 92.14.6 Modules H & I 92.14.7 Module J 92.14.8 Module K 92.15 Malta 92.15.1 Module C 92.15.2 Module D 92.15.3 Module E 92.15.4 Module F 92.15.5 Module G 92.15.6 Modules H & I 92.15.7 Module J 92.15.8 Module K 92.16 Netherlands 92.16.1 Module C 92.16.2 Module D 92.16.3 Module E 92.16.4 Module F 92.16.5 Module G 92.16.6 Modules H & I 92.16.7 Module J 92.16.8 Module K 92.17 Poland 92.17.1 Module C 92.17.2 Module D 92.17.3 Module E 92.17.4 Module F 92.17.5 Module G 92.17.6 Modules H & I 92.17.7 Module J 92.17.8 Module K 92.18 Portugal 92.18.1 Module C 92.18.2 Module D 92.18.3 Module E 92.18.4 Module F 92.18.5 Module G 92.18.6 Modules H & I 92.18.7 Module J 92.18.8 Module K 92.19 Slovenia 92.19.1 Module C 92.19.2 Module D 92.19.3 Module E 92.19.4 Module F 92.19.5 Module G 92.19.6 Modules H & I 92.19.7 Module J 92.19.8 Module K 92.20 Spain 92.20.1 Module C 92.20.2 Module D 92.20.3 Module E 92.20.4 Module F 92.20.5 Module G 92.20.6 Modules H & I 92.20.7 Module J 92.20.8 Module K 92.21 Sweden 92.21.1 Module C 92.21.2 Module D 92.21.3 Module E 92.21.4 Module F 92.21.5 Module G 92.21.6 Module H & I 92.21.7 Module J 92.21.8 Module K 92.22 United Kingdom 92.22.1 Module C 92.22.2 Module D 92.22.3 Module E 92.22.4 Module F 92.22.5 Module G 92.22.6 Modules H & I 92.22.7 Module J 92.22.8 Module K 93 Data and sampling requirements for European eel 94 Guidelines for National Programme Proposals 95 Revised version of the Guidelines for the Technical Reports 96 Appointment of a new chair for SGRN 9IntroductionList of participantsSTECF membersMax Cardinale (chair of eel sub-group)Peter ErnstInvited expertsEnrico ArneriClaude Belpaire (part-time)Liam Costello (part-time)Willem Dekker (part-time)Ole FolmerRob GriftRyszard GrzebielecJordi GuillenAaron Hatcher (chair of economists sub-group)Myrto IoannouErnesto Jardim (part-time)Rainer KlepperManos KoutrakisPaloma MartinHelen McCormickRichard MillnerArina MotovaAndrew NewtonMike Pawson (part-time)Wojciech Pelczarski (part-time)Maris PlikshsJukka PönniIñaki Quincoces AbadFrank Redant (chair)Evelina SabatellaJochen Trautner (part-time)Joël VigneauEuropean CommissionOlle Hagström, DGFish (part-time)Philippe Moguedet, DGFish (part-time)Juan-Pablo Pertierra, DGFish (part-time)Iain Shepherd, JRC (part-time)Robert Ziegler, JRCTerms of ReferenceThe 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-conformitiesEvaluation process and structure of the report-  Evaluation processAs 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-conformitiesSGRN'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 commentsComments not linked to particular Modules of the DCR-  On the Preparation and the logistics of SGRN meetingsSGRN 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 recommendationsThe 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 gearsSGRN 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 abroadThe 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 9.1Auction 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 11.1Without 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 15.1Before 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 15.2The 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 statusSeveral 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 surveyThe 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 taggingIn 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 MediterraneanThe 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 requirements2006 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 vesselsIn 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 collectionSGRN 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 dataSGRN 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 valueSGRN 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 industrySGRN 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.BelgiumModule CEvaluators' 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 DEvaluators' 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-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESEvaluators' 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 FEvaluators' 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 GNo comments.Modules H & IEvaluators' 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 JEvaluators' 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 KNo comments.CyprusModule CNo comments.Module DNo comments.Module E-  LANDINGSEvaluators' 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.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FNo comments.Module GEvaluators' 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 & IEvaluators' 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 JEvaluators' 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 KEvaluators' 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.DenmarkModule CNo comments.Module DEvaluators' 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-  LANDINGSNo Comments.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' 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 GEvaluators' 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 & IEvaluators' 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 JEvaluators' 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 KEvaluators' 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.EstoniaModule CNo comments.Module DNo comments.Module E-  LANDINGSNo comments.-  DISCARDSNo comments.-  RECREATIONAL FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' 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 GNo comments.Modules H & IEvaluators' 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 JEvaluators' 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 KEvaluators' 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.FinlandModule CNo comments.Module DEvaluators' 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 ENo comments.Module FEvaluators' 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 GEvaluators' 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 & IEvaluators' 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 JEvaluators' 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 KEvaluators' 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.FranceModule CNo comments.Module DEvaluators' 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-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FNo comments.Module GEvaluators' comments : No comments.SGRN comments : See general comments on the MEDITS survey, and on Tuna tagging.Modules H & IEvaluators' 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 JEvaluators' 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 KEvaluators' 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.GermanyModule CNo comments.Module DNo comments.Module E-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 FISHERIESEvaluators' 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 ISSUESNo comments.Module FEvaluators' 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 GNo comments.Module H & INo comments.Module JEvaluators' 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 KEvaluators' 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.GreeceModule CEvaluators' 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 DNo comments.Module E-  LANDINGSEvaluators' 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.