COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council First report on the implementation of the multiannual plans for the North Sea and Western Waters and the fisheries exploiting those stocks and on the delegation of powers conferred to the Commission by these multiannual plans and by the Deep-Sea Access Regulation
Date: 2024-09-30
Institutions: Directorate-General for Maritime Affairs and Fisheries, European Commission
Subjects: EU waters, North Sea, catch by species, catch quota, conservation of fish stocks, deep-sea fishing, fishing area, fishing regulations, international waters, sea fish

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.9.2024  SWD(2024) 218 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Report from the Commission to the European Parliament and the Council First report on the implementation of the multiannual plans for the North Sea and Western Waters and the fisheries exploiting those stocks and on the delegation of powers conferred to the Commission by these multiannual plans and by the Deep-Sea Access Regulation {COM(2024) 406 final}  
 
 
Executive summary 

This staff working document provides more details about certain chapters of the report (1) on 
the  implementation  of  the  multiannual  plans  for  the  North  Sea (2)  (NS  MAP)  and  for  the 
Western Waters (3) (WW MAP), information about the implementation of the MAPs, and the 
detailed replies given in the stakeholder consultation. 

Contents 

EXECUTIVE SUMMARY ........................................................................................................................... 1 
TAC SETTING .................................................................................................................................. 2 
1. 
MODIFICATIONS OF THE NORTH SEA MAP ......................................................................... 2 
2. 
LANDING OBLIGATION ............................................................................................................... 3 
3. 
EXERCISE OF THE DELEGATION OF POWERS UNDER THE MAPS ............................... 3 
4. 
4.1.  DELEGATED ACTS ADOPTED UNDER THE WESTERN WATERS MAP .......................... 3 
4.2.  DELEGATED ACTS ADOPTED UNDER THE NORTH SEA MAP ......................................... 6 
5. 
ECOSYSTEM-BASED APPROACH .............................................................................................. 8 
SOCIO-ECONOMIC DEVELOPMENT ...................................................................................... 10 
6. 
6.1.  NORTH SEA AND THE EAST ATLANTIC (NSEA) ................................................................. 10 
6.2.  NORTH WESTERN WATERS (NWW): ..................................................................................... 11 
SOUTH WESTERN WATERS (SWW): ....................................................................................... 12 
6.3. 
REGIONAL COOPERATION ...................................................................................................... 12 
7. 
8. 
EXERCISE OF THE DELEGATION OF POWERS UNDER  THE DEEP-SEA ACCESS 
REGULATION ............................................................................................................................... 13 
STAKEHOLDER CONSULTATION ........................................................................................... 14 
9. 
9.1.  MEMBER OF BLE DEUTSCHLAND ......................................................................................... 15 
9.2.  MEMBER OF DTU AQUA EXPERT GROUP FOR FISHERIES AND AQUACULTURE .. 18 
9.3.  MEMBER  OF  IE  NATIONAL  CORRESPONDENTS  AND  OF  THE  REGIONAL 

COORDINATION GROUPS (DATA COLLECTION FRAMEWORK).................................. 23 
9.4.  CONTRIBUTOR OF MINISTRY OF DENMARK .................................................................... 28 
9.5.  MEMBER  OF  LV  NATIONAL  CORRESPONDENTS  AND  OF  THE  REGIONAL 

COORDINATION GROUPS (DATA COLLECTION FRAMEWORK).................................. 33 
9.6.  CNPMEM ........................................................................................................................................ 37 
9.7.  NORTH SEA MEMBER STATES GROUP (SCHEVENINGEN GROUP) ............................. 45 
9.8.  NORTH SEA ADVISORY COUNCIL ......................................................................................... 49 
9.9.  CITIZENS ........................................................................................................................................ 53 

(1) COM(2024)406 

(2) Regulation (EU) 2018/973 of the European Parliament and of the Council of 4 July 2018 establishing a multiannual plan 
for demersal stocks in the North Sea and the fisheries exploiting those stocks, specifying details of the implementation of the 
landing obligation in the North Sea and repealing Council Regulations (EC) No 676/2007 and (EC) No 1342/2008 (OJ L 179, 
16.7.2018, p. 1). 
(3)  Regulation (EU) 2019/472 of the European Parliament and of the Council of 19  March 2019 establishing a multiannual 
plan  for  stocks  fished  in  the  Western  Waters  and  adjacent  waters,  and  for  fisheries  exploiting  those  stocks,  amending 
Regulations (EU) 2016/1139 and (EU) 2018/973, and repealing Council Regulations (EC) No 811/2004, (EC) No 2166/2005, 
(EC) No 388/2006, (EC) No 509/2007 and (EC) No 1300/2008 (OJ L 83, 25.3.2019, p. 1). 

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9.10.  NORTH WESTERN WATERS ADVISORY COUNCIL ........................................................... 59 
9.11.  MEMBER OF STECF .................................................................................................................... 67 
9.12.  MEMBER OF STECF .................................................................................................................... 71 
9.13.  SWWAC ........................................................................................................................................... 74 
9.14.  MEMBER OF THE SWWAC ........................................................................................................ 81 
10.  GLOSSARY ..................................................................................................................................... 85 

1.  TAC setting 

This section adds additional elements to Chapter 3 of the report (COM(2024) 406). 

DEEP-SEA STOCKS 

In  December  2020,  for  the  first  time  since  the  Western  Waters  multiannual  plan  (MAP)(4) 
started to apply, the Council took a decision on a number of total allowable catches (TACs) 
for  deep-sea  stocks.  For  red  seabream  in  Iberian  waters,  which  is  a  target  stock  under  the 
Western Waters MAP, the Commission proposed a 20% reduction for 2021, in line with the 
precautionary advice issued by the Internation Council for the Exploration of the Sea (ICES), 
to  be  rolled  over  in  2022.  The  Council  decided  to  follow  the  Commission’s  proposal.  For 
2023-2024, the Commission proposed a 4% reduction for red seabream in Iberian waters, in 
line  with  ICES  precautionary  advice,  which  the  Council  also  decided  to  follow.  However, 
regarding the Commission’s proposal for a 25% reduction for 2021 for black scabbardfish in 
the Iberian Sea and Azores, in line with ICES precautionary advice, to be rolled over in 2022, 
the Council decided to reduce the TAC by only 20%. The Commission also proposed a 22% 
reduction for red seabream in the Azores for 2023, in line with ICES precautionary advice for 
2023, to be rolled over in 2024. However, the Council decided against this and instead rolled 
over the TAC from 2021 to 2022. 

STOCKS NOT COVERED BY THE MAPS 

Pelagic stocks such as western, northern and southern horse mackerel and anchovy and others 
are not managed under the MAPs. 

2.  Modifications of the North Sea MAP 

Three  aspects  of  the  North  Sea  MAP  were  modified  in  2019.  Firstly,  the  Western  Waters 
MAP modified the provisions of the North Sea MAP to align it in relation to the review of the 
minimum conservation reference size to what was agreed for the Western Waters. Secondly, it 
was specified that the landing obligation does not apply to recreational fishing in the areas it 
covers. Thirdly, it was modified along the same lines as the Western Waters MAP to clarify 

(4)  Regulation (EU) 2019/472 of the European Parliament and of the Council of 19 March 2019 establishing a multiannual 
plan  for  stocks  fished  in  the  Western  Waters  and  adjacent  waters,  and  for  fisheries  exploiting  those  stocks,  amending 
Regulations (EU) 2016/1139 and (EU) 2018/973, and repealing Council Regulations (EC) No 811/2004, (EC) No 2166/2005, 
(EC) No 388/2006, (EC) No 509/2007 and (EC) No 1300/2008 (OJ L 83, 25.3.2019, p. 1). 

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the  scope  of  the  respective  empowerments  and  to  specify  that  delegated  acts  adopted  under 
the empowerments should comply with certain requirements. 

3.  LANDING OBLIGATION 

A  key  objective  of  the  reformed  common  fisheries  policy  (CFP)  (5)  is  to  implement  the 
landing  obligation  and  gradually  eliminate  discards  by  avoiding  and  reducing  unwanted 
catches.  The  landing  obligation  applies  to  species  in  the  North  Sea  and  Western  Waters 
managed by a TAC and has been in force since January 2019. 

On the landing obligation, stakeholders replying to the consultation stated that while there is 
evidence pointing to a decrease in discards, the landing obligation has not met its objective. 
The  main  challenge  is  still  to  make  the  landing  obligation  workable  within  the  legal 
framework,  while  encouraging  a  change  in  fishing  patterns  towards  further  selectivity. 
Despite  this  feedback,  since  the  landing  obligation  was  introduced,  actors  in  the  fisheries 
sector  have  made  a  considerable  effort  to  understand  and  implement  this  policy  and  to 
actively engage with research institutes to develop ways of avoiding and reducing unwanted 
catches, as well as improving general knowledge on these species (including survivability). 

For example, Member States have  made a significant  effort to  provide scientific knowledge 
on  the  survivability  of  fish  caught  in  different  gears.  Member  States  are  also  carrying  out 
multiple research projects to develop gears that are more selective. 

Another challenge identified by stakeholders is the level playing field on the TAC deductions 
when applied to stocks that are shared with non-EU countries. 

On a positive note, stakeholders confirm that the landing obligation has stimulated scientific 
research  on  the  development  of  more  selective  gears  and  fishing  patterns.  However,  for  the 
mixed  demersal  fisheries,  stakeholders  believe  that  there  will  be  a  limit  to  the  degree  of 
selectivity. 

The  Commission  considers  that  the  continuing  problem  of  discards  is  a  control  and 
enforcement issue to be addressed within the EU’s fisheries control system. The MAPs were 
not designed to solve this problem. 

4.  EXERCISE OF THE DELEGATION OF POWERS UNDER THE MAPS 

The below list  gives  an  overview of all delegated acts  that have been  adopted based on the 
relevant legal bases under the Western Waters and North Sea MAPs. 

4.1. Delegated acts adopted under the Western Waters MAP 

1.  South Western Waters 

(5)  Regulation  (EU)  No  1380/2013  of  the  European  Parliament  and  of  the  Council  of  11 December 2013  on  the  common 
fisheries  policy,  amending  Council  Regulations  (EC)  No 1954/2003  and  (EC)  No 1224/2009  and  repealing  Council 
Regulations  (EC)  No 2371/2002  and  (EC)  No 639/2004  and  Council  Decision  2004/585/EC  (OJ  L  354,  28.12.2013, 
p. 22). 

