COMMISSION STAFF WORKING PAPER Impact Assessment
Date: 2011-12-02
Institutions: European Commission
Subjects: FIFG, aquaculture, common fisheries policy, financial aid, fishery resources, fishing area, innovation, marine ecosystem, shipping policy, sustainable development

EUROPEAN COMMISSION 

Brussels, 2.12.2011 
SEC(2011) 1416 final 

COMMISSION STAFF WORKING PAPER 

Impact Assessment 

Accompanying the document 

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE 
COUNCIL 

on the European Maritime and Fisheries Fund [repealing Council Regulation (EC) No 
1198/2006 and Council Regulation(EC) No 861/2006 and Council Regulation No 
XXX/2011 on integrated maritime policy 

{COM(2011) 804 final} 
{SEC(2011) 1417 final} 

 
 
  
 
COMMISSION STAFF WORKING PAPER 

IMPACT ASSESSMENT 

ACCOMPANYING THE DOCUMENT 

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL 

on the European Maritime and Fisheries Fund [repealing Council Regulation (EC) 
No 1198/2006 and Council Regulation(EC) No 861/2006 and Council Regulation No 
XXX/2011 on integrated maritime policy 

This report commits only the Commission's services involved in its preparation and does 
not prejudge the final form of any decision to be taken by the Commission. 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
TABLE OF CONTENT 

1.  PROCEDURAL  ISSUES  AND  CONSULTATION  OF  INTERESTED 

PARTIES..................................................................................................................... 4 

1.1.  Organisation and timing .................................................................................... 4 

1.2. 

Internal consultation .......................................................................................... 4 

1.3.  Consultations with stakeholders........................................................................ 5 

1.4.  Dissemination of the results of consultations with stakeholders....................... 6 

1.5. 

Incorporating comments from the Impact Assessment Board .......................... 6 

2.  THE  STRUCTURE,  PERFORMANCE  AND  PROBLEMS  OF  THE 

PUBLIC FINANCIAL SUPPORT OF THE CFP AND THE IMP ............................ 6 

2.1.  Structure ............................................................................................................ 6 

2.2.  Performance and problems ................................................................................ 8 

2.3.  Problems  linked  to  the  design  of  the  CFP  and  IMP  financial 

instruments …. .................................................................................................. 9 

2.4.  ….limit their effectiveness in achieving CFP and IMP objectives ................. 13 

3.  THE  JUSTIFICATION  FOR  THE  REFORM  OF  THE  PUBLIC 

FINANCIAL SUPPORT INSTRUMENTS .............................................................. 21 

3.1.  Who is affected by the public financial support instruments and how ........... 21 

3.2.  Has the EU the right to act?............................................................................. 22 

4.  WHAT ARE THE POLICY OBJECTIVES?............................................................ 24 

4.1.  Objectives related to the design of the financial instrument ........................... 25 

4.2.  Objectives related to the content of the financial instrument.......................... 25 

5.  WHAT ARE THE POLICY OPTIONS? .................................................................. 26 

5.1.  Elements common to all reform options ......................................................... 27 

5.2.  Description of the options ............................................................................... 29 

6.  COST-EFFECTIVENESS AND EX ANTE EVALUATION .................................. 32 

6.1.  Environmental sustainability........................................................................... 32 

6.2.  Economic sustainability: innovation gap ........................................................ 34 

6.3.  Social sustainability: territorial development of coastal areas ........................ 37 

6.4.  Allocation  between  green  sustainable  fisheries,  green  sustainable 

aquaculture and inclusive territorial development pillars. .............................. 37 

6.5. 

IMP, RFMO and governance .......................................................................... 37 

6.6. 

Intended allocation of EMFF funds per area of activity ................................. 39 

7.  METHODOLOGICAL APPROACH FOR THE ANALYSIS OF IMPACTS 

OF THE DIFFERENT OPTIONS............................................................................. 40 

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8.  ANALYSIS OF IMPACTS....................................................................................... 40 

8.1.  Option  Status  Quo:  Continuation  of  the  current  policy  (including  the 

current EFF)..................................................................................................... 40 

8.2.  Option 1 “EFF +” ............................................................................................ 41 

8.3.  Option 2: EFF+ “Integration”.......................................................................... 44 

8.4.  Option 3: EMFF “Convergence”..................................................................... 44 

9.  COMPARING THE OPTIONS: CONTRIBUTION TO THE EUROPE 2020 

STRATEGY .............................................................................................................. 46 

9.1.  Comparison of impacts.................................................................................... 46 

9.2.  Contribution to the Europe 2020 strategy ....................................................... 47 

10.  THE PREFERRED OPTION .................................................................................... 47 

11.  MONITORING AND EVALUATION..................................................................... 48 

LIST OF ANNEXES:........................................................................................................ 52 

LIST OF ACRONYMS..................................................................................................... 53 

ENDNOTES ...................................................................................................................... 59 

3 

 
 
 
COMBINED  IMPACT  ASSESSMENT  AND  EX-ANTE  EVALUATION  REPORT  CONCERNING 
THE COMMISSION'S PROPOSAL FOR A FUTURE FINANCIAL INSTRUMENT FOR FISHERIES 
AND MARITIME POLICIES (2014-2020) 

Lead DG: DG MARE 

Other  services  involved:  AGRI,  BUDG,  ECFIN,  EMPL,  ENTR,  ENV,  ESTAT, 
HOME,  HOME-JUST,  JRC,  REGIO,  RTD,  SANCO,  SG,  TRADE,  RELEX, 
COMP, MOVE and CLIMA 

Agenda planning reference: 2011/MARE/005 

1.  PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

This report commits only the Commission's services involved in its preparation and does 
not prejudge the final form of any decision to be taken by the Commission. 

1.1.  Organisation and timing 

This document is an impact assessment (IA) and ex-ante evaluation of different options 
for  the  design  of  the  financial  support  to  the  implementation  of  the  Common  Fisheries 
Policy  (CFP)  and  the  Integrated  Maritime  Policy  (IMP)1  in  the  years  2014-2020. 
Accordingly,  its  scope  includes  the  following  financial  instruments  being  currently  in 
use:  (i)  European  Fisheries  Fund  (EFF),  (ii)  IMP  financial  regulation  proposed  by  the 
Commission  to  support  the  IMP  between  2011  and  20132,  (iii)  Community  financial 
measures for the implementation of the CFP and in the area of the Law of the Sea 2007-
20133  (so-called  Second  Instrument)  including  data  collection,  control,  the  voluntary 
financial  support  provided  to  Regional  Fisheries  Management  Organisations  (RFMOs) 
and governance, (iv) the budgets lines concerned by the Common Market Organisation 
(CMO)  for  fisheries  and  aquaculture  products  including  market  intervention  and  the 
scheme to compensate for the additional costs incurred in the marketing of certain fishery 
products  from  the  outermost  regions  of  the  Azores,  the  Canary  Islands,  French  Guiana 
and  Reunion.  In  accordance  with  the  Commission's  Communication  on  A  Budget  for 
Europe 20204, two other currently used instruments have been excluded from the scope 
of  this  IA:  (i)  the  Fisheries  Partnership  Agreements  and  (ii)  the  obligatory  financial 
support provided to RFMOs.  
The  Impact  Assessment  of  CFP  reform5  provided  key  conclusions  on  the  role  of  a 
financial support for the reformed CFP. These conclusions, together with the evaluations 
carried  out  so  far,  the  IA  accompanying  the  CMO6  regulation,  the  initial  IA7  and  the 
Progress  Report8  for  IMP, 
the  Commission's 
Communication  on  a  Multiannual  Financial  Framework  (the  MFF  Communication)9 
form the point of departure for this IA. Furthermore, the results of an ex-post evaluation 
of the Financial Instrument for Fisheries Guidance (FIFG) and of an interim evaluation 
of  the  EFF  finalized  in  February  2011  have  also  been  used,  as  well  as  an  interim 
evaluation of the Second Financial Instrument. 

the  Europe  2020  strategy  and 

1.2.  Internal consultation 

An Impact Assessment Steering Group (IASG) was established in September 2009 and 
met  5  times10.  It  involved  the  following  DGs:  AGRI,  BUDG,  ECFIN,  EMPL,  ENTR, 
ENV,  ESTAT,  HOME,  HOME-JUST,  JRC,  REGIO,  RTD,  SANCO,  SG,  TRADE, 

4 

 
RELEX, COMP, MOVE and CLIMA. At the last of these meetings the current IA report 
(IAR) was presented to the IASG.  

1.3.  Consultations with stakeholders  

The reform of the CFP started with the adoption of the Green Paper11 in April 2009. The 
Green  Paper  was  the  basis  for  public  consultations  which  lasted  until  the  end  of  2009. 
The outcome of the consultations, concerning public support, was as follows: 

(cid:190)  Many  contributions  ask  for  the  continuation  of  public  funding  for  fisheries, 
although  a  few  MS  and  most  NGOs  insist  on  the  elimination  or  phasing  out  of 
subsidies  –  in  their  view  they  preserve  unviable  structures,  contribute  to 
overcapacity and maintain industry dependence on public support.  

(cid:190)  There  is  an  agreement  that  any  future  support  should  accompany  the 
implementation  of  CFP  reform  and  ease  adjustment  of  the  industry,  aiming  at 
long-term economic and social sustainability, or alleviating the possible negative 
consequences of the reform.  

(cid:190)  EU  support  should  focus  on  research  and  innovation,  enhancing  marine 
protection, and supporting fishermen’s organisations and local development.  
(cid:190)  The link to the IMP is considered important: maritime policies can no longer act 
in isolation, and the coherence of the CFP with the IMP needs to be reinforced. In 
fact,  regional,  business  and  NGO  actors  supported  the  need  for  joining  up  EU 
policies affecting seas, maritime sectors and coastal regions already at the time of 
the public consultation in 200712. 

(cid:190)  More  conditionality  between  EU  financing  and  reaching  CFP's  objectives  is 
needed. Compliance with rules/targets should have a bearing on fund availability.  
(cid:190)  A  more  sectoral  approach  to  the  allocation  of  funding  (linked  to  the  size  of  the 
fisheries  sector  instead  of  the  level  of  economic  development,  as  it  is  the  case 
today)  is  strongly  supported  by  a  group  of  MS  while  the  European  Parliament 
opposes this.  

(cid:190)  There  is  general  agreement  on  the  importance  of  the  small-scale  coastal  fleets 
(SSCF) which remain a significant source of jobs in coastal communities. Some 
MS support the idea of a privileged access of this fleet to financing, while others 
do not favour a specific approach.  

(cid:190)  An  overwhelming  majority  of  industry  and  MS  consider  that  common  services 
(such  as  control  and  data  collection)  should  continue  to  be  supported  under  EU 
funding. 

(cid:190)  Regarding  aquaculture  most  of  the  contributions  voiced  opinions  on  whether  it 
should  or  not  be  part  of  the  CFP.  A  majority was in favour of its inclusion and 
aquaculture  was  mentioned  frequently  as  a  potential  beneficiary  of  public 
support.  

In  addition  to  this  public  consultation,  around  200  meetings  with  MS,  Advisory 
Committee  on  Fisheries  and  Aquaculture  (ACFA)  and  Regional  Advisory  Councils 
(RACs), the fishing industry, the processing and marketing sector, trade unions, NGOs, 
and  the  research  community  were  organized.  A  number  of  meetings  took  also  place  in 
2010 and 2011, during which concrete options for the CFP reform, including its financial 
dimension,  were  presented  by  the  Commission  and  discussed  with  the  stakeholders.  In 
particular:  (i)  two  meetings  with  the  Member  States,  during  which  future  funding  was 
discussed,  took  place  in  Gent  (12-14  September  2010)  and  Noordvijk  (9-11  March 
2011). (ii) A dedicated seminar on the future EFF with the participation of stakeholders 
from  industry,  trade  unions  and  Member  States  was  organised  on  April  13th,  2010,  in 

5 

 
 
Brussels.  (iii)  A  conference  on  the  future  of  local  development  in  fisheries  areas  took 
place in Brussels, 12-13th April, 2011.   

1.4.  Dissemination of the results of consultations with stakeholders 

The results of the consultations on the CFP reform are published on DG MARE's website 
(http://ec.europa.eu/fisheries/reform/sec(2010)0428_en.pdf)  and  are  summarized  in  a 
Commission's Staff Working Document "Synthesis of the Consultation on the Reform of 
the  Common  Fisheries  Policy"13.  The  results  of  the  consultations  on  the  IMP  are 
published  on  DG  MARE's  website  and  summarized  in  a  Communication  from  the 
Commission:  Conclusions  from  the  Consultation  on  a  European  Maritime  Policy14.  A 
more  detailed  list  of  the  consultations,  covering  also  the  financial  instrument  can  be 
found in Annex 1. 

1.5.  Incorporating comments from the Impact Assessment Board 

A first draft of the IA report (IAR) was discussed by the IAB on 7 September 2011 by 
written  procedure.  In  its  opinion  of  13  September  201115,  the  IAB  recommended  to 
strengthen the analysis of implementation problems, to strengthen the analysis of value-
added of individual components of the new instruments, to improve the analysis of co-
ordination  with  other  funds  and  to  clarify  further  the  monitoring  and  evaluation 
arrangements. These recommendations have been taken into account in the final version 
of the IAR. The request for improved analysis of co-ordination with other funds was too 
a large extent addressed by the adoption of the common regulation for funds under the 
Common  Strategic  Framework  (CSF),  on  October  5th  ,  which  defined  the  scope  of  co-
ordination  and  common  rules  and  mechanisms  to  be  used  by  all  the  CSF  funds.  The 
request  to  add  more  quantitative  analysis  was  only  party  complied  with  because  of  the 
absence of reliable data concerning the impacts of public financing on the fisheries sector 
(not  least  due  to  lack  of  common  indicators  and  consistent  monitoring  and  evaluation 
framework,  identified  as  a  serious  deficiency  of  EFF  in  this  IA).  Some  data  and 
calculations done in the context of the CFP reform IA have been re-used in this IAR in 
order to better illustrate the problems. Finally, the section on monitoring and evaluation 
has been improved and developed. Starting, milestone and target values for some of the 
indicators would be available in the next 1-2 years, linked to improvements in the quality 
and coverage of economic and social data and of scientific advice. This should allow to 
fully integrate this data in the EMFF Operational Programmes. 

2.  THE  STRUCTURE,  PERFORMANCE  AND  PROBLEMS  OF  THE  PUBLIC  FINANCIAL 

SUPPORT OF THE CFP AND THE IMP 

2.1.  Structure 

2.1.1.  Current funding of the CFP 

The CFP is supported by a set of public financial support tools: 

1)  The  European  Fisheries  Fund  (EFF)  –  under  shared  management-  is  the  major 
financial pillar of the CFP with a total budget of €4.304 million for the period 2007-13.  

The EFF consists of five priority axes (a table with EFF allocations per axis and MS is 
included in the annexes):  

6 

 
•  Axis  1  (28.49%  of  the  total  allocation)  covers  the  adaptation  of  the  EU  fishing 
fleet:  scrapping  premiums,  temporary  cessation,  investments  on  board,  small-
scale coastal fishing, socio-economic measures;  

•  Axis  2  (28.38%)  covers  aquaculture,  inland  fishing,  fish  processing  and 

marketing;  

•  Axis  3  (26.49%)  covers  measures  of  common  interest:  producers'  organisations, 

fishing ports, new market and promotion campaigns, pilot operations;  

•  Axis 4 (12.92%) covers territorial development of fisheries areas by the creation 

of local partnerships in fisheries dependent areas;  

•  Axis 5 (3.72%) covers technical assistance. 

The  5  largest  current  recipients  are  Spain  (26.29%),  Poland  (17.05%),  Italy  (9.86%), 
Portugal (5.73%) and Romania (5.36%). Together they account for close to 65% of the 
total allocation of funds.  

2)  The  Second  Financial  Instrument  (EC  861/2006)  –  under  direct  management- 
provides support for a series of actions not covered by the EFF: 

a)  Control  and  enforcement:  support  is  provided  to  national  fisheries  control 
programmes  which  enable  MS  to  fulfil  their  role  in  relation  to  control  and 
enforcement of the CFP. The total budget is €345 million for 2007-2013.  

b)  Data collection and scientific advice: funds are used to support the establishment of 
complete datasets by the MS (under so called Data Collection Framework) and used 
for  the  evaluation  of  fisheries  resources  and  decision  making.  The  total  budget  is 
€360 million for 2007-2013. 

c)  Governance  of  the  CFP:  providing  funding  for  consultative/advisory  bodies, 
Advisory Committee on Fisheries and Aquaculture (ACFA), the Regional Advisory 
Councils  (RACs),  and  for  communication  and  dialogue  with  stakeholders  and  the 
public. Expenditure for 2007-2013 is €45 million. 

d)  International  relations:  voluntary  and  compulsory  contributions  to  Regional 
Fisheries Management Organisations (RFMOs) and UN bodies dealing with fisheries 
and law of the sea amounted to €9.8 milli on in 2010; €11 million are programmed for 
2013. It has to be noted that although Fisheries Partnerships Agreements (FPAs) are 
mentioned in the Second Financial Instrument, it does not constitute the basic act for 
such expenditure because each FPA is covered by a Specific Council Regulation. 

3) The European Agriculture Guarantee Fund (EAGF) – under direct management- 
finances  intervention  and  compensation  for  production  and  marketing  planning  in  the 
Common  Market  Organisation  for  fisheries  and  aquaculture  products  (about  €12,5 
million per year). The EAGF also supports the scheme to compensate for the additional 
costs  incurred  in  the  marketing  of  certain  fishery  products  from  the  outermost  regions. 
The total amount of the compensation is around €15 million per year. 

2.1.2.  Funding of the IMP 

4) The Integrated Maritime Policy (direct management) was financed on the basis of 
Article  49  (6)  (a)  and  (b)  of  the  Financial  Regulation  funding  pilot  projects  and 
preparatory  actions.  The  total  volume  for  2008-2010  was  €20.4  million.  A  financial 
regulation has been proposed by the Commission to finance the further development of 
the IMP between 2011 and 2013 with a budget of €50 million. The regulation is currently 
discussed in co-decision and is likely to be adopted before the end of 2011. 

7 

 
2.2.  Performance and problems 

The conclusions of the CFP reform IA report were that, notwithstanding progress made 
with the reform of 2002, the CFP had failed to ensure a sustainable exploitation of fish 
resources on its three dimensions: environmental, economic and social16. 

The  identification  of  problems  and  drivers  for  these  problems  was  difficult  because  of 
their  interdependence.  In  spite  of  that  interdependence,  the  following  ranking  of 
problems was set: 

•  The main problem of the CFP is the lack of environmental sustainability; that is the 
existence of overfishing, or of an excessive fishing pressure. Out of the 93 stocks for 
which sufficient scientific advice exists, only 21.5% are exploited at levels delivering 
maximum sustainable yield (MSY), 35% are over-exploited and 43% are outside safe 
biological  limits17.  That  means  that  78.5%  of  Community  stocks  for  which  there  is 
scientific advice are fished unsustainably. Fleet's overcapacity was found to be one the 
main drivers for overfishing. The high level of discards, poor compliance and the lack 
of sufficient scientific advice were found to be important additional ones. 

•  The second major problem of the CFP is the poor economic sustainability. Economic 
performance, in particular of the catching sector, is poor. Gross Value Added (GVA) 
per vessel has been diminishing over the last few years and no more than half of the 
fleets cover all of their costs.  As a result, fleets are vulnerable to external shocks (in 
particular to the evolution of fuel prices which, at current prices of €0.6/l, represent on 
average 25 to 30% of total revenues) and dependent on public support (FIFG and EFF 
funds could represent on average around 5 to 10% of the total turnover). The situation 
as  regards  processing  and  aquaculture  is  generally  speaking  better.  However,  as 
further  explained  below,  aquaculture  is  hampered  by  the  lack  of  innovation, 
particularly  as  regards  marketing  and  commercialisation  activities  and  by  the  very 
small average size of firms (98% are SMEs). 

•  The  third  major  problem  is  the  lack  of  social  sustainability.  From  a  demand 
perspective, low wages and high safety hazards mean that the catching sector is not an 
attractive enough source of employment to new generations of local fishermen. From 
a  supply  perspective,  the  poor  environmental  sustainability  together  with  the  poor 
economic sustainability mean that employment, particularly in the catching sector, has 
been declining at least for the last 15 years at a rate of 4 to 5% per year. The decline 
of  employment  in  the  catching  sector  risk  affecting  the  medium  term  viability  of 
coastal communities; in particular of those where there are not obvious employment 
alternatives to the catching sector.  

•  The  external  dimension  of  the  CFP  has  also  performed  less  well  than  expected, 
particularly as regards environmental sustainability, but also in terms of international 
governance.  In  spite  of  improvements  in  design  and  delivery,  Fisheries  Partnerships 
Agreements (FPA) are still perceived as a source of subsidies for the EU fleets and not 
necessarily  in  line  with  environmental  sustainability  in  the  waters  of  the  beneficiary 
countries. For their part, the Regional Fisheries Management Organisations (RFMO) 
are generally considered as unable to revert the decline of international fish stocks. 