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' 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 GEvaluators' comments : No comments.SGRN comments : See general comments on the MEDITS survey, and on Tuna tagging.Modules H & IEvaluators' 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 IEvaluators' 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 JEvaluators' 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 KNo comments.IrelandModule CNo comments.Module DEvaluators' 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-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FNo comments.Module GEvaluators' 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 & IEvaluators' 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 JEvaluators' 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 KEvaluators' 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.ItalyModule CNo comments .Module DEvaluators' 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-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 conformitySGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.-  RECREATIONAL FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' 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 GEvaluators' comments : No comments.SGRN comments : See general comments of the MEDITS survey, and on Tuna Tagging.Modules H & IEvaluators' 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 JNo comments.Module KNo comments.LatviaModule CNo comments.Module DEvaluators' 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-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' 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 GNo comments.Modules H & IEvaluators' 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 JEvaluators' 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 KNo comments.LithuaniaModule CNo comments.Module DNo comments.Module E-  LANDINGSNo comments.-  DISCARDSEvaluators' 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' 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 GEvaluators' 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 acoustic surveys of sprat and Baltic Sea herring, SGRN notes that this survey is co-ordinated by the ICES WGBIFS, and that all participating countries follow an agreed methodology. Therefore, SGRN assumes that the surveys will be executed as planned and foreseen by WGBIFS.With regards to the BITS survey, SGRN notes that this is also an internationally co-ordinated survey and that Lithuania will follow the same approach and methodology as the other countries participating in the survey.Modules H & IEvaluators' comments : Stocks covered, disaggregation and precision levels are correct, but herring, cod and sprat stocks are over-sampled. Flounder landing data is not available, so it is not possible to know if the sampling intensity is correct. 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. SGRN insists that the MS provides the necessary information on its flounder landings and sampling levels.Module JEvaluators' comments : Lithuania will cover the economic parameters specified in Appendix XVII. However, in the Proposal it is stated that there are several difficulties in obtaining the capital investment, the financial situation, and the employment data. STECF is invited to comment on this issue.SGRN comments : SGRN recommends that the MS follows the provisions of the DCR. Also see general comments on the Estimation of capital value, and on the Definition of "employment".Module KNo comments.MaltaModule CNo comments.Module DNo comments.Module E-  LANDINGSNo comments.-  DISCARDSEvaluators' comments : The vessels will not be sampled randomly from all vessels performing a given fishery but only from the vessels where the skipper has agreed beforehand in having observers on board (page 14 of the NP). On-board observers should be accepted on any vessel in order to avoid biased estimates [CR (EC) No 1581/2004]. Non conformity.SGRN comments : See general comment on Accessibility and compensation of commercial fishing vessels.-  RECREATIONAL FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FEvaluators' comments : Malta states that they will continue to enhance its time series of CPUE data making it readily available for any analysis which may be requested at any time. These data are being collected since 2001. Funding is requested. To be evaluated by STECF.SGRN comments : SGRN notes that there are no details on the CPUE data series that the MS intends to collect. Details to be provided by the MS.Module GEvaluators' comments : Two additional surveys will be included in the Extended Program of Maltese NP.-  GRUND survey; Mediterranean, 37(1,2).-  Juvenile acoustic survey.Nevertheless, regarding the Juvenile acoustic survey, no survey classified as Priority 2 is identified which such name in the Appendix XIV of Regulation 1639/2001 or in the amended revision (Regulation 1581/2004). Non conformity.SGRN comments : SGRN agrees with the Evaluators that there is no Juvenile acoustic survey in the DCR.Additional SGRN comment : Also see general comments on the MEDITS survey, and on Tuna tagging.Modules H & INo comments.Module JNo comments.Module KNo comments.NetherlandsModule CNo comments.Module DNo comments.Module E-  LANDINGSEvaluators' comments : Eel are not dealt with in the text or tables and are proposed to be dealt with in 2006 when more guidelines are available. 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.-  DISCARDSEvaluators' comments : Discard sampling is restricted to the two most important fleet segments, the beam trawl and the pelagic fleet, that are responsible of over 90% of the landings. In order to provide a general overview of the discard practices SGRN had suggested in the first revision of the pilot study on discards in May 2004 that the discard sampling should be extended to other components of the demersal fleet, but the 2005 and 2006 NP Netherlands still limiting operations to these two fleet. Probably Netherlands considers that the discards sampling is representative as it is now, but it should explain it. To be evaluated by STECF.SGRN comments : SGRN recognizes that the MS does not want to "dilute" the available budget over too many fleet segments and that the sampling of the beam trawler and pelagic trawler fleets is representative, but has concerns about the representativeness of the programme for the other fleets. In 2002, SGRN suggested that the Netherlands should undertake pilot studies on the segments of the demersal and pelagic fleet that were not included in the initial pilot study and that might need to be included in future routine discard sampling programmes.Recent information on discard levels in the Nephrops directed fleet, for example, shows that it is important to monitor discarding in this fleet. Moreover, the Netherlands is responsible for a large part (55-65 %) of the Nephrops landings from the Southern North Sea (FU 5). SGRN also notes that Belgium is currently facing serious problems to continue its discard sampling program on the Nephrops fisheries in FU 5 (see section on Belgium in the present Report). Therefore, 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.For the otter trawl fishery, SGRN insists that the Netherlands set up a routine discard sampling programme without further delay.Evaluators' comments : In principle, the vessels to be monitored will be selected randomly from a large number of vessels identified in close co-operation with the Steering Groups. The Dutch law gives no provision to oblige vessels to take observers onboard. Therefore, the vessels cannot be sampled truly random from the whole fleet (page 24 of the NP). On-board observers should be accepted on any vessel in order to avoid biased estimates [CR (EC) Nº 1581/2004]. Non conformity.SGRN comments : SGRN was informed that the Netherlands has made considerable efforts to improve co-operation with the fishing industry through the so-called F-project and that the Netherlands will try to get access to all fleet segments through collaboration with the industry's representatives. Also see general comment on Accessibility and compensation of commercial fishing vessels.