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•  Commission Delegated Regulation (EU) 2019/2237 of 1 October 2019 specifying 
details of the landing obligation for certain demersal fisheries in South Western 
Waters for the period 2020-2021, OJ L 336, 30.12.2019, p. 26–33: 
-  No longer in force; Date of end of validity: 31/12/2020; 
-  Based on Art. 13 of the Western Waters (WW) MAP (a.o.) (6), following a joint 

recommendation submitted by Belgium, Spain, France, the Netherlands, Portugal; 

-  Repealed by Commission Delegated Regulation (EU) 2020/2015 of 21 August 

2020 (No longer in force). 

2.  North Western Waters 

•  Commission Delegated Regulation (EU) 2019/2239 of 1 October 2019 specifying 
details of the landing obligation for certain demersal fisheries in North Western 
Waters for the period 2020-2021, OJ L 336, 30.12.2019, p. 47–58: 
-  No longer in force; Date of end of validity: 31/12/2020; 
-  Based on Art. 13 of the WW MAP (a.o.) (7), following a joint recommendation 

submitted by Belgium, Spain, France, Ireland, the Netherlands, United Kingdom; 

-  Repealed by Commission Delegated Regulation (EU) 2020/2015 of 21 August 

2020 (No longer in force). 

•  Commission Delegated Regulation (EU) 2023/828 of 2 February 2023 correcting 
Delegated Regulation (EU) 2020/2015 as regards the survivability exemption for 
common sole catches by vessels under 12 metres long and using otter bottom trawls, 
in the Western Waters, ICES division 7e, for 2023, OJ L 104, 19.4.2023, p. 23–24: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 13 of the WW MAP, following a request from France regarding an 

error introduced in Delegated Regulation (EU) 2020/2015 by Delegated 
Regulation (EU) 2022/2290, which amended Delegated Regulation 
(EU) 2020/2015; 

-  Matter: correcting Article 4(1) of Delegated Regulation (EU) 2020/2015 by 

including otter trawl gears with a cod end mesh size of 80 to 99 mm (instead of 
only those larger than 80 mm) because of a new survivability exemption for 
common sole (Solea solea) below the minimum conservation reference size 

(6)  Articles  15(6)  and  18(1)  and  (3) of  Regulation  (EU)  No 1380/2013  of  the  European  Parliament  and  of  the 
Council  of  11 December  2013  on  the  common  fisheries  policy,  amending  Council  Regulations  (EC) 
No 1954/2003  and  (EC)  No 1224/2009  and  repealing  Council  Regulations  (EC)  No 2371/2002  and  (EC) 
No 639/2004 and Council Decision 2004/585/EC (1), OJ L 354, 28.12.2013, p. 22–61. 

(7) Article 15(2) of Regulation (EU) 2019/1241 of the European Parliament and of  the Council of 20 June 2019 
on  the  conservation  of  fisheries  resources  and  the  protection  of  marine  ecosystems  through  technical 
measures,  amending  Council  Regulations  (EC)  No 1967/2006,  (EC)  No 1224/2009  and  Regulations  (EU) 
No 1380/2013,  (EU)  2016/1139,  (EU)  2018/973,  (EU)  2019/472  and  (EU)  2019/1022  of  the  European 
Parliament and of the Council, and repealing Council Regulations (EC) No 894/97, (EC) No 850/98, (EC) 
No 2549/2000,  (EC)  No 254/2002,  (EC)  No 812/2004  and  (EC)  No 2187/2005,  OJ  L  198,  25.7.2019,  p. 
105–201. 

4 

 
 
(MCRS) caught in ICES division 7e by vessels under 12 m long and using otter 
bottom trawls (OTB), with a cod end mesh size larger than 80 mm. 

3.  North & South Western Waters 

•  Commission Delegated Regulation (EU) 2020/2015 of 21 August 2020 specifying 

details of the implementation of the landing obligation for certain fisheries in Western 
Waters for the period 2021-2023, OJ L 415, 10.12.2020, p. 22–38: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 13 of the WW MAP, following two joint recommendations 

submitted by (i) Belgium, Spain, France, Ireland, the Netherlands (‘North Western 
Waters Member States’), (ii) Belgium, Spain, France, the Netherlands, Portugal 
(‘South Western Waters Member States’). 

•  Commission Delegated Regulation (EU) 2021/2063 of 25 August 2021 amending and 

correcting Delegated Regulation (EU) 2020/2015 specifying details of the 
implementation of the landing obligation for certain fisheries in Western Waters for 
the period 2021-2023, OJ L 421, 26.11.2021, p. 6–8: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 13 of the WW MAP, following two joint recommendations 

submitted by (i) North Western Waters Member States, (ii) South Western Waters 
Member States. 

•  Commission Delegated Regulation (EU) 2022/2290 of 19 August 2022 amending 
Delegated Regulation (EU) 2020/2015 as regards certain exemptions to the landing 
obligation in the Western Waters for 2023, OJ L 303, 23.11.2022, p. 12–18: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 13 of the WW MAP, following two joint recommendations 

submitted by (i) North Western Waters Member States, (ii) South Western Waters 
Member States. 

•  Commission Delegated Regulation (EU) 2023/1480 of 11 May 2023 correcting the 

Dutch language version of Delegated Regulation (EU) 2020/2015 specifying details of 
the implementation of the landing obligation for certain fisheries in the Western 
Waters for the period 2021-2023, OJ L 182, 19.7.2023, p. 90–90: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 13 of the WW MAP; 
-  Matter: correcting an error of the Dutch language version in Article 13(1), point 

(a) of Delegated Regulation (EU) 2020/2015. 

•  Commission Delegated Regulation (EU) 2023/2623 of 22 August 2023 

supplementing Regulation (EU) 2019/472 of the European Parliament and of the 
Council by specifying details of the landing obligation for certain fisheries in Western 
Waters for the period 2024-2027, OJ L 2023/2623, 22.11.2023: 
- 

In force; Date of effect: 01/01/2024; Date of end of validity: 31/12/2027; 

5 

 
-  Based on Art. 13 of the WW MAP, following two joint recommendations 

submitted by (i) North Western Waters Member States, (ii) South Western Waters 
Member States. 

4.2. Delegated Acts adopted under the North Sea MAP 

•  Commission Delegated Regulation (EU) 2018/2035 of 18 October 2018 specifying 

details of implementation of the landing obligation for certain demersal fisheries in the 
North Sea for the period 2019-2021, OJ L 327, 21.12.2018, p. 17–26: 
-  No longer in force; Date of end of validity: 31/12/2019; 
-  Based on Article (Art.) 11 of the North Sea (NS) MAP, following a joint 
recommendation submitted by Belgium, Denmark, France, Germany, the 
Netherlands, Sweden, (‘Scheveningen Group’) and United Kingdom; 

-  Repealed by Commission Delegated Regulation (EU) 2019/2238 of 1 October 

2019 (No longer in force). 

•  Commission Delegated Regulation (EU) 2019/906 of 13 March 2019 amending 

Delegated Regulation (EU) 2018/2035 specifying details of implementation of the 
landing obligation for certain demersal fisheries in the North Sea for the period 2019-
2021, OJ L 145, 4.6.2019, p. 4–6: 
-  No longer in force; Date of end of validity: 31/12/2019; 
-  Based on Art. 11 of the NS MAP, following two joint recommendations submitted 

- 

by the Scheveningen Group and United Kingdom; 
Implicitly repealed by Commission Delegated Regulation (EU) 2019/2238 of 
1 October 2019 (No longer in force). 

•  Commission Delegated Regulation (EU) 2019/2238 of 1 October 2019 specifying 

details of implementation of the landing obligation for certain demersal fisheries in the 
North Sea for the period 2020-2021, OJ L 336, 30.12.2019, p. 34–46: 
-  No longer in force; Date of end of validity: 31/12/2020; 
-  Based on Art. 11 of the NS MAP (a.o.) (8), following a joint recommendation 

submitted by the Scheveningen Group and United Kingdom; 

-  Repealed by Commission Delegated Regulation (EU) 2020/2014 of 21 August 

2020 (no longer in force). 

(8)Article 15(2) of Regulation (EU) 2019/1241 of the European Parliament and of the Council of 20 June 2019 
on  the  conservation  of  fisheries  resources  and  the  protection  of  marine  ecosystems  through  technical 
measures,  amending  Council  Regulations  (EC)  No 1967/2006,  (EC)  No 1224/2009  and  Regulations  (EU) 
No 1380/2013,  (EU)  2016/1139,  (EU)  2018/973,  (EU)  2019/472  and  (EU)  2019/1022  of  the  European 
Parliament and of the Council, and repealing Council Regulations (EC) No 894/97, (EC) No 850/98, (EC) 
No 2549/2000,  (EC)  No 254/2002,  (EC)  No 812/2004  and  (EC)  No 2187/2005,  OJ  L  198,  25.7.2019,  p. 
105–201. 

6 

 
 
 
•  Commission Delegated Regulation (EU) 2020/1758 of 28 August 2020 amending 
Delegated Regulation (EU) 2019/2238 as regards high survivability and de minimis 
exemptions applicable to certain demersal fisheries in the North Sea, OJ L 397, 
26.11.2020, p. 1–3: 
-  No longer in force; Date of end of validity: 31/12/2020; 
-  Based on Art. 11 of the NS MAP, following a joint recommendation submitted by 

the Scheveningen Group and United Kingdom; 

-  Matter: correcting some errors and unintentional omissions in Delegated 

- 

Regulation (EU) 2019/2238; 
Implicitly repealed by Commission Delegated Regulation (EU) 2020/2014 of 
21 August 2020 (No longer in force). 

•  Commission Delegated Regulation (EU) 2020/2014 of 21 August 2020 specifying 
details of implementation of the landing obligation for certain fisheries in the North 
Sea for the period 2021-2023, OJ L 415, 10.12.2020, p. 10–21: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 11 of the NS MAP, following a joint recommendation submitted by 

the Scheveningen Group. 