•  Finally, the CFP has been affected by a number of external factors such as pollution, 
climate change and the increased use of the marine space by other users, which affects 
fisheries and development of new aquaculture farms. 

As outlined in the CFP reform IA report, part of that failure can be attributed to the very 
complex  and  cumbersome  framework  of  the  CFP,  which  makes  implementation  and 

8 

 
compliance  difficult,  and  to  the  design  of  management tools (notably TAC, quotas  and 
relative  stability).  However,  to  the  extent  that  the  overarching  objective  of  the  CFP 
financial  instruments  was  "to  support  the  common  fisheries  policy  so  as  to  ensure 
exploitation  of  living  aquatic  resources  and  support  aquaculture  in  order  to  provide 
sustainability in economic, environmental and social terms18" it appears evident that part 
of the failure can also be attributed to the policy funding.  

How can this be explained? First, there are serious problems linked to the design of the 
CFP financial instruments, the EFF in particular. Second, these problems acted as drivers 
for the lack of effectiveness in supporting those CFP objectives that were intended to be 
achieved with the help of the financial measures.  These two categories of problems are 
developed below. 

2.3.  Problems linked to the design of the CFP and IMP financial instruments 

…. 

The complexity of financial support under the CFP  

According to CFP reform IA report, the regulatory framework of the CFP is particularly 
complex19. Complexity affects also the financial tools of the CFP, as shown by the above 
description.  Linkages  between  the  CFP  and  the  financial  instruments  supporting  its 
implementation are lacking. Each of the CFP and IMP financial instruments has its own 
implementation  systems  (including  programming,  financial  decisions,  monitoring, 
evaluation and control), comitology and is negotiated separately. As a result there is little 
possibility  of  co-ordination  between  these  instruments  and  of  building  synergies.  It  is 
also  difficult  to  ensure  cross-compliance  between  the  mainstream  EFF  funding  and  the 
obligations  of  the  Member  States  regarding  control  and  data  collection.  Integration  of 
CFP into IMP is also problematic.  

As  an  example  of  the  weak  coordination,  Producer's  Organisations  (POs)  can  receive 
support  under  the  current  EFF  for  their  creation  or  the  implementation  of  plans  to 
improve the quality of products. On the other hand, the European Agriculture Guarantee 
Fund (EAGF) finances operational expenses of POs, i.e. intervention and compensation 
for production and marketing planning. As funds can come from two sources, avoiding 
duplication  entails  an  additional  burden  to  administrations  and  beneficiaries  of  the 
support, since both instruments have different administrative procedures. 

2.3.1.  Financial instruments under shared management 

Financial instruments under shared management represent the bulk of the funding. They 
present a number of problems related to the lack of strategic approach towards achieving 
the CFP objectives, to the lack of coordination with other funds and with a monitoring 
system that not only impedes a good follow up of the instruments but that exacerbates the 
lack of focus on the achievement of the CFP objectives. 

Lack of alignment between EFF allocation criteria and the size of the fishing sector: 
low absorption of the EFF 

9 

 
 
 
 
 
Currently,  the  EFF  is  allocated  on  the  basis  of  dual  criteria.  For  convergence  regions 
(regions with the GDP per capita below 75% of the EU average) funding is allocated on 
the  basis  of  the  historical  share  of  the  fisheries instrument in the  cohesion policy.  This 
method accounts for 75% of the overall EFF envelope. The remaining 25% is distributed 
among non-convergence regions on the basis of a number of criteria, such as the size of 
the production of the fisheries sector in the MS (including employment) and the scale of 
adjustment needed to reduce the fishing effort.  

As  a  result,  the  allocation  of  the  funding  is  predominantly  aligned  with  the  level  of 
economic  prosperity  –  the  lower  the  latter  the  higher  the  funding.  However,  the 
distribution of fishing activities does not follow the same logic. There are a large number 
of major fishing nations in the EU which belong to the non-convergence category. This 
results  in  huge  disparities  among  the  MS  in  terms  of  the  support  per  capita,  to  the 
detriment  of  the  fishing  sector  in  richer  MS.  These  disparities  measured  at  the  level  of 
the MS are as high as 30 to 1.  

As a consequence, the allocation method is one of key factors responsible for the current 
delays  in  EFF  absorption  (certified  interim  payments  sent  by  MS  by  October  2011 
amount to 19,4% of the overall EFF allocation), as some MS combine a huge allocation 
under the EFF with a small fishing and aquaculture sector eligible for this support.  

is  not  unique  to  the  EFF.  According  to  the  MFF 
This  absorption  problem 
Communication, many MS have difficulties in absorbing EU funds not least due to their 
fiscal  situation  which  made  it  more  difficult  to  release  funds  to  provide  national  co-
financing. For EFF this was further complicated by the late adoption of both the EFF and 
the  implementing  regulations.  Moreover,  the  launch  of  EFF  overlapped  with  the 
finalisation  of  the  implementation  of  the  previous  Financial  Instrument  for  Fisheries 
Guidance (FIFG) 2000-2006 which put an additional strain on a relatively small fisheries 
administration. Finally, some MS had difficulties in putting in place the Management and 
Control System (MCS) for the EFF, necessary for the certification and reimbursement of 
payments made by MS to beneficiaries. The reason was that  MS gave priority to MCS 
required by other, larger EU funds. 

Lack of strategic approach in the EFF 
This is a recurrent problem already present in the context of the previous FIFG20, which 
lacked clarity in strategy and priorities regarding the type of investment to promote. The 
EFF is programmed at the level of axes and MS can choose their own priorities from the 
"menu"  of  measures  available  under  each  of  them.  This  often  leads  MS  to  giving 
preference  to  investment  facilitating  absorption  rather  than  focusing  on  key  CFP 
priorities.  This  resulted,  for  instance,  in  overinvesting  in  some  types  of  infrastructures. 
The  EFF  introduced  the  National  Strategic  Plans  (NSP)  to  avoid  this  type  of  the 
approach. The NSP sets out the priorities, objectives, estimated public financial resources 
required and deadlines for its implementation, with particular regard to the objectives set 
out in the CFP.  

However,  unlike  for  other  EU  funds  under  shared  management,  there  is  no  EU-level 
strategic  framework  setting-up  references  levels  and  targets  for  strategic  orientations. 
Moreover, the Commission does not approve NSP which gives it a very limited impact 
on  its  final  shape.  Finally,  while  some  MS  regarded the NSP as an  important first step 
enabling a focus on the strategic priorities, most of them considered it as redundant with 
the  Operational  Programme  (OP)  and  not  worth  the  administrative  effort.  As  a  result, 
most  of  NSPs  have  been  disregarded  once  the  OP  is  in  place.  In  this  way  the  lack  of 
strategic approach remains unaddressed. 

10 

 
Insufficient use of the EFF for achieving environmental sustainability 

An example of the consequences of lack of the strategic approach is a low uptake of EFF 
measures related to the environment. According to the mid-term evaluation of the EFF21, 
measures to reduce the impact of fishing and aquaculture on the environment are hardly 
so  far  by  a  few  MS.  Some  types  of 
used:  just  €25  million  has  been  committed 
investments  eligible  under  the  measure  "investments  on  board  fishing  vessels  and 
selectivity"  are  also  relevant  for  the  environment  but  MS  tend  to  use  it  rather  for  the 
modernisation  of  fishing  vessels.  Furthermore,  only  a  few  MS  use  aqua-environmental 
and animal health measures.  

The EFF can also support measures of common interest intended to protect and develop 
aquatic fauna and flora while enhancing the aquatic environment. These measures relate 
to  the  construction  or  installation  of  static  or  movable  facilities,  the  rehabilitation  of 
inland waters, or the protection and enhancement of the environment in the framework of 
NATURA 2000. However, the commitment rate of these measures is also very low. Axis 
4 appears to have a high potential for supporting environmental projects locally, but its 
current state of implementation does not allow having a sufficiently clear picture of this 
type of investments. 

Weak  coordination  of  the  EFF  with  the  other  funds  intervening  in  the  area  of 
fisheries and maritime policy 

There  are  mechanisms  available  to  coordinate  with  the  other  structural  funds  and  rural 
development fund. This is the objective of the so-called "demarcation lines", an informal 
inter-service  document  which  specifies  which  fund  should  support  a  certain  type  of 
investment. However, MS found that Commission's guidance too general and focused too 
much on the demarcation, at the expense of co-ordination. In addition, as OPs are written 
at  a  stage  when  there  is  little  ability  to  foresee  the  measures  that  will  subsequently  be 
implemented,  it  was  difficult  to  fix  clear  demarcation  lines.  Further  problems  emerged 
during  the  implementation  phase,  due  to  some  differences  in  the  definition  of  eligible 
measures  (e.g.:  in-kind  contributions,  salary  costs  and  VAT).  Finally,  subsequent 
modifications of the OP can result in the lines being obsolete. 

Weak co-ordination of local development implemented under EFF and rural development 
is an example of potential synergies which might be exploited to a larger extent. Local 
groups created under both funds often exist in the same areas and face similar problems; 
yet the possibilities of co-operation between them existing in the legislation in force are 
limited.    

Moreover, there is a large but unexploited potential for the co-ordination with centrally 
managed EU funds, such as LIFE. 

Lack of critical mass of projects 

As a consequence of the lack of strategic approach and the weak co-ordination with other 
funds,  there  is  little  concentration  of  EFF  expenditure  on  strategic  priorities,  such  as 
aforementioned  environmental  sustainability.  A  specific  issue  linked  mainly  to  the 
sustainable development of fisheries areas is the size of the budgets of local partnerships. 
Some of them are as small as € 100,000 which  means that local group cannot have a real 
impact on the economic situation in the fisheries area - the experience shows that optimal 
budget  should  be  around  2-3  million  per  group.  This  is  made  worse  by  the  lack  of 
alignment between allocation criteria and the size of the fishing sector. 

A  weak  monitoring  and  evaluation  system  that  lacks  focus  on  results  and 
performance 

11 

 
The  monitoring  and  evaluation  functions  within  the  EFF  have  various  weaknesses  that 
prevent  high  quality  reporting  and  limit  an  effective  impact  on  the  results  and 
performance  of  the  programmes.  The  EFF  does  not  have  any  common  framework  for 
monitoring indicators on results and impacts. DG MARE produced a guidance document 
covering these aspects22. However, in the end each MS has set up its own indicators. The 
resulting heterogeneity impedes aggregation and comparisons across MS. 

Data based on a common list of 170 categories of data related to measures (as defined in 
Annex  III  of  Regulation  (EC)  No  498/2007)  are  to  be  communicated  on  request  to  the 
Commission. MS consider that indicators required by EFF implementing regulation are 
too  numerous  and  redundant.  Furthermore,  despite  being  compulsory  output  indicators, 
these  data  are  no  longer  collected  on  a  regular  basis  by  the  EU  as  the  Infosys  system 
created  for  the  2000-2006  programming  period  and  that  was  used  to  consolidate  data 
received  from  MS  is  no  longer  operational  under  the  EFF.  The  existing  system  is 
ineffective whilst it entails a high administrative cost at both national and EU level. 

Furthermore, the issue is not limited to the lack of coherence. The interim evaluation of 
the EFF has shown also that both existing indicators and reporting at mid-term period are 
focused on operational level and financial absorption, and that less attention is given to 
results  and  impacts.  Impact  indicators  are  also  less  developed  and  difficult  to  follow. 
This exacerbates the negative consequences of the lack of strategic approach. 

The  above  shortcomings  explain  the  lack  of  focus  on  results.  With  the  exception  of 
scrapping  where  the  combined  use  of  the  monitoring  system  and  the  Fleet  Register 
allows  an  overview  of  the  evolution  of  the  fleets,  it  is  very  difficult  to  know  to  what 
extent the money spent has actually contributed to achieving the objectives of the CFP.  

The insufficient use of conditionalities 

No  conditions,  sanctions  or  incentives  can  currently  be  attached  to  the  achievement  of 
objectives.  Furthermore,  conditionalities  are  seldom  used  in  the  current  CFP  in  general 
and  in  its  financial  instruments  in  particular.  They  take  the  form  of  general  condition 
such  as  "operations  financed  by  the  EFF  shall  not  increase  fishing  effort23"  or  of  very 
specific conditions attached to the eligibility of certain measures (exclusion of the retail 
sector  from  the  support  under  Axis  2  for  example).  Some  formal  conditions  are  also 
present such as the need to carry out an ex-ante evaluation (including an environmental 
impact assessment), the use of a specific template for presenting the OPs, etc.  

Beyond  these,  there  are  neither  general  conditions  such  as  a  strategic  fit  of  the 
programme with the objectives of the CFP, nor specific requirement for compliance with 
other CFP-related legislations such as control, IUU or data collection regulations which 
could foster compliance and coherence of the whole policy.  

2.3.2.  Financial instruments under direct management 

The financial instruments under direct management have also some design and delivery 
problems,  often  similar  to  these  of  the  shared  management  instruments.  In  particular, 
delivery and design mechanism was a key factor leading to an inefficient functioning of 
the  CMO  in  fisheries  and  aquaculture  products.  These  issues,  however,  have  been 
addressed by the new CMO regulation adopted by the Commission within the framework 
of CFP reform24: current intervention mechanisms have been simplified (one intervention 
instrument  instead  of  six)  and  the  role  of  Producers  Organisations  (PO)  have  been 
significantly reinforced.  

The  main  outstanding  problem  stemming  from  direct  management  relate 
to 
administrative  constraints  internal  to  the  Commission.  This  translates  into  heavy 

12 

 
administrative  costs  and  burden  for  the  EU  and  the  beneficiaries,  which  are  mainly 
administrations  in  the  MS.  This,  for  example,  is  one  of  the  reasons  for  the  delayed 
implementation of control expenditure. 

The  Comitology  attached  to  financial  instruments  under  the  direct  management  is 
different,  leading  to  a  multiplication  of  meetings  and  a  lack  of  awareness  of  the 
stakeholders that are not involved in the discussions held in each Committee.  

A  related  issue  is  the  fact  that  these  strands  of  funding  are  generally  managed  on  an 
annual basis, which is incompatible with the longer term strategic approach required for 
the  CFP  reform.  This  also  renders  achieving  consistency  with  the  mainstream  EFF 
funding very difficult, if not impossible.  

Similarly,  the  fact  that  data  collection  is  implemented  through  a  separate  instrument 
prevents it from ensuring better policy enforcement – as the financial sanctions for those 
MS which do not provide required data are seriously limited.  

The  adoption  of  the  IMP  funding  instrument  is  still  pending;  therefore  no  conclusion 
about  its  functioning  can  be  formulated  at  this  stage.  For  voluntary  contribution  to 
RFMOs and the governance expenditure, the major conclusions of evaluations concerned 
legislative  arrangements  rather  than  delivery  mechanism;  those  were  addressed  by  the 
CFP reform. 

Finally, the scheme to compensate for the additional costs incurred in the marketing of 
certain fishery products from the outermost regions has provided MS with a significant 
degree  of  flexibility  to  confront  changes  in  demand  affecting  the  marketing  of  seafood 
products  from  these  regions  in  terms  of  eligible  products  and  levels  of  compensation. 
However, transparency regarding compensation is not fully guaranteed because there are 
not always lists of eligible additional costs. Furthermore, there are coordination problems 
with other EU funding instruments related to fisheries and aquaculture (e.g. funding for 
aquaculture development in the EFF) or to other policies (e.g. POSEI Agricole). 

2.4.  ….limit their effectiveness in achieving CFP and IMP objectives 

This  section  focuses  on  these  CFP  problems  the  solution  of  which  requires  public 
financial support. None of them is new. Their persistence over the years shows the lack 
of effectiveness of the public support tools so far (notably the FIFG and the EFF). 

2.4.1.  Environmental sustainability 

Public financial support has not eliminated the problem of overcapacity 
The  CFP  Reform  IA  report25  identifies  overcapacity26  as  one  of  the  key  drivers  of 
overfishing.  Notwithstanding  almost  30  years  of  EU  financial  support  to  scrapping, 
overcapacity  remains  significant  in  many  fleets.  Over  time,  the  financial  amounts 
allocated  to  scrapping  have  actually  increased:  €374  million  for  the  period  1994-1999, 
€559  million  (2000-2006)  and  €720  million  for
ecasted  in  the  current  programming 
period (2007-2013). Yet, nominal fishing capacity (expressed below as a continuous line) 
is  removed  at  the  constant  rate  of  ca  2%  per  year  (1.8%  for  2007-2013),  which  barely 
corresponds to the increase in actual fishing capacity (dotted line) due to technological 
progress (2-3%).  

13 

 
Figure 1 – Capacity development over the last 16 years in EUR12 MS 

10

8

6

4

2

Multi Annual Guidance
Programmes III & IV

Entry/Exit regime
under revised CFP

(

i
l
l

w
k
n 
o
mi
er
w
o
P
g 
n
hi
s
Fi

0
1992 1994 1996 1998 2000 2002 2004 2006 2008

Source: EU's Fleet register 

Scrapping premiums can have the perverse effect of encouraging fishermen to continue 
fishing, even though fishing cannot provide them with viable income27.  
The  above  view  was  emphasized  by  the  Court  of  Auditors  (ECA)28.  In  its  report  it 
concluded that the measures taken to date to reduce fishing overcapacity by adapting the 
fishing  fleet  to  fishing  resources  have  been  unsuccessful.  Moreover,  according  to  the 
report,  the  effect  of  scrapping  was  further  reduced  by  investments  linked  to 
modernisation aboard which was very likely to lead to increases in fish catches. 

The  effectiveness  of  scrapping  premiums  is  further  put  into  question  because  50%  of 
recent reductions of capacity (in terms of number of vessels) was achieved without EFF 
support and seems to be the result of increases of fuel costs and reductions of income. 

Finally,  other  management  tools  have  proven  effective  in  reducing  capacity  without 
public funding. This is the case of transferable fishing rights implemented in a number of 
world fisheries and, increasingly, in the EU itself. In Denmark, for example, in the first 
two years after the introduction of the system, the demersal fleet was reduced by about 
35% in terms of active vessels. A recent assessment of the capacity of the Danish fishing 
fleet showed a good balance between the capacity of the active part of the fleet and the 
fish resources presently available for Denmark.  

Fishing has a high environmental impact 

The  existence  of  high  levels  of  discards  is  identified  in  the  CFP  Reform  IA  as  an 
important driver of the lack of environmental sustainability of the CFP. Based on FAO 
data, it can be estimated that in EU fisheries discards could reach 23% of total catches. 
As  TACs  are  based  on  landings;  discarded  fish  are  not  taken  into  account.  This 
unaccounted  mortality  reduces  the  effectiveness  of  the  TAC  system  as  a  conservation 
tool and undermines scientific advice.  

The reformed CFP proposal includes ban on discards. As shown in the CFP Reform IA, 
such  policy  should  induce  a  change  in  selectivity  of  gears  and  fishing  techniques. 
However, in the short term (2013-2015) it may imply significant negative impacts, both 
in terms of  increased cost  of fishing (resulting from the acquisition of selective fishing 
gear) and reduced income from fishing (lower first sale prices).  

Another  issues  which  needs  to  be  addressed  concerns  a  by  catch  of  protected  species. 
There  are  also  scientific  and  public  concerns  about  the  environmental  impacts  of  the 
fisheries from a broader perspective of maintaining biodiversity and the health of marine 
ecosystems. Some forms of fishing (bottom trawlers for example) have a strong impact 
on vulnerable marine ecosystems, which need better protection. Small scale coastal fleets 
(SSCF)  often  (although  not  always)  fish  with  less  negative  impacts  in  a  non-intensive 

14 

 
 
 
manner, using a range of seasonally diverse fishing methods on a range of species, have a 
relatively low impact on the ecosystem. 

Environmental impacts of aquaculture 

Extensive and some types of intensive aquaculture (such as closed recirculation systems) 
may have very low or no environmental impacts (apart from high electricity consumption 
in recirculation systems). However, some other types of intensive fish farming may have 
negative  environmental  impacts  such  as  sedimentation,  water  pollution,  genetic 
interaction with wild organisms or spread of diseases and parasites29. 

Carnivorous  fish  farming,  as  other  animal  production  sectors  (e.g.  poultry,  pig 
production)30,  imply  a  demand  for  fish  meal  and  fish  oil  which  may  add  itself  to  the 
fishing  pressure  on  wild  stocks  for  human  consumption.  In  recent  years,  new 
knowledge31 and technologies have been developed which may limit the future needs on 
fish  meal  and  fish  oil  of  the  aquaculture  sector.  However  applied  innovation  is  still 
required  in  these  areas.  Furthermore,  the  small  size  of  the  aquaculture  sector  acts  as  a 
disincentive  for  firms  to  invest  more  in  research  and  innovation,  whereas  the  small 
average size of aquaculture firms limits their access to existing technologies. 

Furthermore,  there  are  many  cases  where  compliance  with  higher,  standards  (in 
particular  in  the  phytosanitary  field)  increase  production  cost  and  make  farms  less 
competitive in the market place. 

Aquaculture production is also highly dependent on a high quality environment – above 
all the water quality. This is an increasing concern for most aquaculture sectors.  