-  RECREATIONAL FISHERIESEvaluators' comments : A two year pilot study, initiated in 2005 to estimate the amount of catches by the recreational fishery will be continued in 2006. Cod is included in this study. There is the suggestion of including eel sampling as a pilot study (page 32 of the NP). 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.-  OTHER ISSUESNo comments.Module FEvaluators' comments : Regarding the EP, The Netherlands includes an activity to update the catch, effort and CPUE data on a less aggregate level than is required in the MP for a number of selected species on an annual basis. To be evaluated by STECF.SGRN comments : SGRN agrees with the approach taken by the MS because this activity is under the EP of the DCR and according to Chapter III of the Annex of the DCR " any study covering the definition of indexes of abundance or of effective effort on the basis of detailed catch and effort data coming from the commercial fleets is eligible under the extended programme. "Module GNo comments.Modules H & IEvaluators' comments : Sampling intensity is not following the Regulation:Area | Species | Comments | STECF |Recurrent | IV, VIId | Whiting | Over-sampled | Accepted |Recurrent | IV, VIId | Turbot | Over-sampled (to maintain precision level) | Accepted |Recurrent | IV, VIId | Rays and Skates | Over-sampled | Accepted |Recurrent | IV, VIId | Brill | Over-sampled | Accepted |New | IIa, IVa, Vb, VIa, VIIa-c,e-k, VIIIabde, X | Horse mackerel | Over-sampled |New | VIa, VIaN, VIaS, VIIbc, VIIbc, VIIa, VIIj | Herring | Over-sampled |New | II, V, VI, VII, VIII, XII, XIV | Blue whiting | Over-sampled |New | IV, VIId | Dab | Under-sampled |SGRN comments : SGRN recognizes that the way in which the Netherlands samples herring, horse mackerel and blue whiting, lengths of these species are automatically "over-sampled". This is because the lengths of all fish in a sample are measured, before fish are selected for biological sampling.Regarding dab, the Evaluators seem to have mis-read the NP Proposal. The numbers proposed for dab in Table 6 of the Dutch NP Proposal conform to the requirements of the DCR.Module JEvaluators' comments : Netherlands will not fully comply with the Appendix III of the DCR. Fleet population is divided into the inactive and active vessels, being inactive the vessels with gross revenue under €50,000 (which represent almost the 60% of the total vessels, given the information in table on page 26). Netherlands only takes into account the so-called active vessels as part of the sampling plan which is contrary to the SGECA recommendations. STECF is invited to comment on this issue.SGRN comments : SGRN was informed that in 2005, the Netherlands executed a pilot study on the characteristics of "inactive vessels" to assess the consequences of including these vessels in economic models. SGRN was informed that the preliminary results show that the group of 456 inactive vessels comprises two sub-categories: vessels used for aquaculture (92 vessels) and vessels used for fisheries (364 vessels). The vessels used for aquaculture have only recently (2003) come under the EU-licensing system and for these vessels, economic data collection will start this year, covering the year 2004 onwards. The latter category is of little economic importance: it only added 1.5 % to the total value of the landings of the Dutch fleet and had an average value of landings of less than € 10,000. Also the estimated employment and investment – both less than 5 % of the total of the Dutch fleet – added little to the economic performance of the Dutch fleet. Nevertheless, SGRN insists that the MS follows the provisions of the DCR and that all vessel categories be included in the data collection process. Also see general comment on Population coverage and segmentation for economic data collection.Evaluators' comments : The investment value is not calculated according to the DCR which specifies the insurance value as preferred. The investment value is obtained from the actual purchase price where possible. As the second best option, the insured value is adopted, and finally valuation by expert knowledge could be seldom used. STECF is invited to comment on this issue.SGRN comments : See general comment on the Estimation of capital value.Evaluators' comments : The financial position for the pelagic segment is confidential, which implies that it is not possible to assure the full commitment to the DCR. STECF is invited to comment on this issue.SGRN comments : SGRN was informed that the pelagic segment of the MS only comprises three companies and hence, financial information cannot be published because privacy cannot be guaranteed. Moreover, SGRN was informed that it is very difficult to obtain financial information on fishing activities, because these companies own both national and foreign vessels and also deploy various other economic activities. SGRN understands the MS's concerns over the privacy aspects but, in general, does not consider these to be a valid argument for not collecting the information. Therefore, SGRN insists that the MS follows the provisions of the DCR.Evaluators' comments : Netherlands affirms that sampling effort will be increased to satisfy the precision level for the segment of demersal trawlers and seiners under 24 m. However, no statistical information is provided to check this. In addition, in the period 2003-2004 the precision level 1 was not met. STECF is invited to comment on this issue.SGRN comments : See general comment on Sampling information and precision levels for economic data.Module KEvaluators' comments: Netherlands will not cover requirements of the DCR, in particular, some of the economic parameters specified in Appendix XIX.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.PolandModule CNo comments.Module DNo comments.Module E-  LANDINGSEvaluators' comments : Mis-reporting of cod (black landings) is suspected to be a major problem in Poland. To be evaluated by STECF.SGRN comments : SGRN considers that mis-reporting (of cod) concerns not only the Polish landings, but that in general, this is a problem which is not in the remits of SGRN.-  DISCARDSEvaluators' comments: Ship-owners will be compensated for accommodation (see financial forms). According to the CR (EC) No 2371/2002 and the amendment 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 FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FNo comments.Module GNo comments.Modules H & IEvaluators' comments : Poland asks for derogation for biological sampling of foreign landings landed in Polish ports in 2006 because these landings are unknown and probably of small quantity. To be evaluated by STECF.SGRN comments : Following the general principles on international co-operation with regards to biological sampling of foreign flag vessels (as agreed by several RCMs), SGRN suggests that Poland enters into bilateral negotiations with the flag states concerned and agrees with them on a system of task sharing for sampling these landings.Evaluators' comments : Poland expects to exchange the roundnose grenadier quota with other EU countries, thus Poland request derogation from sampling this specie. To be evaluated by STECF.SGRN comments : SGRN agrees with the approach taken, but in case the exchange of quota should not happen, Poland is expected to sample roundnose grenadier according to the provisions of the DCR.Evaluators' comments : It’s not clear from the NSP what is going to be done and the methodologies to be used under Module