•  Commission Delegated Regulation (EU) 2021/2062 of 23 August 2021 amending 
Delegated Regulation (EU) 2020/2014 specifying details of implementation of the 
landing obligation for certain fisheries in the North Sea for the period 2021-2023, OJ 
L 421, 26.11.2021, p. 4–5: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 11 of the NS MAP, following a joint recommendation submitted by 

the Scheveningen Group; 

-  Matter: continuation of certain exemptions to the landing obligation beyond 2021. 

•  Commission Delegated Regulation (EU) 2022/2289 of 18 August 2022 amending 

Delegated Regulation (EU) 2020/2014 as regards exemptions to the landing obligation 
for certain fisheries in the North Sea for 2023, OJ L 303, 23.11.2022, p. 6–11: 
-  No longer in force; Date of end of validity: 31/12/2023; 
-  Based on Art. 11 of the NS MAP, following a joint recommendation submitted by 

the Scheveningen Group. 

•  Commission Delegated Regulation (EU) 2023/2459 of 22 August 2023 

supplementing Regulation (EU) 2018/973 of the European Parliament and of the 
Council by specifying details of the landing obligation for certain fisheries in the 
North Sea for the period 2024-2027, OJ L, 2023/2459, 06.11.2023: 
- 
-  Based on Art. 11 of the NS MAP, following a joint recommendation submitted by 

In force; Date of effect: 01/01/2024; Date of end of validity: 31/12/2027; 

the Scheveningen Group. 

7 

 
 
 
5.  ECOSYSTEM-BASED APPROACH 

Article 2(3) of the Basic Regulation states that the CFP must implement an ecosystem-based 
approach  to  fisheries  management  to  reduce  negative  impacts  of  fishing  activities  on  the 
marine ecosystem. Article 3(3) of the MAPs provide that the MAPs have to be coherent with 
EU environmental law and in particular with the objective of achieving good environmental 
status  by  2020  as  required  by  the  Marine  Strategy  Framework  Directive  (MSFD) (9).  The 
MSFD  provides  11  qualitative  descriptors  for  determining  good  environmental  status.  The 
MAP aims to ensure that the conditions of descriptor 3 (as the one most relevant for fisheries 
management) are met and to contribute to meeting the other relevant descriptors in proportion 
to the relative role played by fisheries. 

Descriptor 3 is directly linked to the fixing of fishing opportunities. It reads ‘the populations 
of all commercially exploited fish and shellfish are within safe biological limits, exhibiting a 
population  age  and  size  distribution  that  is  indicative  of  a  healthy  stock’.  Fishing  activities 
have an impact on the descriptors relating to biological diversity (1), the food web (4), sea-
floor integrity (6) and marine litter (10). The contribution of fishing to the other descriptors is 
at best indirect and/or not substantial (10). 

ICES indicates that fishing mortality has in general decreased steadily since the 1990s and is 
now on average below FMSY. 

Regarding  the  Bay  of  Biscay  and  Iberian  waters  ecoregion,  ICES  indicates  that  natural 
mortality  is  becoming  proportionately  more  significant,  because  fishing  mortality  has  been 
reduced on many stocks. Predation mortality can occur from other fish, seabirds and marine 
mammals. ICES also notes (11) that ‘climate change effects are evident within the ecoregion, 
notably in the Gulf of Cadiz, where warming has been  observed over the last two decades’, 
and that this is leading to distribution changes in the fish population and migration patterns. 
ICES further notes that ‘climate-induced changes in temperature and salinity have affected the 
biological  communities of the Gironde estuary and modified its nursery function for marine 
juvenile fish’ (12). 

Moreover,  ICES  notes  that:  ‘Fish  diversity  is  high  in  this  ecoregion,  reflecting  its  wide 
latitudinal  dimension.  […]  Hake  is  the  most  abundant  predator  species  in  the  demersal 
community.  Anglerfish,  megrim,  and  sole  are  more  abundant  in  the  northern  part  of  the 
ecoregion. The limit of distribution for some cold-water species such as whiting and pollack is 

(9) Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a framework for the 

community action in the field of marine environmental policy (OJ 164, 25.6.2008, p. 19). 

(10)  Introduction  of  non-indigenous  species  (2),  human-induced  eutrophication  (5),  hydrographical  conditions  (7),  level  of 
contaminants in the sea (8), level of contaminants in fish and seafood (9), introduction of energy including underwater 
noise (11). 

(11)    ICES.  2022.  Bay  of  Biscay  and  the  Iberian  Coast  ecoregion  –  Ecosystem  overview.  In  Report  of  the  ICES  Advisory 

Committee, 2022. ICES Advice 2022, Section 6.1, https://doi.org/10.17895/ices.advice.21731579. 

(12)  ICES  2020.  Bay  of  Biscay  and  the  Iberian  Coast  Ecoregion  –  Ecosystem  overview.  ICES  Advice:  Ecosystem 

Overviews. Report. https://doi.org/10.17895/ices.advice.7636. 

8 

 
 
 
in the north of Portugal. Skates, sharks, and deep-sea fish occur over the continental slope and 
in  the  deeper  parts  of  this  ecoregion.  For  evaluated  stocks,  the  spawning-stock  biomass  is 
above  reference  points.  The  historical  evolution  of  spawning-stock  biomass  relative  to 
reference points by fish guild in the Bay of Biscay and the Iberian Coast ecoregion shows an 
increase in the biomass that has been observed since 2002.’ 

Fisheries risk catching protected species, such as seabirds and marine mammals (13). The 2013 
CFP  reform  provided  new  ways  for  stakeholders  and  Member  States  in  specific  regions  to 
work  together  to  agree  on  bespoke  measures  for  their  sea  basins.  As  part  of  the  ecosystem 
approach, stakeholders and Member States in the South Western Waters are currently holding 
discussions in order to agree measures to reduce incidental catches of dolphins in the Bay of 
Biscay. 

Regarding  the  greater  North  Sea  region,  ICES  states  that  climate  change  is  causing  the 
warming  of  surface  water  temperature.  This  has  already  resulted  in  the  redistribution  of 
several  plankton  and  fish  species  within  the  ecoregion,  which  is  likely  to  continue.  Further 
cascading  effects  are  likely  to  occur  throughout  the  ecosystem  with  consequences  on  the 
spatial distribution of fisheries. Marine spatial planning actors should therefore consider this 
when planning infrastructure such as wind farms or putting in place marine protected areas. 

In  the  Greater  North  Sea  ecoregion,  according  to  ICES,  by-catch  in  fisheries  is  the  human 
activity with the greatest effect on the population level of marine mammals. ICES notes that 
‘the highest multiannual by-catch rates during 2017-2021 were recorded for common dolphin 
in purse seines and harbour porpoise in set gillnets’ (14). 

In the Greater North Sea ecoregion, the stock sizes of most groups of commercial species are 
now above levels that can provide the maximum sustainable yield (MSY) overall. However, 
some individual species are still below MSY levels. 

Regarding the Celtic Sea ecoregion (15), ICES states that ‘Climate change is causing changes 
in water masses. Freshening of western subpolar north Atlantic waters is observed in deeper 
areas of the ecoregion. In addition, the warming of surface water temperature in shallow shelf 
regions has become increasingly seasonally stratified and nutrient-limited in some areas. This 
has  already  changed  the  spatial  distribution  of  several  plankton  and  fish  species  within  the 
ecoregion  and is likely to continue to do so.’ ICES also notes that ‘Climate change induced 
cascading  effects  are  likely  to  occur  throughout  the  ecosystem  with  consequences  for  the 
spatial distribution of fisheries.’ 

The North Western Waters Member States Group considers that the North Sea MAP has not 
achieved the ecosystem-based approach, and some members of the Scientific, Technical and 

(13)   ICES.  2022.  Bay of  Biscay  and  the  Iberian  Coast  ecoregion  –  Ecosystem  overview.  In  Report  of  the  ICES  Advisory 

Committee, 2022. ICES Advice 2022, Section 6.1, https://doi.org/10.17895/ices.advice.21731579. 

(14)   ICES.  2022.  Greater  North  Sea  ecoregion  –  Ecosystem  overview.  In  Report of  the  ICES  Advisory  Committee,  2022. 

ICES Advice 2022, Section 7.1, https://doi.org/10.17895/ices.advice.21731912. 

(15)    ICES.  2022.  Celtic  Seas  Ecoregion  –  Ecosystem  overview.  In  Report  of  the  ICES  Advisory  Committee,  2022.  ICES 

Advice 2022, Section 7.1, https://doi.org/10.17895/ices.advice.21731615. 

9 

 
 
Economic Committee for Fisheries (STECF) and stakeholders mention that neither of the two 
MAPs  has  contributed  to  achieving  the  ecosystem-based  approach.  The  North  Western 
Waters  advisory  councils  asked  for  other  pressures  on  the  marine  environment,  such  as 
climate change and pollution, to be taken into account. 

A  commonly  held  view  by  stakeholders  responding  to  the  public  consultation  is  that  the 
ecosystem-based approach  has  not  been achieved and the MAP  has  played a neutral  role in 
this regard. Concerning the high levels of by-catches of common dolphins in the North-East 
Atlantic,  stakeholders  consider  that  the  MAP  has  not  yet  contributed  to  protecting  sensitive 
species  and  the  marine  environment  as  required  by  Article 7  of  the  Basic  Regulation. 
Consultation respondents also think it is necessary to implement regionalisation better and to 
use the available scientific advice, in particular when defining spatio-temporal closures. 

Industry criticises the MAP as being too rigid on the list of target stocks and having no clear 
criteria  on  what  makes  a  target  stock.  The  Commission  acknowledges  this  limitation  of  the 
MAP, which was the result of interinstitutional negotiations. 

The consulted stakeholders underline the importance of an ecosystem-based management of 
fisheries  and  the  contribution  of  fisheries  to  achieving  good  environmental  status,  while 
pointing  out  that  non-fisheries  related  factors  also  play  an  important  role.  Member  States 
consider  that  the  situation  of  the  fish  stocks  would  probably  have  been  worse  without  the 
MAP, while the Advisory Council is of the view that the MAP has been counterproductive as 
it lacks specific provisions on how to implement an ecosystem-based management of fisheries 
in practice. 

6.  SOCIO-ECONOMIC DEVELOPMENT 

6.1. North Sea and the East Atlantic (NSEA) 

According to the STECF’s latest annual economic report (16), two main players dominate the 
seascape  of  this  region.  In  2021,  the  Danish  fleet  was  the  most  important  in  terms  of  both 
landed weight (about 370 000 tonnes) and landed value (EUR 309 million). Furthermore, the 
Dutch fleet is also an important contributor (186 000 tonnes and EUR 281 million). The share 
of the French, German, Swedish and Belgian fleets is considerably lower, but except for the 
French fleet, the region itself is of major importance for these national fleets.’ 