On  the  other  hand,  aquaculture  often  plays  an  important  role  in  environmental 
conservation  and  enhancement  of  biodiversity,  retention  of  water  in  the  landscape  and 
flood  protection.  In  some  cases  aquaculture  is  instrumental  in  restoring  wetlands  for 
sustainable  exploitation.  These  extensive  or  semi-intensive  aquaculture  systems  can  be 
compatible with sensitive habitats and can generate environmental benefits.  

One clear example of the above is that of extensive fishponds, especially in Central and 
Eastern Europe. They provide a very important habitat for large numbers of water birds. 
They  were  created  in  the  1940s  and  1950s,  mostly  for  carp  farming.  Very  often  such 
fishponds  developed  on  the  site  of  former  natural  wetlands  and,  due  to  the  extensive 
management,  have  evolved  into  semi‐natural  wetlands  supporting  high  biodiversity.  In 
this  way  inland  aquaculture  has  replaced  natural  marshes  in  hosting  high  diversity  of 
aquatic plants and animals. At the moment, many of these aquaculture facilities lie close 
to/in  NATURA  2000  sites.  In  countries  such  as  the  Czech  Republic,  Romania  and 
Hungary sites with fishponds makes up a quarter or more of all special protection areas 
(SPAs) in the country32. 

In economic terms, on the one hand, the provision of these environmental services results 
in higher production costs which make these firms less price-competitive. On the other 
hand, many consumers are not willing to pay a higher price for these products, in spite of 
their positive environmental role. As a result aquaculture activities in these areas risk not 
being profitable.  Intensification of production in fishponds or the pure abandonment  of 
traditional  fish  farms  would  severely  decrease  their  role  as  a  wildlife  habitat.  Their 
drying up, encroachment by scrub and trees or replacement with other land use will lead 
to the decline of biodiversity. 

According  to  the  EFF  interim  evaluation.  the  lack  of  strategic  approach,  of  clear 
priorities and of focus on performance and results seriously limits the contribution of the 

15 

 
EFF  in  the  environmental  areas  (see  section  "Insufficient  use  of  the  EFF  for  achieving 
environmental sustainability") 

Insufficient scientific advice and data and lack of co-ordinated approach to marine 
data do not allow for a fully fledged knowledge based policy.  
The  CFP  Reform  IA  report33  identifies  the  lack  of  sufficient  scientific  advice  and 
economic data as an important driver for the lack of environmental sustainability and a 
risk  for  the  success  of  the  CFP  reform.  Reliable  scientific  information  (allowing  for 
knowledge-based  management)  is  available  for  just  45%  of  the  208  commercial  stocks 
for  which  the  EU  is  responsible.  The  situation  is  even  worse  for  the  Mediterranean, 
although this is partly explained by the fact that there are no TACs set at EU level. 

Furthermore,  according  to  the  Communication  from  the  Commission  "Consultation  on 
Fishing Opportunities for 2011"34, the number of stocks the state of which is unknown 
due  to  poor  data  has  been  steadily  increasing  for  the  period  2003-2010  (from  48  to  60 
stocks in the North-East Atlantic and adjacent waters). 

Significant  amounts  of  additional  funding  would  be  required  (estimated  at  around  €20 
million/year).  This  should  be  also  considered  in  the  light  of  potential  risk  that  the 
capacity  of  the  MS  to  co-fund  data  collection  expenditure  may  be  reduced,  in  the 
aftermath of the current budgetary austerity programmes. 

Knowledge is not only necessary for fisheries but also for the wider maritime economy. 
Member  States  spend  approximately  €1.5  b illion  a  year  collecting  marine  data.  The 
impact assessment35 for "marine knowledge 202036" found that a better-organised marine 
data  infrastructure  would  not  only  save  €300  million  a  year  to  existing  users  but  open 
new  opportunities  for  innovation  worth  another  €60-200  million  a  year.  The  co-
ordination  between  data  collection  done  under  the  Data  Collection  Framework  (which 
largely  supports  collection  of  data)  and  the  European  Marine  Observation  and  Data 
Network  (which  largely  assembles  data  that  has  already  been  collected  in  order  to 
facilitate their distribution to users) is insufficient at the moment. 

Insufficient compliance with the CFP rules 

Since 1996 EU provides funding to control programmes which enable MS to fulfil their 
role in relation to control and enforcement of the CFP. As concluded by the CFP IA, the 
control and IUU Regulation set up new framework which properly addressed weaknesses 
detected  by,  inter  alia,  the  report  of  the  ECA.  However,  the  implementation  of  this 
framework, in particular in terms of new technologies (including those made obligatory 
by  the  EU  control  regulation)  requires  significant  amounts  of  funding.  The  increased 
frequency  of  the  control  –  a  main  recommendation  of  the  evaluation  of  the  second 
instrument – will have similar consequences. Finally, as in the previous case the capacity 
of the MS to co-fund control expenditure may be reduced, in the aftermath of the current 
budgetary austerity programmes.  

The  lack  of  common  tools  to  regulate  spatial  deployment  of  economic  activities  at 
sea and collaboration in the implementation of environmental policy 

Competition for space among human maritime activities and in the marine environment, 
combined with no or limited coordination increases pressure on the marine environment. 
The current state of development of Maritime Spatial Planning (MSP) is insufficient to 
achieve  environmental  sustainability.  It  can  also  have  negative  effects  on  economic 
sustainability,  in  particular  for  the  marine  aquaculture  sector,  as  the  lack  of  MSP 

16 

 
  
providing investors with a business certainty is considered to be an important bottleneck 
for the development of the sector. 

The  Marine  Strategy  Framework  Directive  requires  Member  States  to  achieve  good 
marine environmental status by 202037. Member States are required to cooperate where 
they  share  a  marine  region  or  sub-region.  Experience  so  far  demonstrates  EU  led  co-
operation – such as EU strategy for the Baltic Sea - is much more efficient in this respect. 
Such coordination needs to be developed in other sea basins which require the set-up of 
steering mechanisms and stakeholder involvement.  

2.4.2. 

 Economic sustainability  

EU  fisheries  and  aquaculture  are  characterised  by  low  innovation  level  and 
insufficient economic viability 

According  to  the  MFF  Communication,  the  EU  faces  a  significant  innovation  gap  that 
needs  to  be  addressed  if  the  EU  is  to  compete  with  other  developed  economies  and 
emerging, developing economies38. 
These  innovation  gaps  exist  also  in  the  fisheries  sector.  The  CFP  reform  IA  report39 
points out that, on top of overcapacity, low levels of innovation explain part of the poor 
performance  of  the  catching  sector  and  the  stagnation  of  the  aquaculture  production  in 
the EU for the last 15 years. Available data shows that labour productivity (measured in 
terms of gross value added per employee) in the fisheries and aquaculture sector in the 
EU is 25% lower than the EU average. Neither the FIFG nor the EFF have been able to 
significantly fill that gap, in spite of the significant amounts of public financial support 
vested  to  the  sector  (FIFG  and  EFF  account  for  some  10%  of  the  value  of  landings  in 
some coastal areas)40.  

The catching sector 

Although  low  innovation  levels  can  have  many  effects,  they  certainly  prevent  the 
catching sector from adding more value to their products. It also means that production 
costs are higher than they could be.  

Figure 2 - Profitability of EU fishing fleets 

The  issue  of  innovation  is  of  a  particular  importance  for  the  small  scale  coastal  fleet 
(SSCF). 91% of fishing enterprises in this sector own a single vessel, placing them in the 
micro enterprise category. This makes financing innovation particularly difficult, taking 

17 

 
 
into  account  the  risky  nature  of  investments  in  the  sector  and  the  difficult  access  to 
funding of SMEs in the current economic downturn. 

Aquaculture 

As stated above, the EU aquaculture production has not been increasing for the last 15 
years,  and  that  in  spite  of  a  relatively  high  technological  level  and  quality  better  than 
products imported from third countries.  

Figure 3 - Production of aquaculture (Worldwide and EU) 

Evolution of the total aquaculture production in EU-
27 and in the World                                

(reference year 1995: Index based on quantity produced) 

x
e
d
n
I

250

200

150

100

50

0

EU-27 production

Global production

5
9
9
1

7
9
9
1

9
9
9
1

1
0
0
2

3
0
0
2

5
0
0
2

7
0
0
2

9
0
0
2

The  EU  aquaculture  is  exposed  to  many  important  constraints  such  as  competition  for 
space and access to water, lack of level-playing field and high administrative burden. As 
emphasized  in  the  CFP  reform  IA,  the  high  EU  standards  put  EU  aquaculture  at  the 
forefront of sustainable development in the world, but combined with higher production 
costs and the market which is not ready to compensate for more sustainable methods of 
production,  aquaculture  has  a  difficulty  to  compete  price-wise  with  some  third-country 
producers.  

Consumer awareness on aquaculture products and their production methods are limited. 
They  are  not  well  informed  about  the  sustainability  and  the  high  quality  of  the 
aquaculture production in the EU. Given this lack of information the price factor remains 
the  main  driver  of  consumer  choice.  Furthermore,  some  European  fish  farming  sectors 
have been facing repeated “bad press” in recent years, which has tarnished their image. 

New  technologies,  research,  innovation  and  infrastructures  in  the  aquatic  environment 
are  expensive.  The  results  of  the  new  knowledge  and  innovation  projects  are  often  not 
well  disseminated,  especially  to  SMEs  (60%  of  the  EU's  aquaculture  firms  are  micro-
enterprises and 98% are SMEs). 

A  significant  proportion  of  the  assets  of  a  traditional  aquaculture  enterprise  lie  in  the 
value of the stock, which makes any disease or abnormal mortality in the fish stock or the 
suspension of harvesting farmed molluscs a significant risk to the economic viability of 
firms. The same goes for market closures related to the occurrence of marine bio toxins. 

The small size of most EU aquaculture firms makes difficult their access to finance and 
to insurance (where it is available), possibly even more so than SMEs in other economic 
sectors. Aquaculture also has a long production  cycle, which  implies a  significant  time 

18 

 
 
lag between a loan being taken out for site development and sufficient product sales to 
start  making  repayments.  The  long  production  cycles  also  make  it  more  difficult  for 
producers to cope with market price fluctuations. 

Finally,  as  stated  above,  another  important  bottleneck  is  the  lack  of  certainty  for 
economic investors, especially in the marine areas where spatial planning is lacking. 

The  low  economic  viability  of  fisheries  and,  in  particular,  aquaculture,  is  largely  the 
result  of  the  organisation  of  supply  and  of  marketing  and  commercialisation.  In  that 
respect the CMO IA pointed to the fact that EU supply is both diverse and fragmented 
while fisheries and aquaculture Producer Organisations (POs) lack the resources and the 
incentives to organise production efficiently and manage fishing. Furthermore, many EU 
producers  do  not  sell  their  fish  or  aquaculture  products,  but  rather  wait  until  buyers 
come. A large part of their economic fragility comes from their poor understanding of the 
market and a lack of strategic marketing.  

The  current  EFF  includes  measures  to  address  some  of  these  issues.  However,  these 
measures  (linked  to  innovation  and  to  facilitating  the  adoption  of  environmental 
standards)  are  scattered  over  the  different  axes  and,  with  the  exception  of  the 
Netherlands, are not addressed in a strategic manner by the MS. As stated above, in most 
MS the emphasis is put on "simple replacement"41 investments. Axis 4 seems to have a 
high  potential  for  fostering  local  innovation.  In  those  Member  States  where  the  local 
partnerships  started  early,  there  is  already  evidence  of  a  number  of  highly  innovative 
projects42  in  adding  value  to  the  local  products  (e.g.:  marketing  or  processing  of  local 
catches including shellfish or seaweed). However, it is too early to see actual results. 

Understanding and tapping the growth potential in maritime sectors  

Segmentation of maritime policies results in a lack of synergies and a lack of adequate 
impedes  a  clear 
support  for  research  for 
understanding of where the real potential for marine growth exists.  

innovation.  This  also 

technological 

There are areas of potential technological innovation in martime activities which are not 
supported by sectoral or national instruments due to their prospective nature. The lack of 
interoperability  between  sectoral,  national  and  Community  surveillance  systems  can  be 
an example here. The current situation is that whereas data stop at the national borders 
vessels and criminal activities do not. Duplication of efforts at regional, national and EU 
levels  increase  the  economic  costs,  reduce  the  overall  effectiveness  of  surveillance  and 
thus degrades security and safety at sea. This is crucial considering that 90% of Europe's 
external trade is carried out at sea.  

Similarly,  the  lack  of  coordinated  approach  results  in  conflicts  between  different 
stakeholders  –  often  to  the  disadvantage  of  the  fishermen  or  aquaculture  farmers  -  and 
limits the potential for the economic growth. Hence the need for MSP which can balance 
different interests including the environmental aspects, and improve the predictability for 
planning of future investments.  

High fuel/energy consumption in fisheries  
Fishing,  aquaculture43  and  the  processing  sector  contribute  to  CO2  and  other  emissions 
and  hence  to  climate  change.  Global  fisheries  represent  around  1.2%  of  global  fuel 
consumption. 

Based  on  Annual  Economic  Report  data,  it  is  estimated  than  on  average  consumption 
was 0.58 l of fuel per kg of landings in 2007. This figure has been worsening since 2002 
(0.38 l /kg) which most likely can be attributed to the deterioration of stocks.  

19 

 
There  are  nevertheless  very  substantial  differences  between  fishing  gears.  Pelagic 
trawlers  &  seiners  (0.18  l  /kg)  and  dredges  (0.24  l  /kg)  are  those  consuming  less. 
Demersal  (1.32  l  kg)  and  –in  particular  –  beam  trawlers  (2.38  l  /kg)  are  the  most  fuel-
intensive techniques. There are  also significant differences length categories. Generally 
speaking,  the  longest  the  vessel  the  lowest  its  fuel  consumption  per  kg  of  landed  fish. 
Vessels over 40 meters consume far less than the average (0.32 l / kg); those in the 24-
40m category consume 0.53 l /kg. Vessels up to 12 meters (SSCF) consume 0.81 l/ kg. 
Finally, the 12-24m category consumes 0.87 l /kg.  

If successful, the reformed CFP should significantly improve the situation both in terms 
of  absolute  and  relative  fuel  consumption  and  emissions  –  through  the  removal  of 
overcapacity (less vessels fishing the same amount of fish) and through the rebuilding of 
the  stocks  (less  time  necessary  for  the  catch).  With  the  introduction  of  market  based 
system fleets should also become economically viable and more resilient to the increases 
in fuel costs. 

However, investments in energy efficiency represent a short term cost that will only pay 
in the long term, if fuel prices would be sufficiently high. The incentive for the sector to 
engage  in  such  investments  (e.g.:  energy  audits  and  pilot  projects  which  are  possible 
under    the  current  EFF)  seriously  diminishes  as  soon  as  fuel  prices  go  down,  with  the 
result that sudden price surges take the sector unprepared, which immediately threatens 
its profitability.  

The  results  of  the  evaluation,  audits  and  the  ECA  report,  demonstrate  that  such  energy 
efficient  investments  in  particular  with  regard  to  onboard  modernisations  need  to  be 
carefully framed in order to avoid increasing the ability of the vessel to catch fish in the 
current  overfishing  context.  The  same  care  has  to  be  paid  with  financing  engine 
replacement which very easily can increase the fishing capacity of vessels. 

2.4.3.  Social sustainability  

Low attractiveness of jobs in the catching sector and the reduction of employment 
undermine the viability of fishing communities 

The CFP reform IA report referred to the low attractiveness of employment in the sector 
in  particular  for  younger  generations  of  local  people  and  to  the  threats  the  decline  of 
fishing activities represent for many coastal communities dependent on fishing. The CFP 
in  general  and  its  successive  public  funding  tools  have  not  avoided  the  decline  of  the 
employment  and  of  the  attractiveness  of  the  sector  for  new  generations.  From  that 
perspective  it  seems  clear  that  the  role  of  the  public  funding  of  the  CFP  in  ensuring 
sustainable income has been poor at best. 

The decline of fishing activities is already a fact in many coastal areas as the employment 
in the fisheries, since 20 years, has been going down at the constant rate 4-5% per year. 
This is also explained by wages that generally speaking remain below national averages 
and poor working conditions on board. 

Many  of  these  communities  are  reacting  and  new  activities  are  replacing  fisheries  as 
main sources of income and employment. However, some of these coastal areas may not 
have  viable  diversification  alternatives  at  hand.  At  the  same  time  the  employment 
potential  in  other  maritime  sectors  in  the  area  may  not  be  exploited  due  to  the  lack  of 
qualifications.  
In that respect, socio-economic studies on fisheries dependent communities44 have shown 
that in most cases, the alternative employment opportunities are not readily available or 

20 

 
appropriate to the skill sets of fishers, and that the effects on employment will need time 
and adequate support (training, specific investments) to occur. 

Furthermore, the reduction of overcapacity that should result from the CFP reform would 
bring  about  further  employment  losses.  According  to  the  CFP  reform  IA,  these  could 
amount to close to 24% of employment in the modelled fleets (2022 over 2012)45. Some 
further employment losses would take place in the ancillary services sector. Creation of 
some  employment  in  processing  would  not  be  enough  to  compensate  for  the  expected 
losses. 
Even  though  they  represent  26%  of  employment  in  the  fisheries  sector46  women  are 
confronted with a series of challenges. There is a lack of visibility and recognition of the 
contribution women make to the sector and fishing communities: numerous women work 
in  the  family  fishing  enterprise  (e.g.  taking  up  management,  administration,  marketing 
tasks etc.) or in ancillary activities such as net mending, often without a legal status and 
the  associated  social  security.  In  addition  women  have  faced  obstacles  in  access  to 
advisory  and decision-making bodies (incl. resource management), as well as access to 
loans and there are no specific measures, outside Axis 4, under the current EFF.  

3.  THE  JUSTIFICATION  FOR  THE  REFORM  OF  THE  PUBLIC  FINANCIAL  SUPPORT 

INSTRUMENTS 

3.1.  Who is affected by the public financial support instruments and how 

The public financial support instruments are tools to support the CFP and the IMP and 
contribute  to  achieving  its  objectives.  As  a  successful  CFP  and  IMP  are  the  ultimate 
reason of being of public financial support, stakeholders affected are the same identified 
in the CFP reform IA report: 

Table 1 - Key stakeholders in the EU fishing industry  

Description of stakeholder 
EU vessel owners, operators and crew. 

Key interests 
Maintaining profitability and livelihoods. 

Aquaculture producers 

Maintaining profitability and livelihoods 

Business and communities dependent upon 
fisheries for their livelihoods. 

Those processing raw material both imported 
and caught within EU waters 

Sector 
regulators 

National, regional and local bodies regulating 
fishing  

Sector research 

Scientific research bodies contributing to the 
conservation and management of stocks 

Consumers 

Those consuming fisheries products 

Third countries 

Fishing sector in competition with EU fleets. 
Aquaculture producers, exporters to the EU.   

NGOs, the civil 
society and EU 
citizens 

Non-governmental organizations advocating 
sustainable management of fisheries. 
The wider public with an interest in and 
concern for fisheries and the marine 
environment 

21 

Maintaining profitability and livelihoods as 
well as the viability of communities in the face 
of the decline of fishing activities 
Maintaining profitability and livelihoods. 
Increasing value added. Get access to stable 
supplies. 
Optimize public financial support as tool to 
achieve objectives of the policy. Guarantee 
food supply. 
Contribution to an effective fisheries 
management regime through the timely access 
to high quality data. 
Availability, cost, quality and nutritional values 
of fisheries products with varying degrees of 
environmental scrutiny. 
Conflicting interest between those who see the 
EU as export market and source of revenue and 
small local fishing communities that face 
competition from external fleets of the EU on 
access to local resources.  
To maintain fish populations, marine bio-
diversity, and the amenity value of oceans, 
rivers and lakes together with an economically 
and socially sustainable industry. Adequate 
food supply. 

Stakeholder 
Catching sector 
in the EU 

Aquaculture 
sector 
Dependent 
businesses & 
communities  
Processing 
sector 

 
3.2.  Has the EU the right to act? 

According  to  Article  3  (1)  (d)  of  the  Treaty  of  the  Functioning  of  the  EU  (TFEU),  the 
Union  shall  have  exclusive  competence  in  the  conservation  of  marine  biological 
resources  under  the  CFP.  Other  aspects  of  fisheries  are,  under  Article  4  (2)(d)  TFEU, 
shared  competences  between  the  Union  and  the  Member  States.  Article  43(2)  TFEU 
establishes  the  EU  power  to  adopt  the  provisions  necessary  for  the  pursuit  of  the 
objectives of the CFP.   

According to the draft IMP Financial Regulation (2011-2013), the IMP objectives to be 
pursued  through  the  future  funding  are  linked  to  the  following  multiple  legal  basis: 
Articles  43(2)  -  Fisheries,  91(1)  and  100(2)  -  Transport,  173(3)  -Industry,  175  –
Territorial Cohesion, 188 – Research, 192(1) -Environment, 194(2) –Energy and 195(2) 
– Tourism of the TFEU47. As regards Integrated Maritime Surveillance (IMS), it will be 
financed essentially on the basis of sectoral legislation.  