I. To be evaluated by STECF.SGRN comments : SGRN was informed that, within the RCM Baltic Sea, there is an agreement to collect the "Other biological parameters" under Module I on an annual basis (instead of on a triennial basis as required by the DCR). SGRN expects that the MS will comply with this agreement. SGRN also expects the MS to provide full details on its methodology for Module I in its 2005 Technical Report and in all further NP Proposals.Module JNo comments.Module KNo comments.PortugalModule CNo comments.Module DNo comments.Module E-  LANDINGSEvaluators' comments : Actual situation is not well known in ICES sub-division IXa.SGRN comments : The wide and unclear nature of this comment makes it difficult to understand the Evaluators' message. SGRN urges the Evaluators to be specific and clear on their comments. The Evaluators also seem to have mis-understood the NP Proposal.The Portuguese NP Proposal includes a similar comment related to small scale fisheries (Section E), and it mainly highlights the difficulties of getting information for these vessels based on sales notes. In Section 1.a.ii of the Proposal, a sampling programme for small scale fisheries is presented, which is supposed to provide information on landings for these vessels. SGRN agrees with the approach taken by the MS.Evaluators' comments : No information is provided about Portugal landings abroad or other flags vessels landing in Portugal.SGRN comments : See general comment on Reporting of landings abroad.-  DISCARDSNo comments.-  RECREATIONAL FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FNo comments.Module GEvaluators' comments : Portugal also includes in their MP the Nephrops survey (2nd Q.; IXa), classified with priority 2 both in the Appendix XIV of Regulation 1639/2001 and in the further revision (Regulation 1581/2004). Portugal states that " the assessments performed in the period 1997-2004 indicate that the Iberian Nephrops stocks are overexploited, and the biomass and recruitment levels are very low. For the years 2002-2004, the WG on Nephrops stocks recommended 0 t TAC for the FUs 26 to 29 of the Division IXa, corresponding to West Galicia, North Portugal, SW and S Portugal. Considering these results, STECF has proposed a recovery plan for the Iberian Nephrops stocks. This survey initially of priority 2 was moved to priority 1 because since 2005 will be under a recovery plan ." So, if it is so, the inclusion of this survey by Portugal within their MP is OK.SGRN comments : See general comment on the Upgrade of Priority 2 surveys to Priority 1 status.Additional SGRN comment : Also see general comment on Tuna tagging.Modules H & IEvaluators' comments : Portugal is using the NP 2002 landing data and not the last recent three years data, like the Regulation oblige.SGRN comments : The reference made to the 2002 NP in the 2006 Proposal is the following: " The Portuguese sampling programme for the composition of the landings by length and age, by species, port, month and type of gear presented in this report was specified in NP2002. The sampling effort previewed is expected to produce estimates with a high precision for the main exploited ages, as requested by the revised Regulation ." Portugal is not using the 2002 landings to define its sampling levels, but the sampling methodology specified in the 2002 NP, which is based on an analysis of precision levels achieved. SGRN agrees with the approach taken by the MS.Evaluators' comments : Pagellus bogaraveo and Pagellus acarne are not included in the appendix XV (section H) of the Regulation.SGRN comments : These species are grouped under Sparidae in the DCR. SGRN agrees with the approach taken by the MS.Evaluators' comments : Without knowing the number of fish to be length per sample (tables H1 and H4), it is not possible to know if the sampling intensity is correct.SGRN comments : This is an omission in the NP Proposal. SGRN was informed that a corrected version of the relevant table is available and that the DCR will be correctly implemented.Module JEvaluators' comments : For Madeira based fleet, the included population will be vessels registered in Madeira. The data source for collecting economic information is based on questionnaires. The questionnaires will cover the 15% of active fishing vessels. This information is not enough to check if the precision level 1 will be reached.SGRN comments : Precision levels for questionnaires are difficult to foresee and the sampling levels were defined on an ad hoc basis using information available for the fleet. SGRN was informed that sampling effort will be adjusted in agreement with the precision levels obtained during the implementation of the programme. Also see general comments on Population coverage and segmentation for economic data collection, and on Sampling information and precision levels for economic data in the present Report, and on Precision levels in general in the December 2004 Report of SGRN.Module KNo comments.SloveniaModule CNo comments.Module DEvaluators' comments : Slovenia points out that within the Slovenia management system even < 10 m boats have the obligation to present logbooks. According to Slovenia’s plan, Slovenia will be able to deliver fishing effort data for all vessels on a precision level of 3. However, it is not clear which the source for fuel consumption data collection is. According to the plan, logbooks do not contain fuel consumption data. STECF to comment on this issue.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.Module E-  LANDINGSEvaluators' comments : No mention to the other flag vessels. 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. Also see general comment on Reporting of landings abroad.-  DISCARDSNo comments.-  RECREATIONAL FISHERIESNo comments.-  OTHER ISSUESEvaluators' comments : A list of conversion factors has not been prepared yet. Non conformity.SGRN comments : List of conversion factors to be provided by MS.Module FEvaluators' comments : Slovenia declares that CPUE data of commercial fishery are available from 2004 when logbooks were introduced. The only source of CPUE data from 1995 onwards is the Slovenian bottom-trawl survey performed by rented commercial bottom trawler. Slovenia requests for funding in this module. To be evaluated by STECF.SGRN comments : SGRN considers that CPUE data series derived from surveys are not compatible with commercial fisheries.Module GEvaluators' comments : No information is provided about the sampling area, sampling procedure or modifications in the survey effort or sampling design. Non conformity.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.Modules H & IEvaluators' comments : It is mentioned in the NP that, according to the registered landings data, the only species to be considered in the sampling program would be Sardina pilchardus . However, since no data on landings is provided in modules H&I, it is impossible to know whether DCR is going to be properly implemented. 