The  STECF  also  notes  that  ‘Even  though  the  share  of  the  number  of  small-scale  vessels  is 
more  than  50%  and  the  effort  is  about  a  quarter  of  the  total  days-at-sea  in  the  NSEA,  their 
economic contribution as well as their share of the landed weight is marginal. The large-scale 
fleet landed 99% of the total weight and 97% of the total value in 2021.’ 

(16) Scientific, Technical and Economic Committee for Fisheries (STECF) - The 2023 Annual Economic Report 
on the EU Fishing Fleet (STECF 23-07), Prellezo, R., Sabatella, E., Virtanen, J., Tardy Martorell, M. and 
Guillen,  J.  editor(s),  Publications  Office  of  the  European Union,  Luxembourg,  2023,  doi:10.2760/423534, 
JRC135182. 

10 

 
 
 
In  addition,  it  notes  that  ‘The  revenue  generated  by  the  EU-27  NSEA  fleet  in  2021  was 
estimated at EUR 959 million, 35% of which was provided by Denmark (EUR 333 million), 
30%  by  the  Netherlands  (EUR 288  million),  and  11%  by  Germany  (EUR 104  million). 
Although  total  revenue  remained  about  stable  between  2020  and  2021  some  differences 
between  countries  can  be  noticed  when  comparing  2020  to  2021.  Countries  that  had  a 
noticeable  decrease  in  revenue  were  Denmark  (EUR 50  million;  -13%),  Lithuania  (EUR 9 
million; -32%) and Spain (EUR 6 million; -24%), while countries with a noticeable increase 
in revenue were Ireland (EUR 18.6 million; +790%), Germany (EUR 16 million; +18%) and 
the Netherlands (EUR 9 million; +3%). The improved economic performance of the German 
fleet  may  be  a  reflection  of  the  complete  dataset  of  pelagic  trawlers  and  thus  inclusion  of 
these data in the analyses. The economic performance of the German fleet in comparison with 
previous  years  should  therefore  be  placed  in  correct  context.  The  gross  value  added  (GVA) 
produced by the EU-27 NSEA fleet covered in the analysis was estimated at about EUR 487 
million in 2021. This represented an overall increase of 8% compared to the GVA generated 
in 2020.’ 

6.2. North Western Waters (NWW): 

Again, according to the  STECF’s latest annual economic report ‘The revenue (income from 
landings  and  other  income)  generated  by  the  EU-27  NWW  fleet  covered  in  the  analysis  in 
2021  was  estimated  at  EUR 1.07  billion,  representing  17%  of  the  total  revenue  for  the  EU 
fleet.  This  represents  an  increase  in  revenue  of  7%  from  2020.  GVA  was  estimated  at 
EUR 569  million,  representing  an  increase  of  1%  compared  to  the  previous  year.  The  fleet 
made EUR 186 million in gross profit, an increase of 14% compared to 2020. The net profit at 
EUR 85 million also increased by 6% compared to 2020. In 2021, the price of fuel was 0.52 
euro/litre  (29.5%  higher  than  in  2020)  and  fuel  consumption  increased  by  14%  from  2020 
following  the  increase  in  effort.  Fuel  is  an  important  operational  cost  and  therefore  an 
important  driver  for  profits  which  will  no  doubt  begin  to  show  negative  impacts  with  the 
increase  in  fuel  prices  experienced  from  2022  as  a  result  of  the  war  in  Ukraine  and  rising 
inflation levels.’ 

Furthermore,  when  looking  at  a  more  detailed  picture  of  the  sea  basins,  for  example  in  the 
Bay  of  Biscay,  the  Commission  identified  on  the  basis  of  an  STECF  report (17)  that  the 
decrease  in  fishing  opportunities  for  2024  had  an  impact  on  the  earnings  of  specific  fleets 
(netters, hooks and lines). 

The  North  Western  Waters  Member  States  group  confirms  the  medium  to  long-term 
beneficial socio-economic impact of the Western Waters MAP. 

(17) Scientific, Technical and Economic Committee for Fisheries  – 75th Plenary Report (STECF-PLEN-24-01), 
RIHAN, D. and DOERNER, H. editor(s), Publications Office of the European Union, Luxembourg, 2024, 
doi:10.2760/82418, JRC137730. 

11 

 
 
 
 
 
6.3. South Western Waters (SWW): 

According to STECF’s latest annual economic report ‘The small-scale coastal fleet dominates 
in number of vessels (63%) and effort (54%) while the large-scale fleet is the main segment in 
terms of production (88% in weight and 75% in value).’ 

The report also notes that ‘In 2021, the fleet operating in the SWW generated over EUR 1.3 
billion in revenue, EUR 758 million in GVA and EUR 168 million in gross profits. Overall, 
revenue and profits have recovered since 2013, going from a loss-making position to posting 
net profits, although they have deteriorated from 2015 to 2020. However, in 2021 there was a 
recovery  with  an  increase  of  12%  in  revenue.  This  fleet  as  a  whole  was  profitable  in  2021, 
posting a net profit of over EUR 84 million (7% profit margin).’ 

7.  REGIONAL COOPERATION 

Regional  cooperation  is  central  to  the  CFP.  Its  main  goal  is  to  take  better  account  of  the 
differences  between  the  various  sea  basins  and  to  integrate  stakeholders  more  into  fisheries 
management, including by making use of their knowledge and experience. Ultimately, having 
stakeholders  directly  involved  in  the  formulation  and  implementation  of  management 
measures will lead to a greater sense of shared ownership as well as a commitment to comply 
with  the  measures.  Through  regional  cooperation,  stakeholders  with  a  direct  management 
interest  can  support  the  adoption  of  conservation  measures,  such  as  multiannual  plans  and 
discard plans. This cooperation is achieved mostly by means of advisory councils and Member 
States’ groups. 

The  advisory  councils (ACs)  (18) (19),  are  stakeholder-led  organisations  with  a  common 
interest  in  fisheries  and  aquaculture  activities  in  a  given  region.  They  are  composed  of 
Member  State  representatives,  fishing  sector  stakeholders  and  other  groups  such  as 
environmental  organisations,  recreational  fishermen  and  consumers.  Scientists  from  national 
institutes,  the  STECF  and  ICES  are  also  involved  and  are  regularly  invited  to  present  their 
research  work.  The  ACs  that  fall  under  the  scope  of  this  report  are  the  North  Sea  Advisory 
Council  (NSAC,  established  in  2004) (20),  the  North  Western  Waters  Advisory  Council 
(NWWAC, established in 2005) (21) and the South West Waters Advisory Council (SWWAC, 
established  in  2007) (22).  These  ACs  issue  recommendations  to  the  Commission  and  to  the 
Member State concerned on matters relating to the management and socio-economic aspects 

(18) Article 43-45 of the Basic Regulation. 

(19)  Commission  Delegated  Regulation  (EU)  2017/1575  of  23  June  2017  amending  Delegated  Regulation  (EU)  2015/242 

laying down detailed rules on the functioning of the Advisory Councils under the CFP (OJ L 239, 19.9.2017). 

(20) Commission Decision of 9 November 2004 declaring operational the Regional Advisory Council for the North Sea under 

the CFP (OJ L 342, 18.11.2004). 

(21) Commission Decision of 22 September 2005 declaring operational the Regional Advisory Council for the North Western 
Waters under the common fisheries policy (OJ L 249, 24.9.2005). 
(22)  Commission  Decision  of  4  April  2007  declaring  operational  the  Regional  Advisory  Council  for  the  South  Western 

Waters under the common fisheries policy (OJ L 95, 5.4.2007). 

12 

 
 
 
 
of  fisheries.  Together  the  three  ACs  have  published  more  than  120  recommendations (23) 
between  2019  and  2023,  covering  a  variety  of  CFP  topics  such  as  fishing  opportunities,  the 
landing obligation, the marine action plan, the management of skate and rays, seabass, brown 
crab and Iberian sardines. 

According  to  the  Basic  Regulation,  Member  States  with  a  direct  management  interest  may 
submit  joint  recommendations  on  matters  related  to  conservation  measures,  technical 
measures and discard plans. For this purpose, Member States gather in the form of high-level 
groups or Member States’ groups (MSG). This report covers three MSG: (i) the North Sea 
MSG, also known as the ‘Scheveningen Group’; (ii) the North Western Waters MSG; and (iii) 
the  South  Western  Waters  MSG (24).  Their  main  objective  is  to  improve  coordination  and 
cooperation  between  their  members  and  with  other  stakeholders  in  the  region,  such  as  the 
ACs. They exchange information, develop policy positions and design regional conservation 
measures  through joint  recommendations. Since the adoption of the  North Sea  and  Western 
Waters MAPs, the three MSGs have submitted joint recommendations aimed at implementing 
the  landing  obligation  for  the  stocks  under  the  MAPs.  These  joint  recommendations  have 
been set out in the Commission delegated regulations referred to above in Chapter 4. 

The  stakeholder  consultation  gathered  useful  comments  on  how  the  regional  cooperation 
under  the  North  Sea  and  Western  Waters  MAPs  is  working  in  practice.  For  example, 
stakeholders  consider  that  the  MAPs  provide  the  necessary  legal  framework  to  implement 
regional cooperation, and the NWWAC and Members of the STECF think that cooperation is 
increasing between the relevant stakeholders (25). The joint recommendations have gradually 
provided  more  technical  evidence  and  practical  knowledge,  as  well  as  bespoke  sea  basin 
measures.  However, the  MSGs  would benefit from  greater involvement of stakeholders  and 
scientists. In this respect, the Fisheries and Oceans Pact (26) calls on Member States to make 
progress on CFP governance for the benefit of all stakeholders concerned and  for society in 
general. 

8.  EXERCISE OF THE DELEGATION OF POWERS UNDER THE DEEP-SEA ACCESS 

REGULATION 

The  Deep-Sea  Access  Regulation (27),  as  well  as  contributing  to  achieving  the  objectives 
listed in Article 2 of the Basic Regulation on deep-sea species and habitats, aims to: 

(23) The recommendations are publicly available online on the websites of NSAC, NWWAC and SSWAC. 