3.2.1.  Subsidiarity and proportionality tests 

According to the MFF Communication, the proposal for the future budget of the EU has 
strong  in-built  pan-European  logic  and  focuses  already  on  "the  policy  areas  where  the 
EU  can  be  more  effective  by  acting  through  the  EU  level  in  the  current  climate  of 
national austerity and financial consolidation". In that respect there is strong subsidiarity 
logic in it as regards the areas and issues it proposes to cover and address.  

Regarding  fisheries,  the  MFF  Communication  refers  to  a  new  European  Maritime  and 
Fisheries Fund (EMFF) structured around 4 pillars: Smart, Green Fisheries, Smart, Green 
Aquaculture, Sustainable and Inclusive territorial Development and Integrated Maritime 
Policy.  The  first  three  pillars  are  under  the  shared  management,  the  last  one  under  the 
direct  centralised  management.  In  addition,  the  EMFF  will  include  accompanying 
measures  in  the  areas  of  data  collection  and  scientific  advice,  control,  governance, 
fisheries  markets  (including  outermost  regions),  voluntary  payments  to  Regional 
Fisheries  Management  Organisations  (RFMOs)  and  technical  assistance.  Two  further 
international  instruments  complement  the  policy:  Fisheries  Partnerships  Agreements 
(FPAs)  and  the  compulsory  payments  to  RFMOs.  As  explained  before,  these  two 
instruments will remain outside the scope of EMFF. 

The  subsidiarity  and  proportionality  for  the  parts  of  the  CFP  falling  under  shared 
competence is as follows: 

Regarding the EMFF itself, its general objective is to support the objectives of the CFP. 
Given the structural problems of the fisheries sector (as explained in the present IA but 
also in the CFP reform IA and the CMO IA reports) as well as the limits on the financial 
resources of MS – in particular in the current economic context - MS are not in a position 
to sufficiently achieve these objectives acting on their own. They can therefore be better 
achieved at EU level by multi-annual financing focussed on the relevant priorities.  

Achieving sustainable fisheries within the field of the exclusive competence of the CFP 
may  imply  negative  social  impacts  for  coastal communities,  particularly  in  the  short  to 
medium  term.  This  is  of  particular  importance  for  coastal  communities  depending  on 
fishing, as the viability of some of them is already precarious today.  

In this context, public intervention maximising value added of the fisheries or allowing 
fishers to find alternative jobs, in particular in the expanding sector of maritime economy 
is expected to be of crucial importance. EU financial support will also set the framework 

22 

 
for  national  state  aid,  thus  preventing  distortion  to  competition  among  the  MS  which 
might undermine the implementation of the CFP reform. 

Many  factors  related  to  the  aquaculture  sector  (e.g.  allocation  of  space,  issuing  and 
renewing of licenses; red tape) have a strong subsidiarity dimension. On the other hand 
strategic choices made at national level may impact the development in neighbouring MS 
or in the whole of the EU. This is due to the fact that many aquaculture sites operate in 
marine ecosystems which go beyond national borders and due to the development of off-
shore aquaculture (which can be towed form one marine area to another or, in the future, 
even  to  waters  within  EU  competence)  and  to  the  increasingly  global  nature  of  market 
for some aquaculture products (such as salmon, sea bass or sea bream). 

Promoting  the  sustainable  development  of  aquaculture  is  also  essential  to  meet  the 
growing demand for fish and seafood in the EU and to ease the pressure on marine fish 
stocks.  It  can  also  divert  demand  from  less  sustainable  stocks  and  increase  the  number 
and range of substitutes for these species. As stated above, all these factors become more 
important  in  the  current  context  of  national  austerity  and  financial  consolidation  and 
given the SME nature of most of firms in the EU aquaculture sector. 

In their conclusions with regard to the EU aquaculture strategy of 2009, both the Council 
and the European Parliament (EP) supported the further financing of aquaculture both in 
the  current  EFF  and  the  new,  future  financial  instrument.  The  EP  stated  in  its opinion 
that it:  

"29. Hopes that the future European Fisheries Fund in support of the reformed Common Fisheries Policy will provide 
for specific budget lines for sustainable aquaculture development and support for investment in that sector, following 
best  environmental  practice,  and  to  promote  economic  activity  and  employment  with  a  particular  focus  on 
technologically innovative plants with a lesser environmental impact (e.g. water purification systems for eliminating 
residues and pollutants), farms that promote fish health and welfare and sustainable forms of aquaculture; 

30. Hopes that this Fund will take into due account the need to provide financial support for enterprises in the sector, 
particularly for SMEs and family-run enterprises, based on their contribution to the social and economic development 
of the coastal area and with the emphasis on remote and border areas".

48 

The  Commission  has  taken  on  board  these  requests  and  the  proposal  on  the  reformed 
CFP  requires  that  MS  prepare  national  strategic  plans  based  on  a  set  of  strategic  EU 
guidelines  to  create  favourable  conditions  for  aquaculture  and  to  improve  its 
competitiveness, to support its sustainable development and innovation, and to stimulate 
diversification. Open methods of coordination may take the exchange of information and 
best practices among Member States a step further. 

Control and enforcement as well as data collection and scientific advice are necessary 
pieces  for  the  exclusive  competence  to  be  exercised  and  the  general  objectives  of  the 
CFP  achieved.  Data  collection  and  scientific  advice  are  core  element  for  efficient 
management  of  fisheries  and  marine  resources;  they  are  the  key  to  a  fully  fledged 
knowledge based policy. Similarly, control activities co-ordinated and co-financed at the 
EU level provide for significant savings and synergies in terms of costs and compliance 
(for example through a joint purchase and use of control vessels). 

Regarding the CMO, according to the new CFP Regulation, measures provided for under 
the CMO need to be consistent throughout the EU to maximize their effectiveness and to 
ensure  the  functioning  of  the  internal  market.  The  compensation  mechanism  for  the 
outermost regions is   

Finally,  as  regards  the  IMP,  the  rationale  for  action  at  EU  level  stems  from  the  cross-
sectoral and trans-national nature of many of the activities involved. EU action is likely 

23 

 
to produce clear benefits by reason of its scale and effects, compared with activities and 
actions pursued only at the level of Member States and regions:  

•  Marine knowledge will not imply investing EU money in data collection or data 
application, but limits itself to data assembly (i.e. pooling data that have already 
been collected) to create accessibility and inter-operability.  

•  Even  though  the  maritime  surveillance  activities  are  carried  out  by  Member 
States,  most  of  the  activities  and  threats  that  they  address  are  transnational  in 
nature. Threat analysis done by one MS is not shared on a systematic basis across 
borders  thus  identified  threats  regularly  remain  without  a  global  response.  A 
Common  Information  Sharing  Environment  (CISE)  is  expected  to  be  developed 
in each MS, in each EU sectoral community and across communities in the EU.  
Only  the  EU  common/central  component  will  be  financed  by  the  Integrated 
Maritime Surveillance (IMS)/IMP budget. The sectoral components (at EU level) 
will  be  financed  by  the  respective  sectoral  funds.  the  national  by  the  MS.  The 
setting  up  of  the  CISE  should  allow  for  technical  improvements,  sectoral 
enhancements and better situational awareness. This process shall also not hinder 
the development of existing and planned sectoral information systems, as long as 
the need for interoperability enabling information exchange with other systems is 
taken into account. 

•  Competence  for  the  MSP  process  will  remain  at  MS  level,  based  on  common 
standards in the context of a proposed EU initiative. However, EU action would 
ensure  that  MS  implement  MSP  in  EU  waters  and  that  they  would  do  so  more 
coherently  through  common  objectives  and  through  effective  cross  border  co-
operation between Member States. Doing so would allow to achieve the potential 
economic  effects  of  MSP  which  are  fourfold:  (i)  enhanced  coordination  and 
simplified decision processes leading  to reduced transaction costs, (ii) enhanced 
legal  certainty  for  all  stakeholders  in  the  maritime  arena,  (iii)  enhanced  cross 
border cooperation and (iv) enhanced coherence with other planning systems. 

•  From  a  maritime  perspective,  issues  may  be  more  often  related  to  sea  basin 
characteristics  and  are  thus  trans-national  by  nature  Given  the  highly  integrated 
and globalised nature of most of the maritime economy, MS are often not able to 
address  the  trans-national  dimension  of  the  Blue  Growth  concept  and  hence  to 
ensure full consistency with the Europe 2020 goals. However, it has to be noted 
that proposals to be brought forward concerning maritime economic sectors as a 
result of the on-going Blue Growth initiative will not necessarily imply additional 
investment but a better focus of interventions on areas which are most promising 
in terms of growth and employment through innovation.  

In  all  cases,  action  at  EU  level  will  not  go  beyond  what  is  required  to  achieve  the 
objectives of the MEFF. 

4.  WHAT ARE THE POLICY OBJECTIVES? 

In line with the CFP reform and the MFF Communication the general objectives of the 
EMFF are the following: 

•  To support the objectives of the reformed Common Fisheries Policy. 

•  To support the further development of the Integrated Maritime Policy. 

24 

 
The future funding instruments is a tool to achieve these objectives. In doing so, it will 
also  contribute  to  the  Europe  2020  strategy,  in particular to three flagship initiatives: a 
resource efficient Europe, an innovation Union and the agenda for new skill and jobs49. 

As  stated  above,  the  focus  of  the  EMFF  would  be  put  on  market  failures  resulting  in 
activities not sufficiently financed by private or national funding. 

It is also important to maximize the effectiveness and the efficiency of the instrument and 
of the available funds by addressing the design issues identified above. On the basis of 
the problem analysis above, the following specific objectives have been defined. 

4.1.  Objectives related to the design of the financial instrument 

Table 2 – Problems and specific objectives: design  

Problem  

Specific objective 

Lack of alignment between EFF allocation criteria and 
the size of the fishing sector. 

Align allocation criteria with the size of the fishing sector. 

Lack of critical mass and concentration 
Too much focus on investments unrelated to key CFP 
objectives and too many individual subsidies with 
limited impact and deadweight effects. 

Ensure thematic concentration on smart green investments and 
territorial development. 

Foster  strategic  thinking  and  favour  collective  approaches, 
without prejudice to other approaches that could develop. 

The ineffective strategic programming leads to a "pick 
and choose" strategy, lacking synergies and coherence.

Improve strategy & programming. 

A  weak  monitoring  and  evaluation  system  impedes 
focus on performance and results. 

Set up a consistent framework for monitoring and evaluation, 
based on common indicators. 

Insufficient  use  of  conditionalities  linking  financial 
support to the achievement of CFP objectives. 

Reinforce  conditionalities  and enlarge  the  scope  of  cross 
compliance. 

Lack of co-ordination with other EU funds intervening 
in fisheries and maritime areas. 

Focus on demarcation instead of co-ordination. 

The administrative burden of fund management and the 
complexity of managing several funding instruments. 

The low level of absorption in some MS. 
Problems linked to direct management. 

Exploit  synergies  with  other  EU  funds  (ERDF,  ESF,  CF, 
EARDF),  including  with  LIFE  funding  and  prioritised  action 
frameworks for NATURA 2000. 

synergies  between  CFP  and 

Exploit 
financial 
instruments.  Simplify  delivery  and  reduce  administrative 
burden. 

IMP 

4.2.  Objectives related to the content of the financial instrument 

Table 3 – Problems and specific objectives: content 
Specific objective 

Problem 

Public  financial  support  has  not 
eliminated 
of 
overcapacity. 

problem 

the 

Eliminate  subsidies 
reducing overcapacity. 

ineffective 

in 

Fishing  has  a  high  environmental 
impact. 

Reduce  environmental 
fisheries.  

impact  of 

25 

 
 
 
 
 
to 

Contribute,  in  the  context  of  the 
the 
fisheries, 
sustainable 
sustainable 
and 
management 
preservation  of  marine  ecosystems 
and  to  the  objectives  of  MSFD  and 
Natura2000. 

Aquaculture  must  contribute  to 
high environmental standards.  

Promote 
aquaculture. 

green 

growth 

in 

Insufficient  supply  of  data  and 
scientific  advice  and  lack  of  co-
ordinated approach to marine data 
do  not  allow  for  a  fully  fledged 
knowledge based policy. 

Improve 
the  availability  of  high 
quality and timely data and scientific 
advice. Ensure compliance with Data 
Collection  Framework,  co-ordinate 
fisheries and IMP related data. 

Insufficient  compliance  with  the 
CFP rules. 

Ensure compliance with CFP rules. 

Lack  of  common  tools  to  regulate 
spatial  deployment  of  economic 
activities  at  sea  and  collaboration 
of 
in 
environmental policy. 

implementation 

the 

Promote  an  integration  of  policies 
enabling 
cross-
border/ecosystem-based  management 
of European sea basins. 

sustainable 

and 

EU  fisheries  and  aquaculture  are 
characterised  by  low  innovation 
levels  and 
insufficient  economic 
viability. 

Increase  innovation  in  particular  in 
the  value-added  of  fisheries  and 
aquaculture products. 

Promote animal health and welfare. 

Insufficient  understanding  and 
tapping  growth  potential  in  the 
maritime sectors. 

Promote  the  use  of  cross-sectoral 
instruments  tackling  segmentation  of 
maritime policies and contributing to 
identification  of  new  growth 
the 
opportunities.   

High  fuel/energy  consumption  in 
types  of 
fisheries  and 
aquaculture 

some 

Reduce 
energy 
fisheries and aquaculture. 

consumption 

in 

Low  attractiveness  of  jobs  in  the 
catching  sector  and  the  reduction 
of  employment  undermine 
the 
viability of fishing communities  

attractiveness  of 

Improve 
jobs, 
(including  gender  equality)  and 
support  the  viability  of  communities 
fisheries, 
in  areas  dependent  of 
including 
to  other 
maritime sectors. 

reconversion 

5.  WHAT ARE THE POLICY OPTIONS? 

The  No  Policy  Option  -  Options  2  and  2a  analysed  in  the  CFP  reform  IA  report50 
included the elimination of all EU public financial support (as well as of the CMO). The 
economic and social performance of options 2 and 2a was found to be significantly worse 
than  these  of  options  1  and  1a  (which  translate  into  Option  EFF+  in  this  IAR  –  see 
below).  On  the  economic  side  this  is  due  to  short  term  negative  economic  impacts 
(stemming  from  the  introduction  of  a  discards  ban  and  the  transition  to  MSY)  not 

26 

 
 
compensated  by  public  assistance  targeting  more  selective  gear,  marketing  and 
innovation in particular. On the social side, short to mid term reduction of employment in 
the catching sector would remain not addressed.  

In  addition,  the  discontinuation  of  funding  for  data  collection,  scientific  advice  and 
control is not a feasible option, as it will mean that the CFP would be deprived of any 
knowledge  base  for  formulating  policy.  Similarly,  without  co-ordinated  and  co-funded 
control  policy,  the  efficiency  of  control  would  be  drastically  reduced  with  dramatic 
consequences for the compliance.  

In the same wake, lack of funding for IMP would amount to the discontinuation of the 
policy development so far and missed growth and job opportunities at a time when other 
countries,  such  as  the  US,  dynamically  develop  this  policy  viewed  as  one  of  the  most 
promising avenues driving future economic development.  

Furthermore, the lack of funding for governance would put an end to the dialogue with 
the  sector,  established  in  the  aftermath  of  the  2002  CFP  reform.  Finally,  without 
voluntary contribution to RFMOs, the EU would lose credibility in this organisations and 
legitimacy to projects internationally the principles of sustainable fishing.  

For  these  reasons  the  "no  policy  option"  is  discarded  and  not  taken  any  further  into 
account  in  this  IAR.  This  is  in  line  with  the  conclusions  of  the  CFP  reform  IA  report 
where the preferred options include reformed EFF and CMO as well as an IMP financial 
instrument. It is also in line with the MFF Communication. 

The No Policy Change Option. The Status Quo Option in the CFP reform IA explicitly 
included  the  continuation  of  the  current  EFF  and  IMP  financial  instruments  under  an 
unchanged  CFP.  The  Status  Quo  Option  was  analysed  but  it  was  found  to  perform 
significantly worse than any of the CFP reform also analysed. As a result it was not the 
preferred  Option.  It  is  nevertheless  kept  in  the  present  IAR  as  a  baseline  to  help 
comparing the impacts of the different reform options.  

5.1.  Elements common to all reform options 

The three reform options developed below are alternative avenues to achieve the general 
and specific objectives of the EMFF. There are nevertheless common elements to each of 
them.  These  common  elements  are  to  a  large  extent  pre-determined  by  the  MFF 
Communication as well as by the proposal for a regulation of the European Parliament 
and of the Council on the Common Fisheries Policy (the new basic Regulation)51. These 
common elements are the following:  

•  The  global  financial  allocation  for  the  EMFF,  international  fisheries  and  RFMOs  is 
€6.7  billion,  as  stated  in  the  MFF  Communication.  The  key  elements  of  EMFF 
architecture  are  also 
aquaculture, local development and IMP).  

the  MFF  Communication  (fisheries, 

implied  by 

those 

•  The distribution of the global financial allocation between policy areas is the same in 
all  the  options,  in  line  with  the  analysis  contained  in  the  ex-ante  section  of  this 
document52. 

•  Most  of  the  direct  fleet  subsidies  (the  current  EFF's  Axis  1)  are  discontinued, 
including permanent (scrapping) and temporary cessation, in line with the conclusions 
of  the  CFP  reform  IA  report  and  the  new  basic  Regulation.  The  analysis  of  the 
Commission on this point coincides with the criticism of some MS and many NGOs   
that these measures actually do not eliminate overcapacity. The MFF Communication 

27 

 
foresees  the  re-deployment  of  inefficient  direct  fleet  subsidies  in  line  with  the 
objectives of the Europe 2020 Strategy.  

•  In  line  with  the  simplification  objective  of  the  MFF  Communication,  the  new  CMO 
regulation  will  be  integrated  into  the  EMFF.  Only  one  tool  of  market  intervention 
(storage  aid)  is  to  be  temporarily  maintained  (to  be  phased  out  until  2018)  and  the 
assistance to POs will be significantly increased.  

•  The scheme to compensate for the additional costs incurred in the marketing of certain 
fishery products from the outermost regions of the Azores, the Canary Islands, French 
Guiana  and Reunion will be integrated  into the EMFF and its amount maintained at 
current levels. 

•  Critical  mass,  which  is  another  aim  of  the  MFF  Communication,  is  to  be  achieved 
through more emphasis on collective actions, including through PO, and on increased 
budgets for FLAGs under the territorial development pillar. In line with the views of 
stakeholders,  more  emphasis  will  also  be  put  on  projects  requiring  strategic  plans  – 
such as marketing and production plans implemented by PO and local development in 
general (as it requires the preparation of integrated strategy of local development) . 

•  For the IMP part of funding, as the overall objectives of the IMP remain unchanged 
and confirmed by Council53 and the European Parliament54, the major issue tested in 
this IA is related to the need of greater integration of the CFP into IMP, which was 
also a repeated request during the consultation process. 

•  All the objectives related to the ex-EFF part of the funding are addressed in Option 1 

and the results of this analysis are included in other options. 

•  Beyond  these  elements,  the  financial  support  for  governance  (dialogue  with 
stakeholders,  communication)  will  be  adapted  to  the  content  of  the  new  basic 
Regulation (in particular the replacement of ACFA by an Advisory Committee). The 
same  holds  true  for  the  voluntary  contribution  to  RFMOs.  Therefore  no  alternative 
options are tested for these two instruments.  

•  The  allocation  criteria  will  be  aligned  with  the  size  of  the  fishing  sector.  The 
allocation method will take into account two criteria currently used for the allocation 
of the EFF envelope among non-convergence regions: (i) the value of the production 
of  the  fisheries,  including  aquaculture  and  processing  and  (ii)  the  employment  in 
fisheries, aquaculture and processing industry. Additional criteria will account for the 
importance of the SSCF in the fishing sector. This criterion is intended to reflect the 
importance of SSCF for fisheries communities in terms of jobs, the fact that most of 
them  are  micro  enterprises  and  their  greater  economic  vulnerability  in  the  current 
context (but also in view  of the  fact that TFC, which increase economic viability of 
fishing operators will remain voluntary for these fleets). 

•  There was near unanimous support in the consultation for the continuing involvement 
of the Commission regarding data collection and control. Allocation criteria for these 
items of expenditure stay the same as at present, although allocations will be made for 
7 years instead of one.  

•  The  need  for  improved  conditionality  was  also  an  important  result  of  the  public 
consultation  and  FIFG  and  EFF  evaluations.  Furthermore,  the  MFF  Communication 
requires that conditionality is introduced into all programmes and instruments so that 
MS  and  beneficiaries  demonstrate  that  the  funding  received  is  being  used  to  the 
achievement of the EU policy priorities. Accordingly, the use of conditionalities will 
apply to all reform options and will be based on the following elements: (i) the scope 

28 

 
of  eligibility  and  the  content  of  the  measures  –  in  particular  the  elimination  of 
scrapping and temporary cessation, (ii) the compliance with the control obligations, in 
line with the proposal for new CFP Regulation adopted by the Commission on July, 
13th - a beneficiary from the fisheries sector must have a clean control track, in terms 
of significant infractions as defined in the control regulation, at least one year before 
applying for EU assistance, (iii)  the compliance with the IUU Regulation – a vessel 
on the list of IUU vessels cannot receive aid from the Fund; if aid was received before 
the vessel was put on the list it should be repaid, on the pro rata basis (iv) compliance 
with  data collection obligations by MS - lack of compliance will result in interruption 
and  suspension  of  payments  (v)  ex  ante  conditionality  for  aquaculture  part  of  the 
spending – MS should adopt National Strategic Plan for Aquaculture, as described in 
the new CFP basic Regulation, aiming at the removal of obstacles for the development 
in aquaculture. If this is not the case MS should make a clear commitment concerning 
preparation of such a strategy by 1st of January 2016. 