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.Module JNo comments.Module KEvaluators' comments : The data requested by the DCR are partially collected by their Statistical Office, but some economic parameters are not covered such as the raw material, fixed costs, financial position and capacity utilization. A pilot survey will be conducted to collect this economic information in 2006. STECF is invited to comment on this issue.SGRN comments : SGRN agrees with the approach taken by the MS. Also see general comment on Pilot studies by new MS in December 2004 Report of SGRN.SpainModule CEvaluators' comments : The data will be collected for each fleet segment. But, the fleet segments have not been defined in the Spanish program. STECF to comment on this issue.SGRN comments : The Evaluators seem to have mis-interpreted the NP Proposal. From the text on page 14 of the NP Proposal, it is clear that Spain is using the segmentation from Regulation 1581/2004, Appendix III.Module DEvaluators' comments : All parameters will be collected except the fuel consumption. STECF to comment on this issue.SGRN comments : SGRN insists that the MS follows the provisions of the DCR.Module E-  LANDINGSEvaluators' comments : Not many information is provided about Spanish vessels landing in other countries or other flags vessels landing in Spain. To be evaluated by STECF.SGRN comments : See general comment on Reporting of landings abroad.Evaluators' comments : For vessels less than 10 metres information is obtained through sales notes, where no information is given either for fishing area or for the gear used. It will be then difficult to assign landings to one sub-area when the trip was conducted over two sub-areas. Furthermore, Spain will face difficulties when the DCR will move toward a fleet based approach. To be evaluated by STECF.SGRN comments : SGRN considers this to be a general problem when vessels are fishing on the boundary of adjacent fishing areas. In view of the limited action radius of vessels < 10 m, however, SGRN considers this to be a relatively minor problem in the case of small vessels.With the expected shift of the DCR towards a fleet based system of data collection, no further difficulties are to be expected, since Spain is collecting the landing data and has a record of the gear(s) that is (are) licensed for each vessel.-  DISCARDSEvaluators' comments : The list of species given in the Spanish program for 2006 does not fit the DCR obligation. To be evaluated by STECF.SGRN comments : The only species that seems to be missing in the NP Proposal is megrim ( Lepidorhombus whiffiagonis ). Spain however, is collecting discard information on this species and the data are used in the ICES WGHMM.Evaluators' comments : A table has been included to show the sampling effort by area. The coverage for the ICES area and sub-areas seems to be very low with respect to the Spanish fleet activity and may be not scientifically appropriate in order to be able to obtain accurate information for the discards. To be evaluated by STECF.SGRN comments : See general comment on Precision levels for discard estimates in the December 2004 Report of SGRN.-  RECREATIONAL FISHERIESEvaluators' comments : No information is provided. To be evaluated by STECF.SGRN comments : SGRN assumes that the DCR will be correctly implemented, since under Module E, Landings, Spain states that " Spanish fleet catch and landing data is gathered and processed globally and disaggregated in accordance with the parameters laid down in the minimum programme. Furthermore, data concerning discards will be obtained for the stocks listed in Appendix XII, and likewise data concerning catches of recreational fisheries referred to in Appendix XI." SGRN insists that full details on the issue be given in future NP Proposals.-  OTHER ISSUESEvaluators' comments : No detailed and technical information is provided concerning the international co-operation (UK, France, Portugal and the Netherlands). To be evaluated by STECF.SGRN comments : Details to be provided by MS.Module FNo comments.Module GEvaluators' comments : IBTS surveys: two surveys are carried out by Spain, one in the Cantabrian Sea, ICES Sub areas VIIIc, IXa (30 days; 120 hauls it means 4 hauls/day) and the other in the Gulf of Cadiz, ICES Sub-area IXa (20 days, 40 hauls it means 2 hauls/day). The duration of the second survey seems inappropriate when comparing the areas covered (the same vessel is used for both surveys, and the Gulf of Cadiz is much smaller than the Northern coast of Spain). For information, there is also a demersal survey carried out in March (ARSA survey) in the same area using the same vessel (12 days, 40 hauls).There is no further explanation concerning the very low number of hauls achieved each day in the Gulf of Cadiz during the October/November survey. To be evaluated by STECF.SGRN comments : To be clarified by MS.Evaluators' comments : NAFO area: two surveys are planned by Spain in this area. The Flemish Cap survey (priority 1) and the 3NO Groundfish Survey (priority 2) using the same vessel (Vizconde de Eza):-  Flemish Cap survey: July/August NAFO area 3M, duration of this survey of 30-36 days (for 120 hauls); this survey was extended to cover deep water area (to target Greenland Halibut in the Flemish pass and the NAFO area 3L) and STECF accepted the duration to be increased to 53 days (195 hauls).-  3NO Groundfish survey: May, June, August NAFO area 3NO +3L; duration 52 days (25+26) (for 120 +70 hauls).STECF accepted the extension of the coverage (and the duration of the survey) of the Flemish Cap survey as NAFO area 3L will be included. It appears now that this survey covers only the NAFO area 3M.The duration of the 3NO Groundfish survey does not fit with the Regulation requirements (27 days). Concerning the extension of the 3NO Groundfish surveys to the NAFO area 3L, it is not clear if this is a request from the NAFO or a national initiative. Furthermore, it seems that NAFO area 3L will be covered two times, by the same vessel at the same period (August). To be evaluated by STECF.SGRN comments : SGRN was informed that the coverage extension of the Flemish Cap Survey included only the Flemish Pass area of 3L and that the extension of the 3NO Groundfish Surveys to NAFO area 3L is a national initiative. This extension was recommended by the first Regional Co-ordination Meeting of the NAFO area in relation to the DCR. The current 3NO Groundfish Survey is extended to 3L to cover the area that is not covered by the Flemish Cap Survey. Contrary to what is said in the NP Proposal, this survey would finish in July, and then (after a change of crew in St. Johns, Newfoundland) the Flemish Cap Survey would begin in mid-July.SGRN recommends that full details on the issue be provided by the MS, and that any financial implications be discussed between the Commission and the MS in their bilateral negotiations.Evaluators' comments : ARSA survey: as there are recovery plans for the Southern Hake stock and the Iberian Peninsula Nephrops stocks, this survey should be considered as priority 1 survey (for the duration of the recovery plans). To be evaluated by STECF.SGRN comments : With regards to the surveys that target Nephrops and southern hake, see the general comment on the Upgrade of Priority 2 surveys to Priority 1 status.SGRN also notes that neither sardine and anchovy in the Mediterranean (the target species of the ECOMED survey) nor Greenland halibut in 3NO (one of the target species of the Groundfish Survey) are subject to EC Recovery Plans or likely to become so in the near future.Additional SGRN comment : Also see general comments on the MEDITS survey, and on Tuna tagging.Modules H & IEvaluators' comments : There is long list of derogation requested by Spain (by area and stocks). To be evaluated by STECF.SGRN comments : The Evaluators seem to have mis-understood the NP Proposal since the list under Module H is not asking for derogations but for a change in the sampling intensities for some species. SGRN agrees with the approach taken by the MS except in the case of Northern hake, given that (i) this stock is under a Recovery Plan, and (ii) the great uncertainties with regards to the growth pattern of hake.Evaluators' comments : In many cases it is stated that it is not possible to estimate the sex ratio (e.g. artic cod) while the sampling are obtained from observers on board. To be evaluated by STECF.SGRN comments : Since an observer is on-board, there appears to be no reason for the biological sampling not to be fully conducted. SGRN insists that the MS follows the provisions of the DCR.Evaluators' comments : Netherlands and Spain are both to sample the same species form the same Dutch vessels fished in CECAF (Mauritanian) waters and landing at Canaries islands and nothing is mentioned about cooperation. To be evaluated by STECF.SGRN comments : On page 46 of the NP Proposal, it is stated that " Community fleet landings at the port of Las Palmas will be sampled by Spain in co-ordination with the authorities of the countries of origin. A sampling Proposal is presented in Annex IX ." Annex IX however is not enclosed to the NP Proposal. Missing information to be provided by MS.Evaluators' comments : It seems that there is an agreement between France and Spain concerning sampling for tropical tunas. No technical details are given so it is impossible to know who is doing what and to evaluate the relevancy of the sampling designs. 