(24)  The  Member  States’  groups  were  established  in  2014  and  are  composed  as  follows:  the  North  Sea  MSG  includes 
Belgium, Denmark, France, Germany, the Netherlands and Sweden; the North Western Waters MSG includes Belgium, 
France  Ireland,  the  Netherlands  and  Spain;  the  South  Western  Waters  MSG  includes  Belgium,  France,  Portugal,  the 
Netherland and Spain. 

(25) Two Members of the STECF replied to the stakeholder consultation. Their responses are available in Section 9. 

(26)  The  common  fisheries  policy  today  and  tomorrow:  a  Fisheries  and  Oceans  Pact  towards  sustainable,  science-based, 

innovative and inclusive fisheries management, COM(2023) 103 final. 

(27) Regulation (EU) 2016/2336 establishing specific conditions for fishing for deep-sea stocks in the north-east 
Atlantic and provisions for fishing in international waters of the north-east Atlantic (OJ L 354, 23.12.2016, 
p. 1.). 

13 

 
 
 
(1)  improve scientific knowledge on deep-sea species and their habitats; 
(2)   prevent  significant  adverse  impacts  on  vulnerable  marine  ecosystems  within  the 
framework of deep-sea fishing and ensure the long-term conservation of deep-sea fish 
stocks; 

(3)  ensure that EU measures for the sustainable management of deep-sea fish stocks are 
consistent  with  the  resolutions  adopted  by  the  General  Assembly  of  the  United 
Nations, in particular Resolutions 61/105 and 64/72. 

To  achieve  the  objectives  of  the  Deep-Sea  Access  Regulation,  Article 9(7)  empowers  the 
Commission  to  amend  Annex  III  to  ensure  that  the  list  of  vulnerable  marine  ecosystems 
(VME) indicator species is  updated in  line with  the latest  scientific advice. This  power was 
conferred  for 5 years as  from 12 January 2017. The Commission  had to prepare a report on 
the  delegation  of  powers  no  later  than  9  months before  the  end  of  the  5-year  period.  In  the 
absence of any opposition by the co-legislators, the delegation of powers was tacitly extended 
for another 5 years, so until 12 January 2027. 

The  Commission  considers  that  so  far  it  has  not  been  necessary  to  adapt  Annex  III.  The 
Commission has therefore not adopted a delegated regulation. 

9.  STAKEHOLDER CONSULTATION 

For this first report on the implementation of the North Sea and Western Waters MAPs, the 
Commission carried out a targeted stakeholder consultation. The consultation was based on a 
questionnaire. Consulted stakeholders included the North Sea MSG, the North Western MSG, 
the South Western MSG, the NSAC, the NWWAC, the SWWAC, the Pelagic AC, the Long 
Distance AC, ICES (who replied that they could not participate in such a survey), STECF, the 
national  correspondents  and  the  chairs  of  the  regional  coordination  groups  (Data  Collection 
Framework),  the  Commission  Expert  Group  for  Fisheries  and  Aquaculture,  the  Fisheries 
attachés, the MSFD experts and the Marine Expert Group. 

This staff working document provides the content of the replies received by the Commission. 

14 

 
 
 
 
 
 
9.1. Member of BLE Deutschland 

Member of the North Sea Member States Group (Scheveningen Group), North Western 
Member States Group, Expert Group for Fisheries and Aquaculture 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. beneficial 

2. very beneficial 

3. beneficial 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. negative 

2. beneficial 

3. neutral 

4. negative in the short term 

15 

 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. negative 

2. neutral 

3. no opinion 

4. negative 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

neutral 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Moratoria, Area closures. 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 
16 

 
 
 
 
 
2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. beneficial 

2. very beneficial 

3. beneficial 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. negative 

2. beneficial 

3. neutral 

4. negative in the short term 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

17 

 
 
 
 
 
2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. negative 

2. neutral 

3. no opinion 

4. negative 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

neutral 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion 

9.2. Member of DTU Aqua expert group for Fisheries and Aquaculture 

Member of an Expert Group for Fisheries and Aquaculture 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

18 

 
 
 
 
 
2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

very beneficial 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

very negative 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

19 

 
 
 
 
 
4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

beneficial 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion 

20 

 
 
 
 
 
 
 
Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

21 

 
 
 
 
 
 
2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative 

22 

 
 
 
 
 
 
 
 
9.3. Member of IE National correspondents and of the Regional Coordination Groups 

(Data Collection Framework)  

Member of a National correspondents and of the Regional Coordination Group (Data 
Collection Framework) 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

23 

 
 
 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

24 

 
 
 
 
 
 
 
3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

beneficial - There has been a gradual improvement in the status of stocks in relation for 

1. 
MSY targets in  the  Celtic  Sea  ecoregion  since  the  introduction  of  the  MAPs 
https://doi.org/10.17895/ices.advice.21641312 
Some cod and whiting stocks remain in poor condition despite various management measures 
and a  limitation to the current MAPs is that they do not define measures to be taken when 
stocks are below Blim.  There is a need to develop and implement rebuilding plans with clear 
targets and time-frames for stocks  below Blim based on best available scientific advice.  This 
might involve rebuilding to Bpa with 50% probability by 2 X T0 (the time required to rebuild 
with  zero  fishing).  This  could  allow  for  positive  catches  prevent  chokes  and  allow  for 
rebuilding with some additional risk. 

neutral, Not our remit but it is very soon to see evidence of medium or long-term impacts. 

2. 
There have not been medium or long-term simulations on the socio-economic impacts to our 
knowledge. 

beneficial - The MAPs are working well and do a good job in clarifying the understanding of 
3. 
how MSY is to  be implemented as a management objective. However, the list of target stocks 
in the plan is rigid with no clear criteria on what constitutes a target stock. In some cases, the 
scientific information is not sufficient to  provide MSY advice e.g., Pollack in area 7 and it is not 
clear why this stock is considered a target. Fishing  exploitation ranges are important if we are to 
integrate the ecosystem indicators to adjust the target fishing  mortality (e.g., as suggested by 
WKIRISH). 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

25 

 
 
 
 
 
 
 
4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Negative – There have been some discard reductions thanks to increased mesh sizes and effective 
technical measures since the introduction of the LO however discards are continuing for many 
demersal stocks in Western Waters according to the ICES assessments. 

2. The MAP FMSY ranges provide some scope to reconcile different fishing opportunities in mixed 
fisheries  and reduce discards. However, there are few examples of where the full MSY ranges have been 
used with  the objective of reducing discards. The MAP does not directly take account of by-catch 
stocks. For depleted  (below Blim) target species where bycatch TACs are set those bycatch TAC should 
be consistent with  rebuilding plans (as mentioned above). 

3. Implementation of the LO remains problematic in demersal mixed fisheries (https://bim.ie/wp-content 

/uploads/2021/02/Lo,report,2016_final.pdf).  Up  take  of  effective  technical  measures  remains  poorly 
documented. 

4. Many challenges remain for the industry to comply fully with the LO. 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

26 

 
 
 
 
 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

1.  neutral, In general, there has been very little implementation of EBFM in western waters. The MAP was 
introduced in 2019 and GES has not been achieved by 2020, there has been but according to ICES there 
has been a trend of declining fishing mortality since the mid-1990s for the benthic and demersal stocks 
with known status. The average F/FM SY ratio is below 1 for assessed benthic stocks and just above for 
the assessed demersal stocks. The trend for stock size in assessed benthic and demersal stocks has been 
increasing over the same period. The average F/FMSY ratio is below 1 for the crustacean stocks, and the 
average biomass has been above 1 in the past decade. The average F/FMSY ratio for pelagic assessed 
stocks has been above 1 in recent years, and the average stock size indicator is declining in recent years 
but remains above MSY Btrigger. 

2. negative. The MAP seems mainly concerned with single species stock MSY. 

3. Neutral – it is not clear what aspect of the “current situation” is intended here 

4. Negative – the combination of external drivers – fuel price, Brexit, COVID, control issues etc. Have 

reduced fishers interest in getting involved in EBFM approaches. 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

27 

 
 
 
 
 
 
 
 
 
9.4. Contributor of Ministry of Denmark 

Member of the North Sea Member States Group (Scheveningen Group) 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Setting  TACs  at  Maximum  Sustainable  Yield  (MSY)  has  been  an  important  milestone  in  transitioning 
towards sustainable fisheries management. The North Sea Multi Annual Plan (MAP) provides a range for 
MSY,  which  gives  some  needed  flexibility  for  a  coherent  management  of  fisheries  -  taking  into  account 
scientific  advice  and  in  a  lesser  extent  socio-economic  concerns.  Furthermore,  the  MAP  provides  a 
framework for conservation measures needed to preserve and restore the stocks covered on the long term. 

A  MSY  range  recognises that  multiple  factors  have  an  impact  on  the  stock  situation  (e.g.,  predator  -prey 
interactions).  Further,  flexibility  makes  the  current  single  species  MSY  concept  more  workable  (i.e.  in 
mixed fisheries) while maintaining MSY as a target and without jeopardising the sustainability of the stock. 
In practice, we see that the higher ends of the ranges are rarely used. 

Consideration  should  also  be  given  to  the  fact  that  choke  situations  most  likely  will  continue  to  be  a 
challenge as stock situations may change over time. 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

28 

 
 
 
 
 
3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

The  Member  States  in  the  Scheveningen  Group  have  continuously  addressed  the  challenges  encountered 
when  implementing  the  landing  obligation,  particularly  endeavoring  to  make  it  workable  within  the  legal 
framework while encouraging a change in fishing patterns towards further selectivity. 

The  legal  framework  acknowledges  continued  discards  based  on  either  high  survivability  or  de  minimis. 
Member States have put great effort into providing scientific knowledge on survivability of fish caught in 
different gears. The Scheveningen Group would like to emphasize the need for appropriate levels of TAC 
deductions  that  take  the  best  available  scientific  research  results  on  survivability  into  account  when 
calculating TAC deductions, and a level playing field on those TAC deductions with third countries such as 
the UK and Norway. 

The landing obligation has underlined the need for scientific research in order to develop gear that is more 
selective.  Member  States  are  conducting  multiple  research  projects  to  this  end.  The  Scheveningen  Group 
recognises  that  further  selectivity  has to  be  achieved in  some fisheries.  However,  for  the  mixed  demersal 
fisheries, there will be a limit to the degree of selectivity. 