•  Finally,  monitoring  and  evaluation  of  the  policy  will  be  improved  by  setting  up  a 
common framework and by defining and using a common set of indicators to measure 
progress towards the EMFF objectives. 

5.2.  Description of the options 

5.2.1.  The status quo option55 

The Status Quo (SQ) developed in the CFP reform IA report is taken here as the main 
baseline option. It amounts to the continuation of the current CFP, including the EFF, the 
CMO and the IMP financial instrument. Nevertheless, the Status Quo takes into account 
recent  legislation,  in  particular  LTMPs,  in  the  pipeline,  the  Control  Regulation  and  the 
IUU  Regulation.  That  way,  it  amounts  to  the  CFP  as  it  will  be  in  place  by  the  end  of 
2012.  

5.2.2. 

 Option 1: “EFF +” 

Option 1 is equivalent to options 1 and 1a in the CFP Reform IA report56. However the 
specific  contents  of  the  different  axis  are  more  developed.  The  Option  addresses  the 
problems  related  to  the  lack  of  policy  links  and  synergies  between  CFP  and  IMP 
financial instruments under the existing financial architecture. In that respect, this Option 
amounts as a supplementary baseline to assess the differential impacts resulting from the 
integration of all CFP and IMP financial instruments. 

Financial architecture:  

•  CFP  and  IMP  financial  instruments  continue  to  be  implemented  separately;  yet  an 
effort is made to better co-ordinate their scope, objectives and delivery, in particular 
through  the  use  of  a  similar  timetable  for  their  adoption  for  the  period  2014-2020, 
coinciding with the adoption of new basic regulation. 

Content, programming and delivery of the new fund: 

•  Common  Strategic  Framework  and  partnerships  contracts  allow 

strategic 

programming and focus on CFP and Europe 2020 objectives. 

•  Thematic concentration and limits put on types of eligible investment should move the 
funding  away  from  "simple  replacement"  investment  aid  towards  smart,  green 
investments in fisheries and aquaculture; 

29 

 
•  Priority given to collective projects such as those implemented by local partnerships 
(under  the  current  Axis  4),  marketing  and  production  plans  implemented  by  POs, 
partnerships  between  fishermen  and  scientists  and  projects  implemented  by  other 
collective  bodies  (groups  of  fishermen  or  aquaculture  farmers,  networks).  This 
priority  will  be  achieved  by  the  design  of  the  measures,  financial  allocations  and 
eligibility criteria;  

•  Preferential treatment for SSCF; 

•  Current  Axis  4  (territorial  development)  will  be  reinforced  with  the  focus  on  value 
added  and  diversification  and  better  coordination  with  other  Local  Development 
initiatives.  

5.2.3.  Option 2: “EFF + Integration” 

Option 2 builds on Option 1 by proposing to merge the financial instruments supporting 
the CFP into a single fund. IMP remains as a separate instrument. 

Financial architecture:  

•  All financial instruments of the fisheries sector are merged into one fund, but continue 
to  be  managed  separately  under  the  same  budgetary  methods  of  implementation 
(shared or direct management) as it is the case now.  

Content, programming and delivery of fund:  

•  Same as EFF+. 

5.2.4. 

 Option 3: “EMFF Convergence” 

Option  3  takes  the  convergence  of  the  funds  one  step  further  via  the  extension  of  the 
scope  of  the  fund  under  shared  management.  Actually,  the  integration  of  all  existing 
fisheries and maritime instruments into a single fund (with the exception of FPAs and the 
EU membership of RFMOs), is provided for in the Maritime and Fisheries Policy annex 
to the MFF Communication. 

Financial architecture:  

•  Full  integration  of  all  CFP  and  IMP  instruments.  Integration  of  data  collection, 
control, CMO and the instrument for outermost regions under the shared management. 
All  the  shared  management  parts  of  the  single  fund  are  covered  by  the  scope  of 
Common Strategic Framework (CSF) and Partnership Contracts. 

Content, programming and delivery of fund:  

•  As  Option  1  but  expanding  the  scope  to  address  some  elements  of  IMP  under  the 

territorial development pillar (current Axis 4). 

5.2.5.  Synthetic view of options 

The following table provides a synthetic view of the above three reform options against 
status quo. It also links the options with the major problems and objectives of the future 
financial instrument. 

30 

 
 
 
Specific objectives 
related to delivery 
mechanism 

Align allocation 
criteria with the size 
of the fishing sector 

Table 4 – Description of options 

Specific objectives 
related to contents

Option 1 "EFF+" 

Option 2 "EFF+ 
integration" 

Option 3 "EMFF 
Convergence" 

As Option 1 

 As Option 1 

Ensure thematic 
concentration on 
relevant objectives, 
linked to 
environment and 
innovation Increase 
funding for local 
sustainable 
development 

Allocation criteria 
for future funding 
instrument based on 
three criteria: (i) 
employment in the 
fishing sector (ii) the 
value of production 
of the fishing sector 
(iii) the share of 
small scale fleet  

As Option 1 

As Option 1 

Ensure thematic 
concentration key 
CFP objectives. 

Ensure thematic 
concentration on 
relevant objectives, 
linked to 
environment and 
innovation  

The ex EFF funding 
reorganised around 3 
pillars with 
refocused measures: 
(i) Green, sustainable 
fisheries (ii) Green, 
sustainable 
aquaculture (iii) 
Sustainable and 
inclusive local 
development  

Foster strategic 
thinking and 
collective/ grouped 
approaches 

Improve 
programming 
process and develop 
delivery 
mechanisms based 
on objectives and 
results rather than 
absorption. 

Develop synergies 
between CFP and 
IMP funding and 
other EU funds 
intervening in 
maritime and 
fisheries sector. 

Ensure thematic 
concentration on 
relevant objectives, 
linked to 
environment and 
innovation. 
Increase funding 
for local sustainable 
development  

Priority given to 
collective projects 
based on strategies: 
(Producer 
Organisation) (ii) 
collective actions 
carried by other 
bodies (iii) local 
partnerships  

Develop further 
synergies with local 
development 
strands under other 
EU funds  

Use of Common 
Strategic Framework 
and partnerships 
contracts for EFF 
part of the funding 

As Option 1  

As Option 1  

As Option 1 but 
Common Strategic 
Framework 
includes also other 
CFP instruments 
(without including 
them into 
partnership 
contracts) 

As Option 2 but 
stronger co-
ordination and the use 
of partnership 
contracts for 
instruments included 
into the funding 
under the shared 
management part 
(control, data 
collection, market 
measures, 
compensation for 
outermost regions 

Set up consistent 
framework for 
monitoring and 
evaluation, based on 

Ensure thematic 
concentration on 
relevant objectives, 
linked to 

Reinforced use of 
performance and 
monitoring for all the 
CFP and IMP 

As Option 1  

As Option 1 but 
performance 
indicators, monitoring 
and evaluation for ex-

31 

 
the same indicators 
for MS 

environment and 
innovation. 
Increase funding 
for local sustainable 
development  

financial instruments 

EFF part, data 
collection, control 
and CMOs integrated 
in the same 
framework under the 
shared management. 

Cross-compliance 
building on the 
existing links. 

Full cross-compliance 
under the shared 
management 

6.  COST-EFFECTIVENESS AND EX ANTE EVALUATION 

The MFF Communication sets both the 2014-2020 financial allocation for maritime and 
fisheries (€6.7 billion in 2011 prices for the EMFF, including market measures, FPA and 
the RFMOs) and big pillars on the EMFF will focus. However it leaves leeway for the 
measures to be eligible under the EMFF. This section looks at these measures from the 
point of view of their cost-effectiveness. The analysis is not complete though. Only these 
measures or categories of measures for which there are some (quantitative or qualitative) 
data are addressed below.  

6.1.  Environmental sustainability 

The  problem  description  has  shown  that  the  contribution  of  the  EMFF  in  the 
environmental sustainability area can be useful primarily in the reduction of discards and 
by  catches,  in  the  foregone  income  of  aquaculture  farms  in  Special  Areas  of 
Conservation under the Habitats Directive and Special Protection Areas under the Birds 
Directive  (including  Natura2000  sites),  in  scientific  advice  and  data  collection  and  in 
control.  

Regarding the reduction of discards, the proposal for the reformed CFP includes discard 
ban. Such policy should induce a change in selectivity of gears and fishing techniques in 
particular from 2015 onwards. However, in the short term, until 2015, the move to catch 
quotas, the obligation to land all the catch as well as other technical (such as the closure 
of  zones)  and  market  measures  (confiscation  of  income)  could  entail  significant 
increased costs and reductions of fleets income (to be added to similar impacts resulting 
from the move to MSY and the discontinuation of fleet subsidies). 

The combination of all these effects could bring about very serious short term difficulties 
for parts of the catching sector, with the risk that some of the fleets segments that discard 
most would become unviable in  the short term. Such an evolution could jeopardise the 
success  of  the  anti-discard  policy  and  result  in  a  high  social  costs  for  coastal 
communities. 

In  order  to  address  these  unwelcomed  effects,    a  short  term  push  to  these  fleets  with 
inherent high discard rates will be justified thus facilitating the quick entry into force of 
the discard policy by supporting the adoption of selective gears. The possible evolution 
and the logic of such an intervention are shown in the graph below.  

32 

 
 
 
 
Figure 4 Expected revenues for haddock quota 2009 – 2030; changes with regard to a CFP 
reformed, no discard policy 

70 

60 

50 

40 

30 

20 

10 

-

)
s
n
o

i
l
l
i

M
€
(

e
u
n
e
v
e
R
d
e
t
a
m

i
t
s
E

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030

Haddock no change (€)

Haddock with  discard reduction policy (€)

Haddock with  discard reduction policy 20% value undersize(€)

Results  of  some  pilot  projects  (in  particular  the  South  West  England  Project  50%  to 
reduce  discards  of  beam  trawlers)  show  the  use  of  selective  gears  could  immediately 
reduce  discards  by  40  to  70%,  without  requiring  any  further  changes  in  fishing 
behaviour57.  

Regarding  cost,  estimations  show  that  the  cost  of  gear  replacement  for  the  whole  EU 
demersal and beam trawler fleets (excluding 250 UK vessels >12 m which have already 
acquired selective gears) would amount to circa €125 million for one gear's replacement 
per  vessel  of  €250  million  for  two.  In  add ition,  some  development  costs  may  be 
experienced  by  the  industry  to  develop  efficient,  selective  gears.  Estimations  indicate 
that a maximum of €50 million for the whole of  the financial period would be sufficient, 
as  the  experience  of  other  countries  (Norway)  shows  that  in  the  mid  term  the 
implementation  of  a  discard  policy  is  sufficient  in  itself  to  foster  the  development  of 
selective gears by the industry.  

Regarding  aquaculture  farms  in  Special  Areas  of  Conservation  under  the  Habitats 
Directive and Special Protection Areas under the Birds Directive (including Natura2000 
sites),    they  may  provide  environmental  services,  such  as  wildlife  conservation  and 
biodiversity  and  landscape  effects,  water  quality,  recreation  and  even  archaeological 
benefit, which society does not pay for and which can limit their economic performance. 
These are difficult to measure and value in the absence of harmonised EU data.  
In  terms  of  cost  and  benefit  only  proxies  can  be  used58.  The  evaluation  of  an  agri-
environmental  scheme  in  the  UK  show  payments  to  farmers  in  the  environmentally 
sensitive  areas  in  the  period  1994  to  2003  was  around  £212  million  and  that  benefit 
estimates exceeded costs, sometimes by many times59. On the basis of that, an estimation 
of €300 million could be a reasonable amount. 

The  CFP  reform  IA  has  already  shown  the  crucial  importance  of  improving  scientific 
advice and data collection for the success of the reform and the risk that not doing so 
will carry out. Estimations in the CFP reform IA indicate that an extra €20 million per 
year will be required to have a reasonably guarantee that needs will be covered.  

The costs of data collection and scientific advice amount at present to circa 0.66% of 
the GVA of the catching sector. This is comparable to the combined public and private 
sector  costs  of  collecting  all  environmental  data  in  the  maritime  sector  within  the  EU. 

33 

 
 
 
 
Importantly,  the  EU  expenditure  influences  the  way  the  national  money  on  data 
collections is spent and ensures a better coordination of the investments between MS and 
a better quality of data. It avoids duplication of work and increases the efficiency of the 
investments carried out by MS. 

An  efficient  control  is  crucial  for  the  success  of  the  reformed  CFP  through  the 
consolidation  and  modernisation  of  control  rules,  through  the  widespread  use  of  new 
technologies and through laying down new control methodologies and procedures as well 
as effective and dissuasive sanctions. It is expected that some tools such as simplification 
of the CFP and the use of transferable fishing concessions would have a positive impact 
on compliance; however, other tool such as the discard policy would imply an increase in 
control activities at sea and at port, in particular in the short term. 

The EMFF will ensure that new technologies are effectively put into operation to allow 
data  validation  and  cross-checks.  It  should  in  particular  help  the  equipment  of  fishing 
vessels  and  administrations  with  Vessel  Monitoring  System,  Electronic  Reporting 
System, databases that are essential for the correct functioning of the EU control system 
and  contribute  to  smart  growth  by  promoting  innovation  and  knowledge  transfer 
throughout the EU. This scheme is complementary with national budgets and actions as 
it  reduces  the  administrative  costs  related  to  the  collection  of  these  data  in  MS.  It  will 
also  result  in  fully  automated  reporting  mechanisms,  which  will  replace  many  of  the 
current TAC and effort reporting obligations by MS.  

Funding  needs  for  control  are  estimated  at  €325  million  for  new  technologies,  €160 
million for joint acquisitions and €115 million for other activities.  

In terms of costs and benefits, the EU expenditure influences the way the money is spent 
by MS, avoids duplication and ensures a better coordination of the investments between 
MS  (including  the  joint  acquisition  and  use  of  patrol  vessels  and  aircraft  by  the  MS 
belonging to the same geographic area) and a better quality of data. Important efficiency 
gains  will  also  stem  from  the  increased  quality  of  data.  The  interim  evaluation  of  the 
Second Financial Instrument (Regulation 861/2006) pointed out that the execution rate of 
control  projects  was  significantly  higher  for  projects  having  benefited  from  an  EU 
contribution  than  that  of  projects  for  which  co-financing  was  rejected  by  the 
Commission, thus indicating that the EU financial contributions are relevant and induce 
MS to implement projects they would otherwise not consider. 

Beyond these main areas, there are still some additional environmental measures which 
could  be  covered  but  which  cannot  be  quantified  at  the  moment,  such  as  actions  to 
reduce  the  environmental  impacts  of  aquaculture  (e.g.  by  assisting  to  extension, 
modernisation,  construction  of  the  aquaculture  facilities  with  a  view  to  substantially 
reduce the possible environmental impact in terms of water pollution, nature protection 
or  improved  energy  efficiency;  supporting  conversion  to  some  specific  production 
processes,  etc.)    or  incentives  for  the  fishermen  for  contributing  to  the  sustainable 
management  of  marine  ecosystems  (collecting  lost  fishing  gear  and  other  debris, 
monitoring and collecting data in Marine Protected Areas, assisting in gear replacement 
to  reduce  the  impact  on  the  sea  bottom). Beyond  these there are public concerns  about 
the  environmental  impacts  of  the  fisheries  from  a  broader  ecosystem  perspective  of 
maintaining biodiversity and the health of marine ecosystems. 

6.2.  Economic sustainability: innovation gap  

There is a deficit in innovation activities between the fisheries sector and the rest of the 
economy. A rough estimation of such "innovation gap", calculated by comparing labour 
productivity  (measured  in  gross  value  added/  employee)  in  the  EU  fisheries  sector 

34 

 
(catching and aquaculture) with the EU average, would be around 25.7%. This is shown 
in the following table (using OCDE data).  

Table 5 – Estimation of innovation gap: Differences between GVA/employee total and in fisheries 
(catching and aquaculture) in 2007 

Member 
State 

GAV/employee 
total 

GVA/employee 
fish 

Difference 
€ 

Diff % over 
total 

DE 

F 

BE60 

DK 

SF 

ESP 

NL 

GR 

HU 

IRE 

IT 

UK 

52831 

66033 

68169 

48000 

54250 

4831 

9,14% 

11783 

17,84% 

105714 

-37545 

-55,08% 

498771 

502112 

57784 

45756 

58596 

42495 

48000 

32822 

63425 

30672 

-3341 

9784 

-0,67% 

16,93% 

12934 

28,27% 

-4829 

-8,24% 

11823 

27,82% 

5577912 

1494030 

4083882 

73,22% 

79701 

54902 

39528 

36241 

26573 

32860 

43460 

28329 

54,53% 

51,60% 

6668 

16,87% 

SWE 

604463 

456667 

147797 

24,45% 

PT 

PL 

Slowakia 

Slovenia 

Austria 

Czech 

Estonia 

EU 

25956 

67842 

25487 

31531 

59148 

608367 

325770 

22111 

25143 

35388 

12491 

23339 

3845 

14,81% 

42699 

62,94% 

-9901 

-38,85% 

19040 

35810 

60,38% 

60,54% 

343798 

264569 

43,49% 

148779 

176991 

54,33% 

25,72% 

Iceland 

6181526 

10463881 

-4282355 

-69,28% 

Norway 

793436 

854214 

-60779 

-7,66% 

Source: STAN database for structural analysis. OECD (values in national currency) 

By  applying  that  result  to  the  EUROSTAT  figure  of  labour  productivity  for  the  EU 
economy 
some 
the  gap 
€13,300/year/employee  for  the  catching  and  aquaculture  sectors  together.  The  fact  that 
labour productivity in the sector in landlocked countries (where most of the activity is in 

(€52,000/year/employee), 

could  be 

estimated 

at 

35 

 
 
 
 
 
the  aquaculture  field)  is  also  significantly  below  national  averages  (e.g.:  Austria  or  the 
Czech  Republic)  demonstrate  that  the  innovation  gap  in  the  aquaculture  sector  is  also 
significant. 

It  is  interesting  to  note  that  in  countries where transferable  fishing concessions already 
exist  (Denmark  and  the  Netherlands  together  with  Iceland  and  Norway),  labour 
productivity  in  the  sector  is  actually  above  national  averages.  For  that  reason,  it  is 
expected  that  the  introduction  of  these  concessions  for  industrial  fleets  would 
significantly  contribute  to  closing  the  innovation  gap.  However  these  rights  are  not 
expected  to  be  fully  operational  before  2017.  In  addition,  they  will  not  apply  to  the 
SSCF.  

According to the CFP reform IA report, under Option 1, GVA/employee will increase by 
147% by 2022 when compared to 2012. However, the increase for the SSCF will be just 
65%.  The  increase  for  all  industrial  vessels  together  would  be  165%.  Hence,  there  is  a 
risk  that  the  SCCF  lags  behind  in  terms  of  innovation.  It  is  estimated  that  the  SSCF 
account  for  circa  65%  of  total  employment  (around  40%  in  full  time  equivalent 
employments) in the catching sector or 93,000 employees. That leaves a maximum gap 
to fill in the region of €1,236 million for  these fleets in the period 2014-2020 (assuming 
that the productivity of the rest of the economy remains stable).  

A  similar  result  would  be  for  the  aquaculture  sector  which  employs  ca  55,000  people 
(2007).  The  cost  of  introducing  innovative  production  processes  and  products  in  the 
aquaculture  sector  is  particularly  high.  For  example,  intelligent fish tanks, allowing for 
cost  reduction  through  control  and  water  quality  in  each  tank,  amount  to  €40,000  per 
plant.  Another  example  of  innovation  in  the  commercialisation  phase  -  Modified 
Atmosphere Packaging keeping the products fresh and of better quality for longer period 
of  time,  costs  ca  €30,000  per  plant.  The  cost   of  marketing  and  promotion  campaigns 
oscillates between €50,000 and 200,000.  

Furthermore,  the  contribution  of  the  EU  to  some  of  the  associated  costs  (e.g. 
Environment Impact Assessments for start-ups) and to create effective advisory services 
would help in restoring some form of level playing field. 

A  very  significant  part  of  the  required  innovation  rest  with  marketing  related 
measures. The reformed CFP puts an enhanced emphasis on collective actions which so 
far have proven to be quite useful; POs in so far as market measures are concerned. The 
238 existing Pos represent ca 50% value of the first sale of fishery products, that is ca €4 
billion  per  year.  If  all  the  POs  adopt  marketing  and  production  plans  they  would  be 
entitled  to  receive,  in  line  with  the  recently  adopted  new  CMO  regulation,  financial 
assistance  equal  to  4%  of  this  value,  €160  million.  With  the  co-financing  level  at  50% 
this would mean €80 million annually or 
2020.  This  amount  does  not  take  into  account  the  new  POs  which  may  be  created  in 
fisheries and aquaculture in the coming years. 