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. Details on existing bilateral agreements to be provided by MS.Evaluators' comments : Other biological sampling: no detailed and scientific information is provided concerning the sampling level (for example how many otoliths will be collected and read; how many gonads will be examined, etc.). It is then impossible to evaluate if the programme is scientifically relevant or not. To be evaluated by STECF.SGRN comments : SGRN was informed that Spain is using the INBIO R Library to calculate the precision levels of the parameters under Module I. Annex II to the NP Proposal includes information about the sampling levels. SGRN assumes that the DCR will be correctly implemented, but insists that full details on the issue be given in future NP Proposals.Module JEvaluators' comments : The data will be collected using random sampling techniques. The analysis of the data will start 9 months after the end of the year (July, year n+1). There is no explanation to justify this lag. STECF is invited to comment on this issue.SGRN comments : SGRN was informed that the lag is due to the delay between the collection of the data by the regional governments, the subsequent transmission of the datasets to the central Government and the time necessary to convert the data to a common digital format. SGRN agrees with the approach taken by the MS.Evaluators' comments : Spain will not meet the vessel disaggregation level according to the Appendix III of the Regulation. Spain will analyse the vessel segments (24) by region and vessel techniques, but without taking into account the vessel length. STECF is invited to comment on this issue.SGRN comments : SGRN insists that the MS follows the provisions of the DCR.Evaluators' comments : There is no mention on the Mediterranean regional level disaggregation. STECF is invited to comment on this issue.SGRN comments : SGRN insists that the MS follows the provisions of the DCR on regional disaggregation levels.Evaluators' comments : Two parameters (revenue/species and quarterly prices/area and species) will be not collected by Spain. STECF is invited to comment on this issue.SGRN comments : SGRN insists that the MS follows the provisions of the DCR.Module KNo comments.SwedenModule CNo comments.Module DNo comments.Module E-  LANDINGSEvaluators' comments : Salmon catches sampling in rivers in Baltic Sea (page 23 of the NP) should have been included in EP. To be evaluated by STECF.SGRN comments: The Evaluator seems to have mis-understood the DCR. According to the Swedish NP, the MS is going to conduct a river survey to monitor both the smolt production capacity and the current smolt production, thus the comment referring to page 23 of the NP Proposal concerns surveys, not landings. However, SGRN considers that the inclusion of any salmon river sampling in the NP, whether in the MP or EP, is not in conformity with the general principles of the DCR. As already stated before (December 2004 Report of SGRN, page 23), SGRN is of the opinion that " no new surveys can be included in the DCR, … , until the next revision of the DCR. ".Evaluators' comments : The catch estimate for herring and sprat in IIIb-d is probably not living up the needed precision level 3, due to the mixed catches of herring and sprat in the industrial fishery and due to the way this is sampled, by the coast guards. At least it is not convincingly documented that it is living up to the specifications. To be evaluated by STECF.SGRN comments: The Evaluator seems to have mis-understood the NP Proposal. The samples of unsorted catch of herring and sprat collected by the coastguard, are for biological purposes, not for the estimation of landings figures. In Sweden, catches are reported exhaustively at landing, and the scheme described on page 10 of the NP Proposal, refers to the control system for checking figures reported at landing. SGRN agrees with the approach taken by the MS.-  DISCARDSEvaluators' comments : There is no authority in Swedish law, which gives the possibility to enforce the fishermen to have observers onboard. Therefore, only vessels where the skipper has agreed on having observers on board will be sampled (page 12 of the NP). On-board observers should be accepted on any vessel in order to avoid biased estimates [CR (EC) Nº 1581/2004]. Non conformity.SGRN comments: See general comment on Accessibility and compensation of commercial fishing vessels.-  RECREATIONAL FISHERIESEvaluators' comments : There is no plan to collect recreational catch of cod even though this type of fishery is pretty extensive at least in SD 23. To be evaluated by STECF.SGRN comments: According to the DRC, results of the surveys for collecting data on the recreational catches of cod in ICES Sub-area III should be provided at the latest by March 31st 2007. This implies that the MS should have started the survey at the latest in the 2006. SGRN insists that Sweden includes a pilot study on its recreational fisheries for cod in ICES Sub-areas III (and IV) in its 2006 NP Proposal. Financial implications to be discussed between the Commission and the MS.-  OTHER ISSUESNo comments.Module FNo comments.Module GEvaluators' comments : Sweden includes a modification in the survey design of the International Bottom Trawl Survey. Last year Sweden stated that the ICES IBTSWG had recommended Sweden to change their sampling design in the Skagerrak because Sweden was not covering the entire area. However, the WG recognized the problem with relation to breaking down a long time series and suggest that Sweden keeps as much hauls as possible from previous years. Sweden extended the 3rd quarter survey by seven days to perform a sensitive analysis. The results of the analysis suggest that changing the sampling design will affect the time series. The WG suggests that Sweden keeps as many hauls as possible from previous years but at the same time tries to cover all rectangles with at least 1 haul where ever possible. Sweden states that a new sampling design in Q3 can only be possible if extra ship time is allocated due to longer distances. Additional ship time is required. To be evaluated by STECF.SGRN comments: SGRN was informed that Sweden has complied with the request of the ICES IBTSWG to maintain as many hauls as possible from previous years. SGRN also notes that most of the new hauls are located in the western part of the Skagerrak, which implies an extension of the survey over a wider geographical area, thus requiring more ship time. SGRN agrees with the approach taken by the MS.Additional SGRN comment : 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.Module