From a socio-economic perspective, it is vital to ensure a smooth process for development of more selective 
gears that decrease unwanted catch as much as possible while keeping the Catch per Unit of Effort (CPUE) 
for the wanted part of the catch as high as possible. Cooperation between Member States on development 
and use of selective gears is crucial for a level playing field for fishermen. 

Requesting  derogations  from  the  landing  obligation  or  technical  measures  requires  extensive  work  by 
national  administrations,  but  these  exemptions  and  derogations  provide  necessary  practical  flexibility  for 
fishermen to mitigate challenges, while continuing trying to further develop more selective gears. 

Although the North Sea MAP provides the opportunity to adopt delegated Acts on technical measures, it is 
the  experience  of  the  Scheveningen  Group  that  the  timeframe  for  adopting  new  technical  measures  on 
selective gears in practice is long and complicated. This endangers the willingness of fishers to even engage 
in scientific projects. 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

29 

 
 
 
 
4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

The ecosystem approach is gradually being introduced and requires careful consideration of the interactions 
between different living marine resources, environmental drivers and fishing, but at this stage, we have not 
yet seen the full impact since scientific advice on the ecosystem-based approach is not yet comprehensive. It 
is important to note, that factors outside fisheries, such as climate change, pollution and predators like seals 
and cormorants also affect the conditions of fish stocks and the marine ecosystems. 

The MAP provides for a comprehensive approach with TAC setting based on ICES advice - in line with the 
sustainability objective. However, it provides for limited opportunity to consider species interactions when 
setting  fishing  opportunities.  Thus  far,  the  MAP  has  had  limited  effects  on  the  implementation  of  an 
ecosystem-based approach. 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Overall, the establishment of the MAP has provided a common approach for the relevant Member States 
in managing fisheries and offered an implementing tool for agreements with third countries regarding the EU 
legal framework. 

The MAP has strengthened the close cooperation between Member States in the regional groups on discard 
plans, technical measures and marine protected areas, resulting in proposals agreed upon by relevant Member 
States and thus, broad support for the exemptions from the landing obligation, specific technical measures and 
closures. This procedure allows an efficient and targeted process, involving Member States and the relevant 
stakeholders with direct interests. The current working procedures for those joint recommendations, however, 
do put a very important workload on the national fisheries administrations, advisory councils, STECF and DG 
MARE. 

The MAP is an EU only regulation and third countries are not legally bound by the content in the plan. Article 
13  of  the  MAP  offers  is  limited  as  a  legal  framework  for  the  EU  position  when  cooperating  on  fisheries 
management on stocks shared with third countries, especially with Norway and the UK. A substantially larger 
number of stocks are jointly managed with third countries in the post-Brexit context, which somewhat limits 
the ability of the EU to use the MAP as a tool to set fishing opportunities on shared stocks. It is important to 
find a new joint approach with the UK and Norway to avoid unilateral plans and measures, especially through 
work on new long term management plans for jointly managed stocks. 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

30 

 
 
 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

A  well-functioning  fisheries  sector  requires  that  the  EU  fisheries  legislation  is  simple,  manageable, 
up-to-date and adapted to the sector, society and technological development. Predictability and transparency 
are important factors when aiming for a faster achievement of the objectives provided for in article 3 of the 
MAP. The Scheveningen Group calls for s transparent, speedy and stringent approach from STECF to their 
evaluations of joint recommendations from the regional groups. 

The Scheveningen Group also sees a need for development of a robust scientific basis for implementing the 
objectives in Article 3. 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

31 

 
 
 
 
 
 
 
4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

32 

 
 
 
 
 
 
 
 
9.5. Member of LV National correspondents and of the Regional Coordination Groups 

(Data Collection Framework) 

Member of National correspondents and of the Regional Coordination Group (Data Collection 
Framework)  

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

No opinion, no fishery in North Sea 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

No opinion, no fishery in North Sea 

33 

 
 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in North Sea 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in North Sea 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in North Sea 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

34 

 
 
 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in Western Waters 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in Western Waters 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in Western Waters 

35 

 
 
 
 
 
 
In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

no opinion, no fishery in Western Waters 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

no opinion, no fishery in Western Waters 

36 

 
 
 
 
 
 
 
9.6. CNPMEM 

Member of the North Sea Advisory Council, South Western Advisory Council, Pelagic 
Advisory Council, Long Distance Advisory Council 

CNPMEM 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Le CNPMEM note la progression réalisé dans le nombre de stock géré au RMD en mer du Nord (cf Ifremer, 
cf communication de la CE COM(2022)253). Pour la plupart des stocks, le FRMD est, quand il est connu, la 
base de référence de fixation des TACs. 

Le plan de gestion offre une certaine flexibilité dans la fixation des possibilités de pêche en permettant de 
fixer le TAC dans une fourchette de capture autour du RMD (article 4). Cette disposition permet de prendre 
en compte la complexité de la gestion des pêcheries mixtes. Le CNPMEM regrette que cette possibilité ne 
soit  pas  utilisée  lors  des  négociations  des  TAC  et  Quotas.  Il  serait  pertinent  que  le  CIEM  soit  saisi  pour 
préciser les conditions d’utilisation de cette fourchette. Celui-ci propose notamment des scénarios intéressant 
avec  par  exemple  des  probabilités  d’atteindre  le  RMD  d’au  moins  95%,  qui  permettent  des  marges  de 
manœuvre intégrant les considérations socio-économiques. 

Enfin,  il  est  regrettable  de  ne  disposer  d’aucune  autre  mesures  que  la  fixation  d’un  TAC  0  lorsque  la 
biomasse du stock est en dessous de Blim. Il est nécessaire d’entamer des réflexions autour de la mise en 
place de plan de reconstitution avec des objectifs clairs et un calendrier défini basés sur les meilleurs avis 
scientifiques disponibles. 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 

37 

 
 
 
 
 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

38 

 
 
 
Depuis la mise en application partielle en 2016 puis totale en 2019 de l’OD, les rejets inscrits dans 
les avis CIEM, sont en diminution ou se stabilisent. Cependant, ces taux de rejets vont dépendre 
des pêcheries et surtout des espèces capturées. 

Une règle applicable pour l’ensemble des techniques de pêche et pour l’ensemble des espèces est 
irréalisable, car cela ne prend pas en compte les différences entre les stratégies de pêche entre 2 
engins,  les  différences  biologiques  entre  les  espèces  (morphologiques,  cycle  de  vie…)  et  les 
différences biogéographiques entre les différentes zones de pêche (que ce soit entre les façades ou 
dans les sous- zones de celles-ci). 

Malgré cette règle unique, l’objectif de lutte contre les rejets a permis dans un premier temps un 
accroissement  des  études  sur  la  sélectivité  et  le  développement  d’engins  sélectifs.  La  mise  en 
œuvre d’une l’ obligation de débarquement stricte est en revanche un échec, tant-elle ne prend pas 
en compte les impacts socio-économiques et la réalité des pêcheries. Le CNPMEM regrette que 
l’obligation  de  débarquement  soit  un  objectif  en  soi  et  non  plus  un  moyen  d’amélioration  de  la 
sélectivité. 

Grace aux PG, les états membres et les professionnels ont pu avoir les outils pour déroger à l’OD, 
par  le  biais  des  exemptions,  pour  que  celle-ci  soient  plus  facilement  réalisable,  cette  flexibilité 
offerte par les exemptions est essentielle pour les professionnels. Mais leur obtention et leur durée 
d’application ne sont pas garantie d’une année sur l’autre ou bien trop peu sécurisées. De plus les 
exemptions sont bien trop précises pour permettre aux pêcheurs travaillant sur plusieurs zones de 
connaitre  exactement  les  réglementations  applicables.  Des  exemptions  d’offices  pour  toutes  les 
espèces soumissent à l’OD pourrait être la solution pour garantir cette flexibilité aux pêcheurs. 

L’utilisation  des  exemptions  (de  survie  et  de  de  minimis)  sont  de  fait  essentiel  pour  ne  pas 
entrainer l’arrêt de l’ensemble des pêcheries d’Europe. 

En  effet,  la  question  des  choke  species  est  l’un  des  plus  gros  challenges  de  l’obligation  de 
débarquement.  Le  CNPMEM  a  interpellé  l’administration  et  la  Commission  européenne  a  de 
multiples  reprises,  sans  réponse  satisfaisante.  En  effet  l’application  dogmatique  de  l’article  15 
dans  un  contexte  de  pêcheries  mixtes  demeure  impossible  sans  lourdes  conséquences  socio-
économiques sur les pêcheries concernées. A noter que le rapport EODE mené dans les Hauts-de-
France a permis de quantifier très précisément ces impacts. L’article 14 de la PCP permettant la 
mise en place de projet pilote dédié à la recherche de dispositifs innovants est une des solutions à 
mettre en œuvre. 

La  fixation  des  TAC  dans  la  fourchette  du  RMD  pourrait  également  résoudre  une  partie  des 
difficultés,  tout  en  gardant  à  l’esprit  que  le  contexte  de  pêcheries  mixtes  reste  une  difficulté 
majeure. A noter que la fixation de TAC 0 est incompatible avec la mise en œuvre de l’obligation 
de débarquement et la continuité des activités de pêche dans la zone. 

L’impact socio-économique de l’OD est l’un des principaux facteurs pour lesquels l’OD a du mal 
à être pleinement mise en place. Pour beaucoup le traitement des rejets est perçu comme du travail 
supplémentaire non rémunérées et est une mesure décidée indépendamment de la réalité du métier. 
Cependant les exemptions ont permis d’offrir au minimum une flexibilité aux marins dans leurs 
pratiques.  Aujourd’hui  il  semble  difficile  de  voir  l’impact  de  l’OD  seule  sur  l’économie  de  la 
pêche, car le secteur sort de plusieurs crises successives (Covid, Brexit, conflit en Ukraine). 

39 

 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Dans un premier temps, il est nécessaire d’introduire une plus grande flexibilité dans la mise en œuvre du 
plan  de  gestion  pour  pouvoir  adapter  la  gestion  des  stocks,  qui  sont  soumis  à  des  changements 
écosystémiques majeurs. La pêche ne peut être la variable d’ajustement pour maintenir sur un court terme 
une exploitation au RMD. 