€560 million for the whole of the period 2014-

The current level of funding should be maintained for market intervention measures (€15 
million/year), even if the current six market intervention mechanisms will be simplified 
to one single storage aid mechanism. It is expected that this mechanism will be widely 
used and that the participation of new MS in the scheme will significantly increase. The 
compensation scheme for outermost regions should also continue (€15 million/year).  

In  addition,  it  is  foreseen  to  create  a  European  Market  Observatory  for  Fishery  and 
Aquaculture Products which would provide a global overview of the European markets 
for  fisheries  products  through  harmonised  economic  information,  data  and  analysis  all 
along  the  supply  chain.  This  would  make  possible  to  better  plan  producers'  supplies 

36 

 
(fishing), production (aquaculture) and sales with a view to increase income. The cost of 
such  service  has  been  estimated  at  €5  milli on  a  year.  Finally,  in  order  to  amplify  the 
expected positive effects of the observatory it should be complemented by other actions 
in  the  field  of  fisheries  markets  such  as  seminars,  publications,  external  assessments, 
studies, evaluations of market policy and EU-level communication campaigns. 

6.3.  Social sustainability: territorial development of coastal areas 

According  to  estimations  done  on  the  basis  of  the  Leader  programme  and  experience 
with the EFF until now, the above amount could allow creating some12,500 jobs by 2022 
plus 4,500 extra jobs in processing and marketing. These should compensate for at least 
most of the job losses in the catching and ancillary services sectors resulting from Option 
1 in the CFP reform Impact assessment.  

For  the  period  2007-13  the  EFF  budget  for  Axis  4  is  €567.4  million  with  ca  260  local 
action  groups  created  (€2.2  million  EFF  per 
measure some MS made very limited use of this axis (France €5 million, Ireland – €1.5 
million).  Taking  account  of  predicted  needs  and  assuming  the  establishment  of  310 
partnerships an amount of the order of €1,057 million would be needed. This means an 
average budget per FLAG of €3.4 million. 

local  action  group).  As  this  was  a  new 

6.4.  Allocation  between  green  sustainable  fisheries,  green  sustainable 

aquaculture and inclusive territorial development pillars.  

The  lacking  elements  of  the  ex-ante  calculations  and  the  fact  that  ultimately  the 
allocation of the money between pillars will be the matter of the negotiations between the 
Commission  and  the  MS,  make  very  difficult  such  an  estimate.  Indicatively,  the  local 
development pillar, in line with the calculation above should account for ca 25% of the 
ex EFF envelope. 

For  aquaculture,  the  allocation  under  EFF  amounts  to  11%  of  the  overall  allocation  – 
taking  into  account  the  needs  for  financing,  in  particular  linked  to  environment  and 
innovation,  this  allocation  should  increase  to  ca  25%.  This  increase  should  be  possible 
through  (i)  broader  and  focused  measures  targeting  environment  and  innovation  and 
removing  spending  items  such  as  scrapping  and  (ii)  the  introduction  of  the  ex  ante 
conditionality linked to the aquaculture strategy defined in the new CFP regulation, with 
the  focus  on  the  removal  of  bottlenecks  impeding  investments  in  the  aquaculture.  The 
adoption of guidelines for aquaculture and Natura2000 may further clarify the rules for 
aquaculture  farmers  and  public  authorities  and  may  be  also  helpful  in  that  respect61. 
Sustainable fisheries would account for the remaining 50%.  

6.5.  IMP, RFMO and governance 

IMP:  Sustained  and  increased  funding  for  the  IMP  is  necessary  to  fully  implement  it. 
The estimate of the financing needs for cross-cutting instruments is that these activities 
would require roughly €360 million to €420 million over 7 years.  

By 2013, only a limited part of the marine knowledge architecture will have been set up. 
The  EU  spends  more  than  €1  billion  a  year  on  collecting  public  marine  data.  Yet 
professionals who require the data are confronted with barriers when they try to find and 
get  permission  to  use  existing  public  data.  By  assembling  standards,  nomenclatures, 
classifications and formats from different sectors and Member States, EMODNET makes 
marine data accessible and enhance knowledge and innovation for industries that exploit 
marine resources. In Ireland, an expenditure of €70 million on marine mapping has been 

37 

 
shown  to  result  in  benefits  of  €415  million  to  the  fisheries,  aquaculture,  biodiversity, 
renewable  energy,  energy  exploration  and  aggregate  industries–  a  return  of  a  factor  of 
six62. The IA for EMODNet concluded that the full implementation of the programme, at 
a cost of €20 to €30 million per year, woul d result on a minimum annual benefit of €60 
to €200 million in increased competition and in reduced operational costs of €300 million 
per year63. For instance, a 25% reduction in uncertainty in sea-level rise would result in 
€100 million of direct savings in coastal defence infrastructure for public authorities. 

The purpose of funding of the IMS is to remove sectoral policy barriers and to overcome 
the  current  lack  of  interoperability  between  sectoral,  national  and  Community 
surveillance  systems,  the  limited  capacity  to  face  transnational  threats  and  to  avoid 
duplication.  Sharing  surveillance  information  across  sectors  of  activities  and  Member 
States will lead to significant saving as it will reduce directly the operational costs of the 
Member  States.  The  current  estimate  is  that  an  expenditure  of  €15  million  per  year  for 
the establishment of the CISE will maximise the efficient use of existing data and avoid 
costly  duplication64.  It  will  generate  a  better  situational  awareness  of  activities  at  sea, 
impacting on maritime safety and security, border control, maritime pollution and marine 
environment, fisheries control, general law enforcement, defence as well as the economic 
interests of the EU, so as to facilitate sound decision making. 

IMP funding will also be necessary to support the implementation of MSP in MS and the 
development of a common approach to MSP in the EU. For instance, a reduction of 1% 
in transaction costs is estimated to lead to positive economic effects ranging from € 170 
million  up  to  €  1.3  billion  by  2020.  Especially,  accelerating  investments  in  wind-farm 
and aqua-farm activity would generate up to € 600 million by 2020 65.  

A major component of a common framework on MSP will be cross border co-operation. 
It  is  therefore  essential  that  EU  action  (possibly  including  legislation)  on  MSP  will  be 
accompanied by cross-border projects in the different sea basins in the EU where MS can 
test  in  practice  the  implementation  of  MSP  in  shared  sea  areas  in  order  to  build  up 
expertise  based  on  practical  experience.  Based  on  the  expected  costs  for  similar  MSP 
projects already launched and those planned to be launched for period until 2014, there 
would be a need for around €8.5 million for the period 2014-2020. 

Also other forms of supporting capacity-building and exchange of best practices would 
be necessary for an effective implementation of MSP within a common framework, such 
as  setting  up  expert  networks  and  organising  stakeholder  events.  The  financial 
requirements  for  such  activities  are  currently  estimated  at  around  €0.5  million.  Further 
work  on  developing  MSP  should  include,  inter  alia,  studies  and  projects  on  how  to 
address MSP in the high seas and on data use for MSP implementation. These projects 
are estimated to require around €1 million during the period 2014-2020.  

In order for the IMP to deliver fully on the objectives of Europe 2020 untapped sources 
of  sustainable  growth  derived  from  marine  living  and  non-living  resources  (Blue 
Growth) need to be identified and a policy framework at EU level conducive to growth, 
innovation  and  employment  needs  to  be  devised.  In  that  respect,  some  €10  million  per 
year would be devoted to:   

•  Calls for proposals for projects on maritime innovation. Projects should be of a cross-

cutting nature, involving at least two maritime sectors. 

•  Awareness building: workshops, conferences and other dissemination actions. 

•  Support for maritime cluster development. 

38 

 
•  Other  specific  measures  to  be  identified  on  the  basis  of  the  findings  of  the  "Blue 
Growth" study, the key elements from the Europe2020 flagship projects and feedback 
from Member States and economic stakeholders, including analysis of regulation. 

Finally, there will be a need for financial support to the sea-basin approach of the IMP. It 
is very difficult at present to obtain reliable facts and figures that would make it possible 
to assess the status and changes of the economic, environmental and social conditions in 
Europe's sea basins. Identifying the strengths of the maritime activities within a sea basin 
would  facilitate  the  development  of  sea-basin  specific  maritime  policy  in  an  integrated 
manner and would be of high relevance to the Europe 2020 objectives. The activities to 
be financed would include studies and stakeholder activities, including the building-up of 
sea-basin  specific  stakeholder  platforms,  awareness  raising,  information  dissemination, 
communication  activities  and  tools.  Financial  needs  are  currently  estimated  at  around 
€30 million during the period 2014-2020. 

Non  obligatory  contributions  to  Regional  Fisheries  Management  Organisations 
(RFMOs): There should be an increase in the contributions made to these organisations: 
€11 million are programmed for 2013 and an incr ease by €2 million per year is foreseen 
in the following years. The increase will support scientific research and enhance control 
and  compliance,  notably  by  developing  countries,  through  projects  in  cooperation  with 
these partners, either bilaterally or regionally. This increase is necessary to enhance the 
environmental sustainability aspects of the new CFP in external waters. 

Governance (including RACs):  No significant increase of expenditure is expected with 
regard to that under the current period (€50 – 60 million for the whole period).  

6.6.  Intended allocation of EMFF funds per area of activity 

The above discussion would justify an allocation of funds per area as that shown in the 
table below: 

Table 6 – Areas of expenditure EMFF 

Areas of expenditure 

Approximate % of total EMFF allocation 
2014-2020 (without allocations to FPAs and 
obligatory contribution to RFMOs )  

Ex - EFF part (out of which) 

  -  Fisheries 

  -  Aquaculture 

   - Local development 

Voluntary 
to 
organisations including RFMOs 

contribution 

international 

Data collection and scientific advice 

Control - contribution MS 

Market  Policy  including  compensation  to 
outermost regions 

Governance 

IMP 

39 

67 - 70% 

30 – 35% 

15-17,5% 

15-17,5% 

1,5 -2,0% 

7 -8% 

10 - 11% 

2,5 – 3% 

0,8-1% 

6 – 7% 

 
7.  METHODOLOGICAL APPROACH FOR THE ANALYSIS OF IMPACTS OF THE DIFFERENT 

OPTIONS 

The analysis  of  impacts below is based  on a methodology which to the extent possible 
builds on the one developed for the CFP reform IA. However, the impacts of subsidies 
were  not  systematically  analysed  there  because  it  was  not  possible  to  separate  their 
impact in terms of income or contribution to profitability. 

These difficulties remain in the current IA. In view of that, 3 indicators were selected to 
deal with differential impacts which are then assessed from a qualitative point of view:  

Impact 

Environmental impact 

Economic impact 

Social impact 

Table 7 - Indicators 

Main impacts 

Indicator 

Reduction of impact of fisheries on 
the environment 

Evolution of discards 

Closure of the innovation gap in 
fisheries and aquaculture 

GVA per employee in the fishing  
and aquaculture sectors 

Creation of jobs outside the 
fisheries sector in communities 
dependent on fisheries 

Number of jobs created in 
fisheries-dependant areas  

8.  ANALYSIS OF IMPACTS 

8.1.  Option  Status  Quo:  Continuation  of  the  current  policy  (including  the 

current EFF) 

As  stated  in  the  CFP  reform  IA  report,  the  SQ  option  results  in  modest,  insufficient 
progress towards achieving the objectives. 

Environmental sustainability is not achieved. Environmental indicators improve slowly 
over the period 2013-2020 and targets are not met as a consequence of discarding, poorly 
assessed  stocks  and  unaddressed  overcapacity.  Fish  stocks  will  experience  even  more 
modest  improvements  if  the  control  regulation  is  less  effective  at  reducing  unreported 
catches  than  what  it  is  assumed  in  the  option.  Relatively  high  levels  of  departure  from 
scientific  advice  are  likely  to  continue.  The  absence  of  an  active  discard  policy  and  of 
actions  intended  to  facilitate  the  transition  to  more  selective  fishing  practices  allow 
concluding that the level of discards would not get reduced significantly. 

Regarding  overcapacity,  modeled  fleets  will  reduce  in  size  (in  number  of  vessels)  by 
only 6.6% in 2017 and by 15.1% by 2022 (compared with estimated number of vessels in 
2012). Fleet size reduction would be larger for those MS that decide to adopt TFCs.  

Economic  sustainability:  There  would  be  a  small,  gradual  improvement  in  economic 
performance,  associated  with  the  improvement  in  fish  stock  status  and  the  reduction  in 
fleet size; however the economic viability of many fleets would remain under threat.  

GVA  per  employee  will  see  a  modest  grow  of  31.3%  by  2022  (all  vessel  categories 
together).  Looking  at  fleets  sizes,  GVA/  employee  for  the  SSCF  will  increase  by  just 
18% in 2022. That of industrial  vessels (>12 meter) will grow by 30.3% These figures 
are sufficiently low to argue that most likely there would not be any significant progress 
in closing the innovation gap in the fisheries, in particular as regards the SSCF; on the 
contrary,  the  gap  might  become  wider.  It  is  not  possible  to  make  any  calculation 
regarding  aquaculture.  However,  as  tools  do  not  change  it  is  expected  than  the  current 
problems will remain. 

40 

 
Social sustainability: Employment in the catching sector is predicted to decline by 10%, 
allowing  that  crew  wage  per  FTE  would  increase  by  negligible  3%  in  2017  and  6%  in 
2022.  Crew  wages  are  expected  to  remain  below  national  averages,  so  that  ceteris 
paribus  the  attractiveness  of  the  sector  would  remain  constant  or  continue  to  decline. 
Employment trends in ancillary services are negative in view of the expected fleet size 
reductions. Many coastal communities would continue to suffer from the decline in the 
importance of fisheries, although some might benefit from an incremental improvement 
in  the  status  of  some  fisheries.  In  the  light  of  the  experience  so  far  it  is  likely  that  the 
current Axis 4 of the EFF would allow creating some employment alternatives in coastal 
communities. This impact, however, will be limited by the small overall size of Axis 4 
and insufficient budgets allocated to many FLAGs. 

The  generalized  failure  to  achieve  objectives  allows  concluding  that  maintaining  the 
current EFF would not be cost-effective. 

8.2.  Option 1 “EFF +” 

To  a  large  extent,  impacts  of  EFF+  are  largely  the  same  as  those  of  options  1  and  1a 
described  and  analysed  on  the  CFP  reform  IA  report.  Emphasis  will  be  put  here  on 
additional  positive  impacts  that  could  reasonably  be  attributed  to  a)  the  content  of  the 
EMFF  reflecting  the  strong  link  to  CFP  objectives  implying  concentration  on  green, 
smart  investment  and  local  development  and  more  synergies  with  IMP  b)  better 
coordination of the different financing tools of the CFP.  

In terms of environmental sustainability, the financial support to the transition towards 
selective  gears  should  speed  up  the  entry  into  force  and  effects  of  the  discard  policy. 
Pilot  projects  show  that  reductions  in  the  region  of  40  to  70%  of  discards  can  be 
immediately achieved by introducing selective gears in beam and demersal trawler fleets, 
at the costs referred to in Section 6 above. 

As regards economic sustainability, section 6 above explains already the gains expected 
from options 1 and 1a) in GVA per employee in fisheries. It is reasonable to expect that 
the  introduction  of  TFC  for  industrial  fleets  would  close  the  innovation  gap  for  such 
fleets, at the latest towards the end of the period. The increase in GVA per employee for 
the SSCF (+65% for the period 2012-2022) does not appear to be high enough to ensure 
closing  entirely  the  innovation  gap  for  this  fleet  segment.  However,  the  support  to 
innovation,  in  particular  in  processes  and  products  closer  to  the  market,  including  in 
marketing  and  commercialisation  activities,  should  allow  reductions  in  production  cost 
and  increases  in  income  that  should  accelerate  the  pace  at  which  the  SSCF  closes  the 
innovation  gap.  According  to  rough  estimations  reductions  of  over  20%  in  productions 
costs and similar increases in income could be achieved. 

Regarding  aquaculture,  strengthened  support  to  environmental-friendly  aquaculture,  to 
the development of new production techniques and to product and market innovation will 
contribute  to  an  increase  in  GVA  and  productivity.  The  lack  of  reliable  and  complete 
statistics on aquaculture does not enable impacts to be accurately quantified, however it 
is realistic to consider they would be in the same range as those obtained in fishing, i.e. a 
reduction of 20% of production costs in 2022 and an increase of + 25% in income. 

As  regards  social  sustainability,  options  1  and  1a  of  the  CFP  reform  IA  resulted  in  a 
contraction  of  the  catching  employment  in  the  modelled  fleets  of  close  to  24%  in  the 
period  2012  to  2022  (slightly  over  14,000  jobs)  plus  an  additional  reduction  of  17% 
(1,500 jobs) in ancillary services. Employment in processing was expected to increase by 
4% (1,200 jobs)66.  

41 

 
The increased focus on value added within the equivalent to the current Axis 4 will allow 
creating  alternative  job  opportunities  for  fisheries  communities  and  developing  new 
activities  in  areas  dependent  on  fisheries  (main  opportunities  are  in  other  sectors  of 
maritime economy, tourism, processing and marketing, ancillary industry). It should also 
support  fishermen  to  access  these  new  sources  of  employment  thus  mitigating  the 
negative  impact  on  the  social  situation  in  communities  dependent  on  fisheries  by 
promoting diversification and supporting the creation of alternative jobs. It is estimated 
that the territorial pillar will create around 12,500 new jobs together with an additional 
4,500  jobs  in  the  marketing  and  processing  sector  thanks  to  the  marketing  measures 
under the green fisheries pillar. This is expected to compensate for most of the losses in 
the catching and ancillary services segments, taking also into account that a part of the 
employment reduction in the fisheries will result from demographic processes. 

Management costs should remain similar to those related to the current EFF 2007-2013, 
although some minor “investment costs” might not occur again. Indeed the shift in 2007 
towards producing a single OP and strengthening the MCS brought new costs, some of 
which were “one off” costs (need to modify the management system and rules, need to 
recruit  and  train  new  staff,  misunderstandings  and  misinterpretation  of  new  rules  in 
relation to audit requirements, etc.). Given the current estimated costs and gains due to 
increased  experience  and  potential  further  simplification,  it  could  be  expected  that  the 
administrative  costs  (calculated  as  the  share  of  technical  assistance  out  of  the  total 
budget)  would  represent  around  3%  of  future  EFF+  budget.  This  amounts  to  a  small 
saving over the current EFF (around 3.72% of the EFF budget). 

The  reduction  might  be  limited  if  new  actions  are  launched  requiring  some  new  skills 
and  adaptations  of  existing  management  systems.  For  example,  an  increased  focus  on 
innovation  might  lead  to  the  need  for  a  strong  technical  assistance  and  high-level 
expertise  within  the  management  structures  at  MS  level  (which  will  have  to  assist 
beneficiaries in developing relevant projects). 

At  EU  level,  the  administrative  costs  would  also  remain  at  a  similar  level  to  the  EFF, 
after  the  2007  simplification  of  programming  structure  (27  OPs  at  the  level  of  the  MS 
instead of 60 OPs at the regional level).  

Regarding  the  co-ordination  of  CFP  and  IMP  financial  instruments  some  piecemeal 
progress could be achieved due to the fact that all these instruments enter into force on 
January  1st,  2014,  following  the  entry  into  force  of  a  new  basic  regulation.  In  practice 
however, as all these financial instruments would be negotiated and adopted separately – 
sometimes as part of the negotiations of a much more important envelope, as in the case 
of the CMO for fisheries and aquaculture products funded under EAGF, they would have 
a  clear  tendency  to  follow  their  own  logic  and  possible  gains  of  initial  co-ordination 
could hence be watered down.  

The use of the Common Strategic Framework (CSF) and the Partnership contracts (which 
will replace the NSP) will address the lack of strategic approach and allow for a refocus 
on  EU2020  objectives.  The  CSF  will  replace  the  current  approach  of  establishing 
separate  sets  of  strategic  guidelines  and  define  specific  objectives  and  performance 
indicators  for  the  funds  covered.  The  Partnership  Contracts  will  quantify  these 
commitments for the MS; Operational Programmes can then be focus on how to translate 
the strategic directions contained in CSF and on the quantified commitments made in the 
Partnership Contracts into the concrete financial allocation and use of specific measures. 
Such an approach will bring programming into the same timeline thus avoiding current 
problem of MS focusing first on the adoption of OP under larger funds, to the detriment 
of EFF Operational Programmes. 

42 

 
The  CSF  and  the  Partnership  contracts  are  expected  to  radically  enhance  the 
coordination between funds. The "demarcation line" currently used to define the scope 
of each fund would be replaced by a strong co-ordination mechanism. The potential for 
such a co-ordination can be demonstrated on two examples.  