H & IEvaluators' comments : The text and the appendix 1 are not in concordance. There is no sampling planed for some species (Herring IIIa, Sprat) in the appendix I, while the text says that they are going to be sampled. To be evaluated by STECF.SGRN comments: SGRN notes that Appendix I of the NP Proposal refers to discard sampling, while Appendix II concerns biological sampling, where all stocks will be sampled according to the DCR requirements.Evaluators' comments : Concerning the EP, there are no data available about the most recent three years landing average. But it seems that all the stocks are over-sampled.SGRN comment: 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. However, SGRN notes that none of the species in the Swedish EP Proposal is subject to analytical stock assessments and any "over-sampling" of these species should therefore be at national expense. Financial implications to be discussed between the Commission and the MS.Module JEvaluators' comments : Vessel segmentation will not be done according to the Appendix III of the DCR, given that identified segments are composed by vessels with a total value of landings above 78,800 Kr (= €8,600). This segment represents more than 95% of total value landed. The rest of the vessels (with total value of landing under €8,600) are classified in a separated segment. 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 economic parameters specified in Appendix XVII will be fully covered, but only for those segments composed by vessels with a total landing value above 78,800 Kr (= €8,600). No information is provided with respect to the expenditures paid by employers. For the segment composed with vessels with low value of landings, only data on value of landings, capacity and effort will be collected. STECF is invited to comment on this issue.SGRN comments : See general comment on Population coverage and segmentation for economic data collection.Evaluators' comments : Sweden will not fully comply with the vessel segmentation according to Appendix IV. The data will be collected for the segments of the minimum program, and other segments based on catch composition (in addition to type of gear and length of vessels). STECF is invited to comment on this issue.SGRN comments : See general comment on Population coverage and segmentation for economic data collection.Evaluators' comments : Sweden will attempt the Extended Program. The economic parameters from Appendix XVIII will not be fully compiled. In particular, parameters lacking are landings per species, production costs (fuel, repair and maintenance, other running costs), fixed costs, financial position, investment and effort. STECF is invited to comment on this issue.SGRN comments : SGRN considers that the data collected under the EP are an added value to the Swedish economic data collection programme, even though not the full set of EP parameters is covered, and therefore agrees with the MS' approach.Module KEvaluators' comments : No details are offered with respect to the rest of parameters from the Appendix such as the financial position, and the fixed costs. STECF is invited to comment on this issue.SGRN comment: SGRN insists that the MS follows the provisions of the DCR.Evaluators' comments : The section K (2a) of the DCR will not be developed. The section K (2b) of the DCR will not be applied. The linkages between Regulations affecting the catch and the processing sector will be evaluated in qualitative not quantitative terms. STECF is invited to comment on this issue.SGRN comment: It is unclear to SGRN what the MS plans to do within the EP. To be clarified by MS.United KingdomModule CNo comments.Module DNo comments.Module E-  LANDINGSNo comments.-  DISCARDSEvaluators' comments : UK states that success in estimating discard depends on, among others, the goodwill of the fishing industry (page 9 of the NP). In previous years, it has not been possible to obtain discard samples from the commercial fleet of Northern Ireland because of a policy of non-cooperation from the industry. The programme proposed for 2006 is therefore completely dependant on obtaining the necessary permission from vessel owners and skippers (page 10 of the NP). Master shall accept observers on board and cooperate with them [CR (EC) No 2371/2002 and amendment]. Non conformity.SGRN comments: See general comment on Accessibility and compensation of commercial fishing vessels. In addition, SGRN insists that Northern Ireland makes more effort to obtain co-operation from its fishing industry in 2006.-  RECREATIONAL FISHERIESNo comments.-  OTHER ISSUESNo comments.Module FNo comments.Module GEvaluators' comments : The International Mackerel/Horse mackerel egg triennial survey is just conducted every third year and it will not take place in 2006. Nevertheless funding is request for this survey within the British NP. No explanation has been found in the text. To be evaluated by STECF.SGRN comments : SGRN was informed that costs for a planning meeting which will take place in 2006 had been erroneously charged to this survey. The meeting is eligible under the DCR and the MS will correct the error. Financial implications to be discussed between the Commission and the MS.Modules H & IEvaluators' comments : The sampling intensity is systematically increased for ALL stocks (reaching a maximum of 22000% increase in lengths for Homarus gammarus and 13000% increase for Gadus morhua ). The reasons for doing so are to reach a precision level (but without mentioning the methodology that has been used to calculate the number of samples) or for continue giving CPUE indexes. 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. Also see general comment on the Interpretation of biological sampling requirements.Evaluators' comments : The "Anglo-Spanish" fleet continues being a problem due to its landings pattern but after one year (this problem was already mentioned in the last NSP from UK) UK still hasn’t got an agreement with Spain in order to sample those landings. To be evaluated by STECF.SGRN comments : SGRN was informed that at the 2005 meeting of the RCM NEA, it was agreed between Spain and the UK that UK flag vessels landing directly into Spain belong to the same métier as the Spanish trawler fleet fishing to the west of Ireland and that this métier is being covered under the Spanish discard programme. SGRN was informed that a bilateral agreement between the two MS will be in place for the start of the 2006 programme. Also see general comment on the Adjustment of NP Proposals to RCM recommendations.Evaluators' comments : For module I, UK wants to use the IBTS survey for gadoids since the commercial catch are usually landed without gonads. This seems to be right but only if UK is not charging twice the same samples since in the IBTS standard protocols is compulsory to sex and give maturity state to the fish sampled and that is already covered by the survey costs. To be evaluated by STECF.SGRN comments : SGRN was informed that these costs are already covered under the survey module and that there is no double charging.Module JEvaluators' comments : UK affirms that it is planning to cover the economic activity of vessels under 10 m. It is said that effort data will be collected. It is not clear enough if additional data collection will be covered for this vessel segment. In fact, budget is divided for vessels of less than 10m and vessels beyond this threshold. STECF is invited to comment on this issue.SGRN comments : SGRN was informed that economic data for the < 10 m fleet will be collected as required by the DCR. Also see general comment on Sampling information and precision levels for economic data.Module KNo comments.Data and sampling requirements for European eelTOR (b) was discussed by an ad hoc sub-group, chaired by Max Cardinale and composed of SGRN-members and invited eel-experts. The outcome of this sub-group meeting was discussed by SGRN in plenary. This resulted in the following comments and recommendations:1.  