En  effet,  l'article  3.3  du  plan  de  gestion  de  mer  du  Nord  indique  que  "Le  plan  met  en  œuvre  l'approche 
écosystémique de la gestion des pêches afin de garantir que les impacts négatifs des activités de pêche sur 
l'écosystème marin sont minimisés". Le CNPMEM souhaite rappeler deux points importants : 

- 

- 

-  La nécessité de prendre en compte les trois piliers de la durabilité - environnement, responsabilité sociale et 
économie. Ainsi, la dimension socio-économique de la PCP doit être renforcée et l'article 2.1 de la PCP doit 
être pris en compte lors de l’instauration d’une mesure de gestion. 

-   La nécessité de ne pas uniquement prendre en compte la pression de la pêche sur les stocks mais adopter une 
approche globale qui tient compte de l’ensemble des pressions sur l'environnement marin (changement 
climatique, pollution, autres usages, etc.). 

Ceci étant dit, il semble important d’entamer une réflexion sur les modifications possibles dans la liste des 
espèces ciblées pour tenir compte de l'évolution des besoins en matière de production alimentaire dans le 
cadre des changements environnementaux. Il est également nécessaire de concentrer des moyens permettant 
d’améliorer les connaissances sur les autres facteurs anthropiques 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

40 

 
 
 
Le PPA est un cadre réglementaire permettant aux Etats membres de mettre en place des mesures régionales. 
Le CNPMEM participe ainsi activement aux différents CC qui fournissent des avis sur les recommandations 
conjointe.  De  même,  le  CNPMEM  travaille  en  étroite  collaboration  avec  l’administration  française  sur  ces 
questions. 

De  cette  expérience,  le  CNPMEM  souligne  l’importance  d’une  communication  fluide  et  régulière  visant  à 
renforcer la collaboration entre les acteurs. 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

L’article 3.5 du PG mer du Nord précise que « Les mesures prises au titre du plan le sont sur la  base des 
meilleurs avis scientifiques disponibles ». Une réflexion sur la définition des « meilleurs avis scientifiques 
possibles » semble nécessaire. 

Nécessité de prendre la pleine mesure des possibilités offertes par les plans de gestion. L’application s’est 
pour  l’heure  trop  contentée  de  s’intéresser  à  la  fixation  des  possibilités  de  pêche  sur  le  court  terme,  sans 
prendre en compte les impacts socio-économiques. Il est aujourd’hui nécessaire que celui-ci se concentrer 
sur les perspectives d’évolutions pour faire face aux défis à venir. 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

41 

 
 
 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

Le CNPMEM note la progression réalisé dans le nombre de stock géré au RMD dans les eaux occidentales 
(cf Ifremer, cf communication de la CE COM(2022)253). Pour la plupart des stocks des eaux occidentale, le 
FRMD est, quand il est connu, la base de référence de fixation des TACs. 

Le plan de gestion offre une certaine flexibilité dans la fixation des possibilités de pêche en permettant de 
fixer le TAC dans une fourchette de capture autour du RMD (article 4). Cette disposition permet de prendre 
en compte la complexité de la gestion des pêcheries mixtes. Le CNPMEM regrette que cette possibilité ne 
soit  pas  utilisée  lors  des  négociations  des  TAC  et  Quotas.  Il  serait  pertinent  que  le  CIEM  soit  saisi  pour 
préciser les conditions d’utilisation de cette fourchette. Celui-ci propose notamment des scénarios intéressant 
avec  par  exemple  des  probabilités  d’atteindre  le  RMD  d’au  moins  95%,  qui  permettent  des  marges  de 
manœuvre intégrant les considérations socio-économiques. 

Le  CNPMEM  regrette  également  la  rigidité  dans  la  liste  des  espèces  cibles  caractérisés  dans  le  plan  de 
gestion, notamment en l’absence de définition claire de définition de la pêche ciblée. Par exemple, le lieu 
jaune de la zone 7 est défini comme un stock ciblé, alors qu’il n’est pas ciblé par une pêcherie spécifique et 
que la connaissance du stock est insuffisante pour que le CIEM fournisse des indicateurs de RMD. 

Enfin,  il  est  regrettable  de  ne  disposer  d’aucune  autre  mesures  que  la  fixation  d’un  TAC  0  lorsque  la 
biomasse du stock est en dessous de Blim. Il est nécessaire d’entamer des réflexions autour de la mise en 
place de plan de reconstitution avec des objectifs clairs et un calendrier défini basés sur les meilleurs avis 
scientifiques disponibles. 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

42 

 
 
 
 
L’objectif  de  lutte  contre  les  rejets  a  permis  dans  un  premier  temps  un  accroissement  des  études  sur  la 
sélectivité et le développement d’engins sélectifs. La mise en œuvre d’une l’obligation de débarquement 
stricte  est  en  revanche  un  échec,  tant-elle  ne  prend  pas  en  compte  les  impacts  socio-économiques  et  la 
réalité  des  pêcheries.  Le  CNPMEM  regrette que l’obligation  de  débarquement soit un  objectif en  soi et 
non plus un moyen d’amélioration de la sélectivité 

L’utilisation des exemptions (de survie et de de minimis) sont de fait essentiel pour ne pas entrainer l’arrêt 
de l’ensemble des pêcheries d’Europe. 

En effet, la question des choke species est l’un des plus gros challenges de l’obligation de débarquement. 
Le  CNPMEM  a  interpellé  l’administration  et  la  Commission  européenne  a  de  multiples  reprises,  sans 
réponse  satisfaisante.  En  effet  l’application  dogmatique  de  l’article  15  dans  un  contexte  de  pêcheries 
mixtes demeure impossible sans lourdes conséquences socio-économiques sur les pêcheries concernées.  

A noter que le rapport EODE mené dans les Hauts-de-France a permis de quantifier très précisément ces 
impacts.  L’article  14  de  la  PCP  permettant  la  mise  en  place  de  projet  pilote  dédié  à  la  recherche  de 
dispositifs innovants est une des solutions à mettre en œuvre. 

La fixation des TAC dans la fourchette du RMD pourrait également résoudre une partie des difficultés, 
tout en gardant à l’esprit que le contexte de pêcheries mixtes reste une difficulté majeure. A noter que la 
fixation de TAC 0 est incompatible avec la mise en œuvre de l’obligation de débarquement et la continuité 
des activités de pêche dans la zone. 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

43 

 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

Dans un premier temps, il est nécessaire d’introduire une plus grande flexibilité dans la mise en œuvre du 
plan  de  gestion  pour  pouvoir  adapter  la  gestion  des  stocks,  qui  sont  soumis  à  des  changements 
écosystémiques majeurs. La pêche ne peut être la variable d’ajustement pour maintenir sur un court terme 
une exploitation au RMD. 

En  effet,  l'article  3.3  du  plan  de  gestion  des  EO  indique  que  "Le  plan  met  en  œuvre  l'approche 
écosystémique de la gestion des pêches afin de garantir que les impacts négatifs des activités de pêche sur 
l'écosystème marin sont minimisés". Le CNPMEM souhaite rappeler deux points importants : 

- 

- 

-  La nécessité de prendre en compte les trois piliers de la durabilité - environnement, responsabilité sociale et 
économie. Ainsi, la dimension socio-économique de la PCP doit être renforcée et l'article 2.1 de la PCP doit 
être pris en compte lors de l’instauration d’une mesure de gestion. 

-  La nécessité de ne pas uniquement prendre en compte la pression de la pêche sur les stocks mais adopter une 
approche globale qui tient compte de l’ensemble des pressions sur l'environnement marin (changement 
climatique, pollution, autres usages, etc.). 

Ceci étant dit, il semble important d’entamer une réflexion sur les modifications possibles dans la liste des 
espèces ciblées pour tenir compte de l'évolution des besoins en matière de production alimentaire dans le 
cadre  des  changements  environnementaux.  Il  est  également  nécessaire  de  concentrer  des  moyens 
permettant d’améliorer les connaissances sur les autres facteurs anthropiques. 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Le  PPA  est  un  cadre  réglementaire  permettant  aux  Etats  membres  de  mettre  en  place  des  mesures 
régionales. Le CNPMEM participe ainsi activement aux différents CC qui fournissent des avis sur les 
recommandations  conjointe.  De  même,  le  CNPMEM  travaille  en  étroite  collaboration  avec 
l’administration française sur ces question. 

De  cette  expérience,  le  CNPMEM  souligne  l’importance  d’une  communication  fluide  et  régulière 
visant à renforcer la collaboration entre les acteurs. 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Sur l’article 3.5 du PG EO, une réflexion sur les « meilleurs avis scientifiques possibles » semble nécessaire. 
Nécessité de prendre la pleine mesure des possibilités offertes par les plans de gestion. L’application s’est 
pour  l’heure  trop  contentée  de  s’intéresser  à  la  fixation  des  possibilités  de  pêche  sur  le  court  terme,  sans 
prendre en compte les impacts socio-économiques. Il est aujourd’hui nécessaire que celui-ci se concentrer 
sur les perspectives d’évolutions pour faire face aux défis à venir. 

44 

 
 
 
 
 
9.7. North Sea Member States Group (Scheveningen Group) 

Members of the North Sea Member States Group (Scheveningen Group) 

Joint reply by the Scheveningen Group on the North Sea MAP 

The  Scheveningen  Group  appreciates  the  opportunity  to  be  consulted  on  the  North  Sea 
MMulti Annual Plan. The Scheveningen Group provides the following remarks: 

MSY  

According  to  the  North Sea  MAP,  MSY  was  to be  achieved  for  all  relevant  stocks  by  2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

To what extent has the MAP contributed to increase the number of TACs set at MSY? 

What  is  the medium to  long-term socio-economic impact  on  the fisheries concerned when a 
TAC is set at MSY? 

What  change  was  brought  by  the  establishment  of  the  target  fishing  mortality  (F)  that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, which are 
consistent with achieving MSY (FMSY)? 

Reply: 

Setting  TACs  at  Maximum  Sustainable  Yield  (MSY)  has  been  an  important  milestone  in 
transitioning towards sustainable fisheries management. The North Sea MMulti Annual Plan 
(MAP)  provides  a  range  for  MSY,  which  gives  some  needed  flexibility  for  a  coherent 
management of fisheries  - taking into account  scientific advice and in  a lesser extent socio-
economic concerns. Furthermore, the MAP provides a framework for conservation measures 
needed to preserve and restore the stocks covered on the long term.  