Firstly,  the  future  funding  should  seek  to  further  develop  the  use  of  the  financial 
engineering. However, for a relatively small amount of funding and taking into account 
the  financial  mechanisms  developed  for  regional  and  rural  development  policy,  it  does 
not  make  much  sense  to  set  up  new  mechanisms  for  the  purposes  of  fisheries  or 
aquaculture.  Instead,  the  existing  ones  should  be  used,  in  particular  under  the  rural 
development  policy  where  lending  to  agriculture  and  fisheries  sector  (aquaculture  in 
particular) is quite similar.  

Secondly, Local Development strands of the EMFF will be aligned with similar strands 
foreseen within the EAFRD (Leader), the ERDF and the ESF. A common "Community-
based" approach will be defined for the 4 Funds and the local partnerships will be offered 
the possibility to utilise all the four funds in a complementary way in the framework of 
an integrated local strategy. When appropriate, a "lead fund" could be established, linked 
to the main policy domain(s) of the programme. The lead fund's interventions would be 
complemented through specific priority axes by interventions from the other fund. This 
would allow the local partners to develop an integrated strategy for their area where the 
role of each fund would be specified.  The EMFF intervention would remain focused on 
fisheries  and  maritime-related  projects,  but  in  the  framework  of  a  larger  strategy, 
ensuring a better coordination of the different interventions at local level. 

A  much  stronger  focus  on  results  and  performance  would  be  built  into  programme 
design and implementation. Programmes would contain a clear articulation of the change 
sought, on how this would contribute to the CFP objectives and the EU 2020 goals, and 
how spending the resources on particular interventions will contribute to change. It will 
also include critical milestones towards the achievement of objectives. These milestones 
would be agreed between the Commission and the Member States in the context of the 
negotiation  of  the  Partnership  Contracts  and  Operational  Programmes  and  provide 
rationale for the use of conditionalities. 

These milestones could be established on the basis of a number of indicators related to 
the  CFP  objectives  and  the  EU2020  goals.  The  progress  towards  milestones  should 
provide robust information on delivery. The existence of such a performance framework 
within the partnership contract or the OPs could form the basis for a number of different 
incentive/sanction  mechanisms  which  should  allow  for  better  enforcing  conditionalities 
for the use of the fund: 

–  It could provide the basis for a peer review process in the context of a political debate. 

–  Satisfactory progress could be linked to disbursement at EU or national level. Where 
progress  was  unsatisfactory,  resources  could  be  held  back  and,  in  severe  cases, 
reallocated between priorities or programmes. 

–  It could form the basis for the allocation of a possible national or EU reserve. In this 
case,  the  main  objective  of  the  reserve  would  be  to  ensure  that  additional  available 
resources are not allocated to poorly performing programmes.  

In view of the above, there would be a significant cost-effectiveness. 

43 

 
 
8.3.  Option 2: EFF+ “Integration” 

Given  that  the  content  of  this  option  is  very  similar  to  that  of  Option  1,  the 
environmental,  economic  and  social  impacts  of  Option  2  would  in  principle  be 
equivalent.  However,  the  strategic  integration  of  the  structural  and  market  instruments 
should ensure better synergies, reduce the potential for duplication and trigger additional 
leverage  effects.  These  effects  are  not  quantifiable  but  are  not  expected  to  be  very 
substantial.  It  is  also  possible  that  these  positive  additional  effects  could  liberate  funds 
that  could  be  invested  in  increasing  the  financial  support  with  regard  to  discard 
reduction, accelerating the pace at which the innovation gap will be closed as regards the 
SSCF  and  aquaculture  and  for  territorial  development.  This  will  be  possible  if  the 
integration allows for an increased efficiency of the policy as far as delivery is concerned 
(achieving the same results with less funds). 

Regarding  the  better  co-ordination  of  CFP  and  IMP  financial  instruments  some  more 
progress could be achieved due to the fact that all CFP instruments would be grouped in 
one  fund  adopted  and  negotiated  with  MS  at  the  same  time.  Furthermore,  these 
instruments  would  be  covered  by  the  CSF,  which  would  allow  for  better  exploiting 
synergies with the other EU funds. However, the potential for such a co-ordination would 
be limited, as centrally managed funds would be covered only to a very little extent in the 
Partnership  Contracts.  Moreover,  the  major  potential  for  such  a  co-ordination  concerns 
IMP, which would remain outside the scope of the future fund.  

lead 

The  merging  of  the  current  EFF  with  other  financial  instruments  in  the  fisheries  sector 
this  option, 
to  a  slight  reduction  of  administrative  costs.  Under 
might 
implementation  and  management  modes  will  remain  unchanged.  Each  instrument  will 
continue  to  be  managed  separately  and  under  the  same  budgetary  methods  of 
implementation:  data  collection,  control  and  CMO  measures  will  still  be  management 
centrally at EU level (direct management) whilst EFF measures will be managed by MS 
(shared management).  

Assuming  that  a  saving  of  3%  could  be  achieved  in  managing  the  additional  funding 
brought within the EFF after merging, it could be expected that the administrative costs 
(calculated  as  the  share  of  technical  assistance out of the total budget) would represent 
around 2,91% of the future budget. 

Overall, this Option should bring about high cost-effectiveness. 

8.4.  Option 3: EMFF “Convergence” 

for  policy  co-ordination,  simplification  and 

The  extension  of  shared  management  to  the  non-EFF  instruments,  adds  a  significant 
additional  potential 
reduction  of 
administrative burden. In particular, for environmental sustainability, the integration of 
the  IMP  into  the  future  fund  would  help  to  improve  management  of  natural  resources, 
notably through the development of the cross-cutting tools of the IMS and MSP. Better 
situational awareness in real time would improve fisheries control and enforcement: by 
providing  financial  assistance  for  fisheries  control  and  enforcement,  that  allows  for 
cross-sectoral data exchange, it would be possible to enhance the use of (i) these data for 
other surveillance purposes and (ii) of surveillance data from other sectors for the benefit 
of  fisheries  control  and  enforcement.  Data  collection  activities  should  also  profit  from 
this  integrated  approach,  simplifying  and  reducing  administration  costs  for  MS  and  the 
Commission, while at the same time allowing the latter to easily check implementation of 
data collection provisions.  

44 

 
Moreover,  MSP  will  facilitate  the  interactions  of  the  fisheries  sector  with  other  sectors 
using the same maritime space and enhance the sustainable deployment of activities 

For  economic  and  social  sustainability,  the  integration  of  the  CFP  funding  with  the 
IMP  might  help  fisheries  communities  to  increasingly  benefit  from  new  opportunities 
generated  in  other  maritime  related  activities,  in  particular  those  related  to  emerging 
maritime  sectors.  In  particular  fishermen  and  fish  farmers  are  expected  to  increase 
involvement  in  data  collection,  in  ecosystem  monitoring  or  in  activities  aiming  at 
restoring the quality of marine and aquatic environment (such as collecting waste at sea 
and lost fishing gears). Although it is impossible to quantify these in quantitative terms, 
closer integration will facilitate funding for a diversification of employment prospects in 
fisheries areas. 

This option allows for supporting the interoperability of data gathered for the CFP with 
other  marine  data  through  the  IMP  European  Marine  Observation  and  data  Network. 
Using the same protocols and standards for fisheries data as for other marine data allows 
them  to  be  processed  using  the  same  procedures.  The  two  types  of  data  can  then  be 
combined in a way that allows the impact of fisheries on other activities and vice versa to 
be  determined  more  easily.  This  integration  would  reduce  the  costs  of  nearly  all 
industries operating offshore and could make other activities such as cabling or pipeline 
tendering more economically viable. 

In  terms  of  simplification,  the  increased  integration  of  the  CFP  financial  instruments 
under  shared  management  is  expected  to:  (a)  allow  for  a  reduction  of  the  number  of 
spending procedures and management and control systems and (b) facilitate investments 
the  programming  on  a  multi-annual  basis,  thus  reducing  the  need  for  annual 
programming exercises for both the MS and the EU. For example, for market measures 
shared  management  means  no  need  for  annual  decisions  of  the  Commission  for  each 
market intervention tool.  

In the mid term this new management methods should lead to a signification reduction in 
administrative costs. Nevertheless this reduction might not be visible in the short term 
due  to  potential  new  “one  off  costs”  necessary  to  implement  new  management  and 
control systems that cover the new scope of measures. After such an adaptation period, 
the  shift  from  separate  management  (each  instrument  having  it  own  management  and 
MCS)  towards  unified  management  and  processes  should  result  in  a  decrease  of 
management  costs.  These  benefits  can  be  obtained  only  if  processes  are  effectively 
harmonised. 

The  move  to  shared  management  should  alleviate  the  administrative  burden  for  the 
institutes responsible for data collection and scientific advice as financial administration 
for  the  whole  OP  will  be  done  by  a  centralised  managing  authority.  The  possibility  to 
pre-finance part of the total allocated budget for data collection will allow MS to better 
plan  and  carry  out  their  activities  at  the  start  of  the  OP  because  of  difficulties  to  co-
finance the national contribution (in particular in the face of budgetary restrictions). 

Assuming that a saving of 10% could be achieved through full integration of all funding 
instruments, it could be expected that the administrative costs (calculated as the share of 
technical assistance out of the total budget) would represent some 2.70% of the budget. 

In  terms  of  monitoring  and  evaluation,  bringing  data  collection  and  control  under 
shared  management  would  allow  for  using  a  single  monitoring  and  evaluation 
framework,  allowing  for  a  much  simpler  creation  of  conditionalities  linked  to  the 
compliance with these two policies. 

In the end the cost-effectiveness of this Option should be very high. 

45 

 
9.  COMPARING THE OPTIONS: CONTRIBUTION TO THE EUROPE 2020 STRATEGY  

9.1.  Comparison of impacts 

The  comparison  of  the  three  reform  options  (EFF+,  EMFF  integration  and  EMFF 
convergence) shows that in all cases positive impacts exceed these of the SQ Option. 

For  environmental  sustainability,  Option  3  could  bring  additional  small  to  medium 
improvements  in  terms  of  scientific  advice  and  data  coverage  and  quality  compared  to 
the other two options. One reason for this would be the integration between IMP, control 
and  DCF  databases.  Most  of  the  impact  however,  would  come  from  the  strongest 
conditionality covering the ex EFF part, data collection and control.  

In  economic  sustainability  terms,  any  option  will  imply  a  significant  improvement  in 
closing  the  innovation  gap  in  fishing  (particularly  as  regards  the  SSCF)  and  in  the 
aquaculture sector with regard to the SQ Option. However models do not allow isolating 
these impacts from improvements due to the transition to MSY and the introduction of 
transferable  fishing  rights.  Option  3  could  perform  better  in  that  respect,  as  the  better 
integration  of  CFP  into  IMP  might  open  up  some  exchange  between  fishing  and 
technologies used in other maritime fields. 

In social sustainability terms, under all three options a focus on territorial development 
should compensate for al least most of the employment lost in the catching and ancillary 
services  sectors.  Option  3  has  the  highest  potential  in  that  respect  due  to  the  stronger 
synergies between different policy strands. For example, in cases of projects conducted 
in a given area by Producers Organizations on the one hand and Fisheries Local Action 
Groups on the other, the integration of financing should give more opportunities for both 
bodies  to  work  together  and  ensure  the  consistency  of  their  marketing  strategies  and 
generate additional employment sources. The same effect might be expected with regard 
to  the  outermost  regions,  where  currently  three  instruments  (CMO,  the  scheme  to 
compensate for the additional costs incurred in the marketing of certain fishery products 
and EFF) operate independently.  

Yet  another  example  is  a  closer  integration  with  the  IMP  under  the  local  development 
pillar.  It  should  better  help  fishing  communities  located  in  coastal  areas  to  spot  and 
benefit  from  additional  income  and/or  new  job  opportunities,  particularly  in  other 
maritime related activities. In general terms, integration will bring about better coherence 
with other polices and instruments. 

Finally Option 3 performs significantly better than the two other reform options in terms 
of simplification and reduction of administrative costs and burden. This is due to the 
fact that the implementation method would be radically modified as the data collection, 
control and market measures will be managed together with EFF measures under shared 
management covering 90% of the expenditure (65% under the two other options). In the 
mid term this approach should significantly reduce administrative costs and burden due 
to  the  unified  approach  in  terms  of  management  and  control,  including  reporting, 
monitoring and evaluation. 

In terms of cost-effectiveness, all reform options will be cost-effective, but Option 3 will 
exceed the other two. 

46 

 
9.2.  Contribution to the Europe 2020 strategy 

In so far as the new financial instrument would contribute to achieve the objectives of the 
reformed CFP and a better integration of the IMP and the CFP, it will also contribute to 
achieving the objectives of the Europe 2020 strategy. 

The contribution would mainly focus on three flagship initiatives: i) a resource efficient 
Europe, ii) an innovation union and iii) the agenda for new skills and jobs. 

Regarding  the  first  initiative,  the  transition  to  sustainable  fisheries  (where  the 
contribution  of  the  new  financial  instrument  will  mainly  focus  in  the  reduction  of 
discards) and aquaculture production, the reduction of the impact of fisheries (including 
fuel  consumption)  and  aquaculture  on  the  ecosystems,  the  improvement  of  scientific 
advice  and  data  collection,  a  more  effective  control  and  an  increased  coordination 
between  fishing,  aquaculture  and  other  maritime  activities  would  improve  resource 
efficiency. 

Regarding the second initiative, the focus on innovation at all levels of the production, 
marketing  and  distribution  chain  in  fisheries  and  aquaculture,  if  successful  would 
certainly contribute to closing the innovation gap in the EU. The improved availability, 
coverage  and  quality  of  data,  resulting  both  from  the  focus  on  scientific  advice  and 
economic data and from the coordination between IMP (marine knowledge, IMS) and the 
CFP would improve the foundations for that. 

Regarding the third initiative,  an increased attractiveness of the fishing sector, together 
with  actions  in  the  field of diversification of skills and jobs in coastal areas, helped by 
actions in the IMP field (in particular in the area of MSP), should help to the agenda for 
new skills and jobs. 

The  above  description  of  impacts  shows  that  three  reform  options  would  positively 
contribute  to  the  Europe  2020  strategy.  However,  the  additional  positive  impacts  of 
Option  3  support  the  view  that  the  contribution  of  Option  3  would  exceed  that  of  the 
other two. 

10.  THE PREFERRED OPTION 

On this basis Option 3 seems to perform much better than the Status Quo and offer some 
advantages over the other two reform options so that, in the end, it is to be considered the 
preferred option. Although this result is to some extent anticipated in the Maritime and 
Fisheries Policy annex to the MFF Communication, the analysis carried out in this IAR 
confirms that view. 

Table 8 - Comparison of options 2 

Level of achievement of target value under each option 

Indicator 

Status Quo 

EFF+ 

EFF+ 
Integration 

EMFF 
convergence 

Environmental sustainability 

Reduction of discards (%) 

Economic 

GVA/employee 
(index), including aquaculture 

in  the  fishing  sector 

2 

2 

2 

2 

2 

3 

0 

0 

47 

 
 
 
 
 
 
 
 
 
 
Social 

Number  of  jobs  created  in  fisheries-
dependent  areas  (%  of  compensation  / 
jobs reduction in the catching sector) 

Effectiveness and efficiency of delivery 

Reduction  of  management  costs:  share  of 
Technical assistance (in % of total budget) 

Strategic fit, focus on results, simplification

Cost  effectiveness 

TOTAL SCORING 

0 

0 

0 

0 

0 

2 

0 

2 

1 

9 

3 

1 

2 

2 

3 

2 

3 

3 

12 

16 

Performance  targets  met  and/  or  very  significant  improvements  of  the 
situation 

Legend 

Performance targets substantially met and/ or significant improvements of the 
situation 

Performance  targets  not  met,  but  little  change  in  the  situation  and  small 
improvements 

Performance targets not met and/or worsening of the situation 

3 

2 

1 

0 

11.  MONITORING AND EVALUATION 

As  stated  in  section  2.3.1  above,  the  weak  monitoring  and  evaluation  system  has 
contributed  to  the  lack  of  focus  on  results  and  performance  which  explains  the 
deficiencies of the current public financial support. 

Hence  the  EMFF  should  have  a  strong  monitoring  and  evaluation  system,  based  on 
common performance indicators allowing assessing the extent to which its objectives are 
being achieved. The system would be based on following components: 

-  A framework of common indicators:  

o 

linked to the structure of the policy framework; 

o  allowing to assess policy implementation against priorities and targets; 

o 

leaving  the  possibility  for  MS  to  define  their  own  custom  indicators  in 
addition to those made compulsory by the Commission. 

-  A set of agreed targets between EU and MS: 

o  These  targets  will  define  the  expected  results  on  a  specific  set  of  results 

indicators;  

o  They  will  be  defined  at  the  level  of  the  EU  in  the  Common  Strategic 

Framework; 

o  The  translation  of  EU  targets  at  national  level  will  be  defined  in  the 

partnership contracts and/or the operational programme. 

48 

 
 
 
 
 
 
 
 
 
-  Annual implementation reports including reporting information on progress made 
towards  objectives  measured  by  the  indicators.  These  reports  will  be  used  to 
verify the conditionalities 

-  Annual examination of programme implementation by the Commission. 

-  Ongoing evaluation 

-  Assessment of the quality of the national monitoring systems to be performed to 

assure the reliability of reported data on common indicators. 

-  Capacity building, to support implementation and evaluation of the fisheries and 

maritime policy. 

–  Reinforced  monitoring  and  evaluation  at  the  level  of  Fisheries  Local  Action 
Groups,  in  line  with  the  provisions  made  by  the  other  funds,  including  a 
reinforced use of self-evaluation techniques. 

The result (performance) indicators related to key EMFF priorities should be included in 
the  EMFF  Regulation,  whilst  the  output  indicators  could  be  discussed  with  the  MS  in 
meetings with a sub-group of the existing EFF Committee before their inclusion  in  the 
Implementing Regulation.  

The following table presents some potential indicators which may provide performance 
framework for the EMFF Regulation. Annual reporting on these indicators will provide 
an  indication  of  the  performance  of  each  Operational  Programme  and  an  input  to  the 
Annual Activity Statement.  

49 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 10 – Monitoring indicators  

Specific objective 

Result indicators 

Current situation 

Target  

General 
Objective 

Achieve 
Environmental 
sustainability 

Reduce 
environmental 
impacts 
fisheries 

the 

of 

Reduce 
environmental 
impacts 
aquaculture 

of 

Unknown, data will be 
available in 2012, with 
the next data call.  

Info  available  at  the 
level  of  pilot  projects 
shows  that  the  use  of 
selective  gears  allow 
decreasing  discards 
by up to 50%, 

Unknown, data will be 
available in November 
2011. 

Linked 
discards rate. 

to 

the  evolution  of 

Source:  National  monitoring 
system 
or  Data  Collection 
Framework 

to 

the 

Linked 
energy 
consumption  per  ton  produced. 
Seriously  limited  use,  as  it  does 
not  capture  the  fact  that  some 
environmentally  friendly  types  of 
increased 
require 
aquaculture 
energy supply. 

Source:  National  monitoring 
system 
or  Data  Collection 
Framework 

Improve  scientific 
knowledge  

Number  of  assessed  stocks 
divided by total exploited stocks.  

Source: ICES 

advice 
Scientific 
for  45%  of 
exists 
commercial 
stocks; 
trend  decreasing  or 
stable. 

to 
as 
for 

close 

As 
100% 
possible 
commercial 
stocks 

Achieve 
economic 
sustainability 

Reduce 
the 
innovation  gap  in 
fisheries (SSCF) 

Reduce 
the 
innovation  gap  in 
fisheries 
(industrial fleets) 

in 

 GVA/FTE 
sector 
divided  by  average  GVA/FTE 
national economy.  

fishing 

Source: Annual Economic Report 
for EU fleets 

in 

 GVA/FTE 
sector 
divided  by  average  GVA/FTE 
national economy.  

fishing 

Partly incomplete data 
for  GVA/FTE  in  the 
fishing 
fleets  exist. 
Data  for  aquaculture 
available  November 
2011. 

Source: Annual Economic Report 
for EU fishing Fleets 

Reduce 
the 
innovation  gap  in 
aquaculture 

GVA/FTE  in  aquaculture  sector 
divided  by  average  GVA/FTE 
national economy.  

Increase 
efficiency 
fishing 

energy 
in 

Fuel  consumption 
divided by volume of landings  

in  volume 

670  litres  per  one  ton 
of fish in 2008. 

Source: Annual Economic Report 
for EU fishing Fleets.  

50 

 
  
 
 
 
 
  
 
  
  
 
 
 
  
 
 
 
 
  
 
  
 
  
 
 
  
 
 
Improve  market 
organisation 

Number  of  POs  /  Number  of 
associated 
and 
aquaculture farmers 

fishermen 

Source:  National  monitoring 
system. 

Promote  viability 
of fisheries areas 

Number  of  jobs  created  by  local 
partnerships (result indicator) 

Source:  National  monitoring 
system 

Achieve 
sustainability 

social 

 Improve 
Compliance  

 Improvement  of 
data quality  

 Degree  of  compliance  with  data 
calls from secondary users under 
the  DCF  as  assessed  annually 
by STEFC 

 Improve control  

 Serious infringements divided by 
n° of inspections  

100% 
compliance 

51 

 
  
 
 
 
 
 
 
  
  
 
 
 
 
 
  
 
  
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
LIST OF ANNEXES: 

1.  List of meetings with stakeholders 
2.  List of studies. 
3.  INTERIM EVALUATION OF THE EUROPEAN FISHERIES FUND (2007-2013) 

FINAL REPORT 
FEBRUARY 2011Interim evaluation of the EFF (2007-2013).  