SGRN notes that the current DCR does not provide for the collection of data with which to estimate R, SSB and F for eel for any of the river basins.2.  SGRN recognises that the DCR needs to be amended, so that it includes river basin districts and adjacent coastal waters as basic spatial disaggregation units. However, SGRN is currently unable to provide answers about the spatial scale and the number of river districts that need to be sampled to enable robust estimates of SSB and F.3.  Currently, 17 existing time series (Dekker, 2002) provide recruitment indices for European eel. SGRN recommends that the continuation of these time series should be included in the MP requirements of the DCR. However, it is possible that in certain areas, fishery dependent series might need to be replaced by fishery independent surveys.4.  SGRN recommends that registration of fishing capacity, effort and landings of commercial eel fisheries (both marine and inland) should be mandatory under the DCR, preferably from 2006 and at the latest from 2007 onwards. Estimation of non-commercial catches should be investigated in pilot studies, preferably in 2006 or 2007 and at the latest in 2008, in order to decide whether they should be included in the DCR.5.  SGRN recommends setting up an internationally co-ordinated pilot project of two years, starting as soon as possible, to establish a cost-effective system for monitoring of recruitment, spawner escapement rate and F by river basin district. The results of the pilot project will be used to identify precision levels and sampling intensities, and for setting up routine monitoring sampling programs to be included in the DCR.6.  SGRN recommends that existing national monitoring programs for eel should be continued and the data should be used in the pilot project.7.  SGRN recommends that a dedicated workshop be convened as an extension to the January 2006 EIFAC-FAO Working Party on Eel, to prepare the pilot study proposed under (e). SGRN recommends that all MS participate in this dedicated workshop and that the costs for participation are eligible under the 2006 NP.ReferencesDekker, W. (ed.) 2002: Monitoring of glass eel recruitment. Report C007/02-WD, Netherlands Institute of Fisheries Research, IJmuiden, 256 pp.Guidelines for National Programme ProposalsThe general concept of the Guidelines for the NP Proposals was discussed by SGRN in plenary, and the following was agreed:8.  The lay-out and overall approach of the Guidelines for the NP Proposals will be the same as for the Guidelines for the Technical Reports, i.e. with general introductory sections, followed by sections by Module of the DCR.9.  The Guidelines will come with a set of Standard Tables, which, in as much as possible, will be similar to the Standard Tables for the Technical Reports.10.  For each Module of the DCR, MS will be requested to provide information on their planned activities under the MP and the EP, the methodology used and a justification of any derogations or non-conformities with the provisions of the DCR. Wherever possible, this information should be provided in tabular form. To that aim, extra tables will be developed, based on existing examples that were considered by SGRN to contain the required information.11.  The chair of SGRN was given the task of preparing a first draft of the Guidelines by the end of 2005. This draft will then be circulated by e-mail to the SGRN for comments and amendments. The final version of the Guidelines should be ready for distribution to the MS by the end of January 2006.12.  Circulation of the Guidelines should be done (i) by e-mail, directly to the National Correspondents, and (ii) via the STECF website hosted and managed by JRC.Revised version of the Guidelines for the Technical ReportsIn June 2005, SGRN decided to produce an amended version of the Guidelines for the Technical Reports. The new Guidelines (version 2005) replace the previous version of the Guidelines (version 2004) and are to be used for the first time for the Technical Reports on the 2005 NPs.The amended version of the Guidelines was prepared by the chair of SGRN and approved by the group in plenary. Apart from some small changes in the text of the Guidelines and the headers of the Standard Tables, the new version comprises the following novelties:13.  Two new Standard Tables (one under Module J and one under Module K of the DCR), with a general description of the sampling populations.14.  The obligation for MS to justify any thresholds in the data collection system for economic data (Modules J and K of the DCR).15.  The obligation for MS to report on the follow-up given to recommendations and initiatives taken by the RCMs.The chair of SGRN was given the task of making the final changes to the Guidelines by the end of 2005, upon which they can be forwarded to the MS. Circulation of the Guidelines should be done (i) by e-mail, directly to the National Correspondents, and (ii) via the STECF website hosted and managed by JRC. JRC is reminded of the fact that only the most recent version of the Guidelines should be made available on the STECF website.Appointment of a new chair for SGRNAfter having chaired the group for three years (2003-2005), Frank Redant has decided to withdraw as chair of the SGRN.Over the past three years, SGRN has evaluated 52 NP Proposals, 39 Technical Reports on National Programmes and 19 Technical Reports on Pilot Studies. It was actively involved in the mid-term revision of the DCR and in the information of the new MS on the requirements of the DCR and the evaluation process. And it went through many difficult discussions on "hot issues" such as the eligibility of "over-sampling", the Atlanto-Scandian Herring Survey, the Blue Whiting Survey, tuna tagging, the inclusion of DNA-studies on salmon in the DCR, etc.While in the early days of SGRN and in the absence of a clear mandate, the role and tasks of SGRN were not well-defined, this has now changed in many ways, with much stricter rules of play, the introduction of standard procedures and templates for the evaluation of NP Proposals and Technical Reports, and the implementation of Guidelines for the MS' NP submissions and their Technical Reports.The DCR is on the verge of major changes, with, amongst others, the shift from an essentially stock-based to a much more fleet-based data collection system, the inclusion of new data sets in compliance with the ecosystem approach and the data requirements in support of the upcoming management plans for eel. The new chair of SGRN will have the difficult task to guide the SGRN through this period of transition. However, the SGRN is confident that, with Joël Vigneau as its new chair, it has found the right person to make sure that it can maintain its scientific independence (a prerequisite to its existence and activities), its evaluation standards, and its sense of criticism, fairness and consistency.After consultation with the Commission, it was agreed that the new chair would fully assume his duties after the Liaison Meeting between the Commission, the chairs of the RCMs and the outgoing and incoming chair of SGRN in February 2006. Until then, the outgoing chair will remain responsible for the "hanging issues" (final report of the December 2005 meeting, final editing of the Guidelines for the Technical Reports and the NP Proposals, etc.).