4.  Repartition of the EFF per Axis and MS (2007-2013) 

52 

 
LIST OF ACRONYMS 

Acronym 

Description 

ACFA  
CFP 
CISE 
CMO  
DCF 
EAFRD 
EAGF  
EC 
ECA 
EFF 
EMFF 
EP  
FAS 
FEAP 
FIFG 
FPA 
GVA 
IA  
IMP  
IMS 
ITQ 
IUU 
MA 
MC 
MCS 
MS 
MSFD 
MSP  
MSY 
NSP 
OP 
PO  
POSEI  
RAC 
RFMO 
TAC 
TFC 

TFEU 

Advisory Committee on Fisheries and Aquaculture 
Common Fisheries Policy 
Common Information Sharing Environment 
Common Market Organisation  
Data Collection Framework 
European Agriculture Fund for Rural Development 
European Agriculture Guarantee Fund  
European Commission 
European Court of Auditors 
European Fisheries Fund 
European Maritime and Fisheries Fund 
European Parliament 
Fleet Adaptation Schemes 
Fishing Effort Adjustment Plan 
Financial instruments for fisheries guidance 
Fisheries Partnership Agreements 
Gross Value Added 
Impact Assessment  
Integrated Maritime Policy  
Integrated Maritime Surveillance 
Individual Transferable Quotas  
Illegal, Unreported and Unregulated fishing 
Managing Authority 
Monitoring Committee 
Management and Control System 
Member State 
Marine Strategy Framework Directive 
Maritime Spatial Planning  
Maximum Sustainable Yield 
National Strategic Plan 
Operational Plan 
Producer Organisations 
Programme d'Options Spécifiques à l'Éloignement et l'Insularité 
Regional Advisory Council 
Regional Fisheries Management Organisation  
Total Allowed Catch 
Transferable Fishing Concession 

Treaty of the Functioning of the EU 

53 

 
ANNEX 1 
MEETING WITH STAKEHOLDERS 

COMBINED IMPACT ASSESSMENT AND EX-ANTE EVALUATION REPORT CONCERNING 
THE COMMISSION'S PROPOSAL FOR A FUTURE FINANCIAL INSTRUMENT FOR FISHERIES 
AND MARITIME POLICIES (2014-2020) 

Draft 27 June 2011 

Conferences organised by the Commission 

•  Conference on the future of local development in fisheries dependent areas, April 12-

13, 2011, Brussels. 

•  Conference on the CFP Reform 16 November 2010, Brussels. 
•  Conference MARE/REGIO on innovation in the fisheries and aquaculture sectors, 19 

October 2010, Vigo. 

•  Seminar  with    the  stakeholders,  Member  States  and  other  Institutions  on  EFF  and 

future financial Perspectives, 13 April 2010, Brussels 

•  Meeting with the stakeholders, Member States and other institutions on future EFF, 

Brussels, 19-20th January 2010. 

•  Seminar  with  European  Transport  Federation,  Split,  November  4-5th    2009,  on  the 

future of the EFF. 

•  THE FUTURE OF LOCAL DEVELOPMENT IN FISHERIES AREAS (POST-2013) - “HOW TO 
IMPROVE THE IMPACT OF EU INTERVENTIONS AT LOCAL LEVEL”: BRUSSELS, 12-13 
APRIL 2011  

Co-organised with the Presidencies 

•  Under  Spanish  Presidency:  Conference  on  the  CFP  Reform  2/3  May  La  Coruña, 
Spain  (including  Individual  Transferable  Rights  as  an  alternative  way  of  managing 
capacity, replacing scrapping, and support to small scale fleet) 

•  Under BE Presidency, meeting of Directors- General responsible for Fisheries in the 
MS,  on  EFF  implementation  (including  critical  assessment  of  the  implementation, 
best  practices  in  line  with  Europe  2020,  need  for  synergy  with  other  EU  funds  and 
discussion on the future funding, 12-14 September, Gent. 

•  Under BE Presidency: Improved Fisheries and Science Partnerships as Policy Drivers 

9/10 November Ostend. 

MS Fisheries Administrations 

•  The  issue  of  future  financial  instrument  has  been  discussed  in  all  official  meetings 
organised with the MS in the framework of the partnership (Monitoring Committees, 
Annual Review meetings) and EFF Committee. 

•  The  future  of  Axis  4  (Local  Development)  has  been  discussed  with  the  Managing 
Authorities in charge of Axis 4 in the meetings organised regularly by the FARNET 
Support Unit. 

54 

 
 
 
 
 
Others: 

•  Seminar organized by European Transport Federation "Enhancing social dialogue in 
the fisheries sector of new EU member states", Split, Croatia, 4 - 5 November 2009. 
Informal  exchanges  and  meetings  with  representatives  of  environmental  NGOs 
(PEW, Seas At Risk, Greenpeace, WWF and Birdlife) 

• 

For IMP 

•  A public consultation on the development of an IMP approach for the Mediterranean 
was  conducted  in  2008,  whose  results  were  taken  on  board  in  the  Commission 
Communication "Towards an Integrated Maritime Policy for better governance in the 
Mediterranean"  COM  (2009)466  of  11.09.2009.  This  work  is  followed  by  WG  on 
IMP the Mediterranean. 

•  The EU strategy for the Baltic Sea region is based on consultations (109 replies from 
authorities,  institutions  or  individuals),  as  well  as  an  internet  consultation  hold 
between  November and  December 2008. 

•  A  two-month  public  consultation  on  Marine  Knowledge  in  20091  received  300 

replies. 

•  Five  stakeholder  workshops  (MS,  regions,  NGOs  and  industry)  on  the  further 

development of Maritime Spatial Planning at EU level took place in 2009. 

•  The  Annual  Forum  on  the  EU  Strategy  for  the  Baltic  Sea  Region  was  held  14-15 

October 2010, Tallinn 

•  Towards  an  Integrated  Maritime  Policy  at  the  level  of  the  Mediterranean  Coastal 

Regions, 16/17 December 2010, Rome 

•  The Annual European Maritime Day Stakeholder Conference took place in Brussels, 

19-20 May 2008 in  Rome, 19 & 20 May 2009 and in Gijon, 18-21 May 2010) 

•  DG  MARE  has  established  a  Technical  Advisory  Group  consisting  of  stakeholders 
(representatives of various 'user communities') for the development of an Integrated 
Maritime Surveillance. 

1  

"Marine Data Infrastructure Outcome of Public Consultation", Commission Staff Working Document, 22.1.2010, SEC(2010)73 
final 

55 

 
 
 
 
                                                 
 
ANNEX 2 
LIST OF STUDIES USED IN IA 

COMBINED IMPACT ASSESSMENT AND EX-ANTE EVALUATION REPORT CONCERNING 
THE COMMISSION'S PROPOSAL FOR A FUTURE FINANCIAL INSTRUMENT FOR FISHERIES 
AND MARITIME POLICIES (2014-2020) 

o  Report  from  the  Commission  -  Second  Annual  Report  on  Implementation  of  the 

European Fisheries Fund (2008), 21.12.2009, COM (2009) 696 final  

o  Report from the Commission - Third Annual Report on Implementation of the European 

Fisheries Fund (2009), 07.02.2011, COM (2011) 0037 final  

o  Studies  undertaken  for  the  Impact  Assessment  of  CFP  reform  including  four  regional 

studies.  

o  Regional social and economic impacts of change in fisheries-dependent communities, 
main report and 24 case studies. Study published 15/03/2011  on the Fisheries web 
site: 
http://ec.europa.eu/fisheries/documentation/studies/regional_social_economic_impacts
/index_en.htm 

o 

Interim evaluation of the European Fisheries Fund (2007-2013), Final report,  
Published in February 2011 on the Fisheries web site: 
http://ec.europa.eu/fisheries/documentation/studies/eff_interim_evaluation_en.pdf 

o  Report  from  the  Commission  to  the  Council  and  European  parliament  on  the 
implementation  of  Council  regulation  on  the  Common  Organisation  of  the  Markets  in 
fishery and aquaculture products 

o 

o 

Interim evaluation on establishing EU financial measures for the implementation of the 
CFP and in the area of the Law of the sea 2007-2013 – August 2010 

Impact 
http://ec.europa.eu/fisheries/reform/impact_assessments_en.htm-  

Assessment 

Studies 

related 

the 

to 

CFP 

available 

at 

o  Synthesis  of  the  Consultation  on  the  Reform  of  the  Common  Fisheries  Policy  –  April 

2010 

o  Ex-Post evaluation of FIFG (2000-2006)- March 2010 

o  A  Diagnosis  of  the  EU  fisheries  sector,  Commission  Staff  Working  Document  –  April 

2009  

o 

Impact  Assessment  for  an  Integrated  Maritime  Policy  for  the  European  Union, 
SEC(2007) 1279, 10.10.2007. 

o  Progress  report  on  the  EU's  integrated  maritime  policy,  COM(2009)540  final, 

15.10.2009. 

o  Ex-Ante  Evaluation  for  establishing  a  Programme  to  support  further  development 

towards an Integrated Maritime Policy, SEC(2010) 1097 final of 29.09.2010. 

o 

Impact Assessment for a European Marine Observation and Data Network SEC(2010) 
998 final, 8.9.2010. 

o  Report  on  Integrated  Maritime  Policy  -  Evaluation  of  progress  made  and  new 
challenges  (2010/2040(INI)),  European  Parliament,  Committee  on  Transport  and 
Tourism, 21.10.2010 

o  Evaluation  of  the  Common  Organisation  of  the  Markets  in  Fishery  and  Aquaculture 

Products, December 2008 

o  Monitoring and Evaluation system. By Ernst & Young. Draft June 2011.  

56 

 
ANNEX 3 
INTERIM EVALUATION OF THE EUROPEAN FISHERIES FUND (2007-2013) 
FINAL REPORT 
FEBRUARY 2011 

Not included. Available at: 
http://ec.europa.eu/fisheries/documentation/studies/eff_interim_evaluation_en.pdf 

57 

 
 
 
 
ANNEX 4 

EFF BROKEN-DOWN BY PRIORITY AXIS AND BY MEMBER STATE 

PUBLIC AMOUNTS PROGRAMMED IN THE LAST DECISION INTO FORCE 

For ease of reference, please refer to the legend below: 
Priority axis 1: measures for the adaptation of the Community fishing fleet 
Priority  axis  2:  aquaculture,  inland  fishing,  processing  and  marketing  of  fishery  and 
aquaculture products   
Priority axis 3: measures of common interest 
Priority axis 4: sustainable development of fisheries areas   
Priority axis 5: technical assistance   

58 

 
 
 
 
 
 
 
 
 
 
 
 
ENDNOTES 

1 The expressions "future fund", "Future funding instrument" or "EMFF" are used in the present IA. They have to be 
considered as synonymous. 

2  COM(2010)  494  final  of  29  September  2010,  Proposal  for  a  regulation  of  the  European  Parliament  and  of  the 
Council establishing a Programme to support the further development of an Integrated Maritime Policy. 

3 COUNCIL REGULATION (EC) No 861/2006 of 22 May 2006 establishing Community financial measures for the 
implementation of the common fisheries policy and in the are of the Law of the Sea 

4 COM(2011) 500 final, 29 June 2011. 

5  SEC(2011)  891  -  Impact  assessment  concerning  the  Commission's  proposal  for  the  2012  reform  of  the  Common 
Fisheries Policy and SEC(2011) 892 - Summary of the Impact assessment, both published 13 July 2011. 

6  Impact  assessment  accompanying  the  document  Regulation  of  the  European  Parliament  and  of  the  Council  on  the 
Common Organisation of the Markets in Fishery and Aquaculture Products SEC(2011)883. 

7 SEC (2007) 1279, of 10.10.2007.  

8Commission Progress Report on the EU's Integrated Maritime Policy – COM (2009) 540 final of 15.10.2009.  

9 COM(2011) 500 final of 29 June 2011on A Budget For Europe 2020 - Part II - Policy Fiches , pp. 80-82; SEC(2011) 
868 final chapter 10: Fisheries and Maritime Affairs. 

10 22/9/2010, 13/12/2010, 17/1/2011, 11/2/2011 and 30/6/2011 

11 COM(2009)163 final, Brussels, 22.4.2009. Green Paper Reform of the Common Fisheries Policy 

12  "Marine  Data  Infrastructure  Outcome  of  Public  Consultation",  Commission  Staff  Working  Document,  22.1.2010, 
SEC(2010)73 final. 

13 http://ec.europa.eu/fisheries/reform/sec(2010)0428_en.pdf. 

14 COM(2007) 574 final of 10.10.2007. 

15 Ares(2011)971305 of 13 September 2011. 

16 SEC(2011) 891. 

17 'Safe biological limits' are defined by a minimum safe stock size and a maximum exploitation rate. These are known 
as reference points. The stock size is measured in terms of 'spawning stock biomass (SSB)' which represents the total 
weight of spawning fish each year. The exploitation rate is called the 'fishing mortality (F)' which measures the rate at 
which  fish  are  removed  from  the  stock  by  fishing.  If  the  stock  is  either  below  the  minimum  safe  SSB  or  above  the 
maximum safe F, the stock is said to be outside safe biological limits. 

18 Council Regulation (EC) n° 1198/2006 of 27 July 2006 on the European Fisheries Fund. OJ L223/1 of 15.8.2006. 
Article 4. 

19 SEC(2011) 891. Section 2.4. 

20 Ex-Post evaluation of FIFG (2000-2006)- March 2010. 
21 Interim evaluation of the European Fisheries Fund (2007-2013), Final report, February 2011. 

22  A  list  of  potential  result  and  impact  indicators  was  suggested  in  a  working  paper  “Indicators  for  monitoring  and 
evaluation:  a  practical  guide  for  the  EFF”.  However,  these  indicators  were  not  used  by  all  MS,  whereas  their 
characteristics were not sufficiently detailed to ensure common use and interpretation within the national monitoring 
systems  (some  indicators  being  focused  either on assessing trends or on measuring absolute figures, which makes it 
difficult to aggregate or consolidate the data provided) (see list in annex). 

59 

 
                                                 
 
23  An  ECA  report  on  overcapacity  is  in  preparation,  raising  the  question  of  the  way  this  condition  was  made 
operational in the MS. Its publication is expected for October 2011. 

24 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the common 
organisation of the markets in fishery and aquaculture products. COM(2011)416 final of 13 July 2011. 
25 SEC(2011) 891. Section 2.1.1. 

26 Overcapacity is a biological and economic problem. It means that too many vessels catch existing fishing resources, 
but also that there are too many vessels for the available fishing rights. 

27  The  existence  of  a  possible  scrapping  premium  is  factored  in  the  investment  decisions  made  by  vessels  owners. 
They might decide to build a new vessel even if its cost can not be covered by the income generated only by fishing.  

28 ECA SPECIAL REPORT No 7/2007 on the control, inspection and sanction systems relating to the rules on 
conservation of Community fisheries resources. 

29 See for example: http://www.euraquaculture.info/files/consensus_brochure_web.pdf  mentions the positive impacts 
of pond fish farming. 

30 Dhepherd J.: Linkage between farmed and wild fish. http://www.oecd.org/dataoecd/20/62/45035118.pdf. 

31 Several research projects have been financed under FP5 – FP7 such as RAFOA, PEPPA, AQUAMAX, PUFAFEED. 

32  Birdlife  International,  BirdLife  Europe:    Support  for  environmental  friendly  aquaculture  practices  from  European 
Fisheries Fund (April 2011). 

33  SEC(2011) 891 Section 2.1.5. 

34 COM(2010)241 final of 17 May 2010, In addition, for a further 42 stocks no scientific advice was available. As for 
the Mediterranean, there are some data for 16 species out of 102. These 16 species correspond to 60 stocks. The status 
of 18 out of these 60 was unknown in 2010 due to poor data. 

35  SEC(2010)  998  final  COMMISSION  STAFF  WORKING  DOCUMENT  European  Marine  Observation  and  Data 
Network IMPACT ASSESSMENT. 

36 COM(2010)461. 

37 Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a framework for 
community action in the field of marine environmental policy (Marine Strategy Framework Directive) 

38 For an estimation of the gap, see Section 6 below. 

39 SEC(2011) 891.  

40 See Section 6.2 below for an estimation of the innovation gap. 

41  Investments  not  related  to  innovation  and  environment  (i.e.  port  facilities,  extension  of  production  facilities  in 
aquaculture, processing industry). 

42 The FARNET Support Unit has gathered information on Good Practice projects which are presented on their web 
site, see https://webgate.ec.europa.eu/fpfis/cms/farnet/content/project-examples. 

43 Regarding aquaculture, its fuel consumption is very small. However, as stated above some forms of aquaculture (e.g. 
recirculation systems) are quite electricity consumption intensive. The development of these production methods could 
increase the amount of electricity consume but not to levels considered problematic. 

in  particular  "Regional  social  and  economic 

44  See 
http://ec.europa.eu/fisheries/documentation/studies/regional_social_economic_impacts/index_en.htm. 

impacts  of  change 

in  fisheries-dependent  communities".  Study  published  by  DG  MARE  15/03/2011. 

45 The modelled fleets represent 80% of the global EU gross value added (GVA) of the catching sector and 70+% of 
employment. 

60 

 
                                                                                                                                                 
46  2003  figures  (EU-25),  sum  of  full  time  and  part  time  employment,  not  Full  Time  Equivalent  posts;  (female 
involvement  in  catching  sector:  4%;  aquaculture:  31%;  processing:  >  55%).  source:  Salz,  P.,  Employment  in  the 
fisheries sector, current situation, study commissioned by DG MARE, FISH/2004/4, 2006.  

47 In cases where the actions envisaged fall under more than one Article of the Treaty, it is constant jurisprudence of 
the Court of Justice: (a) to opt for one single Article choosing that which reflects the main or preponderant objective, 
purpose or component of the envisaged measures. See Case C-178/03 (att 42) Commission vs EP and Council; Case C-
36/98 Spain v Council [2001] ECR I-779, paragraph 59; Case C-211/01 Commission v Council [2003] ECR I(cid:31)8913, 
paragraph 39; and Case C-338/01 Commission v Council [2004] ECR I(cid:31)4829,  paragraph 55 or (b) exceptionally to 
accept that two or more Articles are used as legal basis (multiple bases) under the condition that the objectives pursued 
are  intrinsically  linked  without  one  being  secondary  and  indirect  in  relation  to  the  others.  See  C-211/01  (att  40) 
Commission  v  Council  Case  C-336/00  Huber  [2002]  ECR  I-7699,  paragraph  31;    Case  C-281/01  Commission  v 
Council [2002] ECR I-2049, paragraph 35, and Opinion 2/00 [2001] ECR 1-9713, paragraph 23). 

48http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P7-TA-2010-0243. 

49 See Section 9.2 below. 

50 SEC(2011) 891. Sections 5.4 and 7.3. 

51 COM(2011)425 final of 13 July 2011. 

52 See Section 6 below. 

53 Council Conclusions of 16 November 2009, 14 June 2010 and 23 May 2011. 

54  Report  on  Integrated  Maritime  Policy  -  Evaluation  of  progress  made  and  new  challenges  (2010/2040(INI)), 
European Parliament, 21.10.2010 

55 SEC(2011) 891. Sections 5.4 and 7.1. 

56 SEC(2011) 891. Sections 5.4 and 7.2. 

57 
Assessment 
http://ec.europa.eu/fisheries/documentation/studies/discards/index_en.htm. 

discard 

Impact 

See 

of 

reducing 

policies, 

available 

at 

58  The  projects  related  to  Natura2000  are  usually  costly.  For  example,  environmental  studies  necessary  to  select 
optimal location of cages and minimization of impact with Natura2000 sites cost ca €20,000 per year and plant.  

59  Case  study  of  agri-environmental  payments:  the  United  Kingdom.  T.L.  Dobbs,  J.  Pretty,  available  at 
www.sciencedirect.com. 

60 The results regarding Belgium are probably related to the very small active fleet and fishermen.  

61 This calculation can be further improved with the availability, for the first time, of aquaculture data. The first EU-
wide report is scheduled for the publication in the autumn 2011. 

62 Price Waterhouse Cooper, INFOMAR Marine Mapping Survey Options Appraisal Report June 2008. 

63 European Marine Observation and Data Network Impact Assessment, SEC(2010) 998 final of 8.9.2010. 

64  Further  analysis  of  the  corresponding  savings  will  be  provided  within  the  framework  of  the  Impact  Assessment 
exercise  which  is  currently  being  launched.  Nevertheless,  a  considerable  savings  have  been  proved  in  studies  at 
national level, in particular reduced human resources needs. 

65 Study on the economic effects of Maritime Spatial Planning,, Policy Research Corporation on behalf of DG MARE, 
2011.  http://ec.europa.eu/maritimeaffairs/study_msp_en.html. 

66 Calculations in the CFP reform IA regarding processing and ancillary services 15 EU MS. 

61