A  MSY  range  recognises  that  multiple  factors  have  an  impact  on  the  stock  situation  (e.g., 
predator -prey interactions). Further, flexibility makes the current single species MSY concept 
more  workable  (i.e.  in  mixed  fisheries)  while  maintaining  MSY  as  a  target  and  without 
jeopardising  the  sustainability  of  the  stock.  In  practice,  we  see  that  the  higher  ends  of  the 
ranges are rarely used. 

Consideration should also be given to the fact that choke situations most likely will continue 
to be a challenge as stock situations may change over time. 

DISCARDS 

On  discards  (unwanted  catches  that  are  returned  to  the  sea)  and  the  landing  obligation 
(Article 15 of the CFP Regulation), in your opinion: 

45 

 
 
 
 
 
 
 
 
 
To  what  extent  discards  have  been  eliminated  and  the  landing  obligation  has  been  actually 
implemented? 

To  what  extent  has  the  MAP  contributed  to  achieving  the  current  situation  in  terms  of  the 
elimination  of  discards  and  implementation  of  the  landing  obligation? More  specifically,  to 
what  extent  does  the  MAP  allow  taking  into  account  the  management  of  mixed  fisheries  – 
management of by-catch stocks and avoidance of choking situations  

What  is  the  impact  of  the  current  situation  in  terms  of  the  elimination  of  discards  and 
implementation of the landing obligation on the relevant stocks? What is the socio-economic 
impact of the current situation in terms of the elimination of discards and implementation of 
the landing obligation on the fisheries concerned. 

Reply: 

The Member States in  the Scheveningen Group  have continuously addressed the challenges 
encountered  when  implementing  the  landing  obligation,  particularly  endeavoring  to  make  it 
workable within the legal framework while encouraging a change in fishing patterns towards 
further selectivity. 

The legal  framework acknowledges continued discards based on either high survivability or 
de  minimis.  Member  States  have  put  great  effort  into  providing  scientific  knowledge  on 
survivability  of  fish  caught  in  different  gears.  The  Scheveningen  Group  would  like  to 
zemphasize  the  need  for  appropriate  levels  of  TAC  deductions  that  take  the  best  available 
scientific research results on survivability into account when calculating TAC deductions, and 
a  level  playing  field  on  those  TAC  deductions  with  third  countries  such  as  the  UK  and 
Norway. 

The landing obligation has underlined the need for scientific research in order to develop gear 
that  is  more  selective.  Member  States  are  conducting  multiple  research  projects  to  this  end.  
The  Scheveningen  Group  recognises  that  further  selectivity  has  to  be  achieved  in  some 
fisheries.  However,  for  the  mixed  demersal  fisheries,  there  will  be  a  limit  to  the  degree  of 
selectivity. 

From a socio-economic perspective, it is vital to ensure a smooth process for development of 
more  selective  gears  that  decrease  unwanted  catch  as  much  as  possible  while  keeping  the 
Catch  per  Unit  of  Effort  (CPUE)  for  the  wanted  part  of  the  catch  as  high  as  possible. 
Cooperation between Member States on development and use of selective gears is crucial for 
a level playing field for fishermen. 

Requesting derogations from the landing obligation or technical measures requires extensive 
work  by  national  administrations,  but  these  exemptions  and  derogations  provide  necessary 
practical  flexibility  for  fishermen  to  mitigate  challenges,  while  continuing  trying  to  further 
develop more selective gears. 

Although the North Sea MAP provides the opportunity to adopt delegated Acts on technical 
measures, it is the experience of the Scheveningen Group that the timeframe for adopting new 
technical measures on selective gears in practice is long and complicated. This endangers the 
willingness of fishers to even engage in scientific projects.  

46 

 
 
 
 
 
 
ECOSYSTEM-BASED APPROACH TO FISHERIES MANAGEMENT 

In general, within the context of fisheries management in the North Sea, to what extent has the 
objective  of  implementing  an  ecosystem-based  approach,  and  notably  of  achieving  good 
environmental status by 2020, been achieved?  

To what  extent has  the  MAP contributed to  the  current  situation in  terms of  the ecosystem-
based approach?  

What is the impact of the current situation in terms of the ecosystem-based approach on the 
relevant stocks? 

 What is the socio-economic impact of the current situation in terms of the ecosystem-based 
approach on the fisheries concerned 

Reply: 

The ecosystem  approach is  gradually being  introduced and requires careful  consideration of 
the interactions between different living marine resources, environmental drivers and fishing, 
but at this stage, we have not yet seen the full impact since scientific advice on the ecosystem-
based approach is not yet comprehensive. It is important to note, that factors outside fisheries, 
such  as  climate  change,  pollution  and  predators  like  seals  and  cormorants  also  affect  the 
conditions of fish stocks and the marine ecosystems. 

The MAP provides for a comprehensive approach with TAC setting based on ICES advice - 
in  line  with  the  sustainability  objective.  However,  it  provides  for  limited  opportunity  to 
consider species  interactions  when setting  fishing  opportunities.  Thus far, the MAP  has  had 
limited effects on the implementation of an ecosystem-based approach. 

REGIONAL COOPERATION 

In  your  opinion,  to  what  extent  has  the  MAP  strengthened  regional  cooperation  on  the 
proposal  of  conservation  measures  through  the  submission  of  joint  recommendations, 
including with stakeholders? 

Reply: 

Overall,  the  establishment  of  the  MAP  has  provided  a  common  approach  for  the  relevant 
Member States in managing fisheries and offered an implementing tool for agreements with 
third countries regarding the EU legal framework.  

The  MAP  has  strengthened  the  close  cooperation  between  Member  States  in  the  regional 
groups on discard plans, technical measures and marine protected areas, resulting in proposals 
agreed upon by relevant Member States and thus, broad support for the exemptions from the 
landing  obligation,  specific  technical  measures  and  closures.  This  procedure  allows  an 
efficient  and  targeted  process,  involving  Member  States  and  the  relevant  stakeholders  with 
direct  interests.  The  current  working  procedures  for  those  joint  recommendations,  however, 
do put a very important workload on the national fisheries administrations, advisory councils, 
STECF and DG MARE.  

The MAP is an EU only regulation and third countries are not legally bound by the content in 
the  plan.  Article  13  of  the  MAP  offers  is  limited  as  a  legal  framework  for  the  EU  position 

47 

 
 
 
 
 
when cooperating on fisheries management on stocks shared with third countries, especially 
with Norway and the UK. A substantially larger number of stocks are jointly managed with 
third countries in the post-Brexit context, which somewhat limits the ability of the EU to use 
the MAP as a tool to set fishing opportunities on shared stocks. It is important to find a new 
joint  approach  with  the  UK  and  Norway  to  avoid  unilateral  plans  and  measures,  especially 
through work on new long term management plans for jointly managed stocks. 

ADDITIONAL MEASURES 

Are  there  any  additional  measures  that  would  contribute  to  the  faster  achievement  of  the 
objectives provided for in Article 3 of the MAP? 

Reply: 

A  well-functioning  fisheries  sector  requires  that  the  EU  fisheries  legislation  is  simple, 
manageable,  up-to-date  and  adapted  to  the  sector,  society  and  technological  development. 
Predictability and transparency are important factors when aiming for a faster achievement of 
the objectives provided for in a article 3 of the MAP.  

The Scheveningen Group calls for s transparent, speedy and stringent approach from STECF 
to their evaluations of joint recommendations from the regional groups. 

The  Scheveningen  Group  also  sees  a  need  for  development  of  a  robust  scientific  basis  for 
implementing the objectives in Article 3.  

48 

 
 
 
 
 
 
 
9.8. North Sea Advisory Council 

This paper was approved with consensus by the NSAC Executive Committee on 23 May 2023 
via written procedure. 

1.  Background 

The CFCommon Fisheries Policy (CFP) highlights the importance of establishing multiannual 
plans,  taking  into  account  the  specificities  of  the  different  regions  and  fisheries, 
acknowledging  that  the  objective  of  sustainable  extraction  of  marine  biological  resources  is 
more  effectively  achieved  through  a  multiannual  approach  to  fisheries  management.  The 
Regulation  2018/973  establishes  a  multiannual  plan  for  the  following  demersal  stocks  in 
Union waters of the North Sea (ICES divisions 2a, 3a and subarea 4): cod, haddock,  plaice, 
sole,  whiting,  anglerfish,  northern  prawn,  and  Norway  lobster.  It  also  applies  to  by-catches 
caught in the North Sea when fishing for the above-listed stocks. 

The North Sea Advisory Council (NSAC) provided advice in 2017 on the North Sea Multi- 
annual  Plan  (MAP)28  prior  to  its  final  publication  in  2018,  with  provisions  on  geographical 
scope,  socio-economic  considerations,  treatment  of  stocks,  alignment  with  the  Technical 
Measures Framework, scientific underpinning, enhanced data collection and knowledge-base, 
information processing and modelling. 

The  Regulation  (EU)  2018/973  stipulates  that  the  Commission  shall  report  to  the  European 
Parliament and Council on the implementation of the MAP by 6 August 2023. On 18 January 
2023,  the  Commission  sent  a  letter  to  the  NSAC  requesting  its  input  to  the  public 
consultation,  in  which it called upon the Advisory Council to  provide a position paper with 
the unified view of its constituents. Should this not be possible, individual organisations were 
invited  to  submit  independent  responses  to  the  survey.  This  paper  is  an  attempt  to  collate 
experience and views of the North Sea demersal fisheries organisations and other stakeholders 
on the implementation of the North Sea MAP. 

2.  Advice 

The NSAC believes that MAPs are appropriate and potentially useful tools for achieving the 
objectives of the CFCommon Fisheries Policy. However, a more ecosystem-based and longer- 
term approach to MAPs is needed. The MAPs should be improved to make them regionally 
tailored  and  ecosystem-based,  and  to  include  clear  environmental  and  socio-economic 
objectives,  as  also  specified  in  the  NS  MAP.  In  our  2017  Advice  Ref.11-1617  we  mention 
that it is important  to  consider the implication of Fmsy  ranges in  a mixed fisheries  context. 
Fishing  contributes  to  food  security  and  as  such  requires  a  better  appreciation  of  socio-
economic impacts. 

(28) https://www.nsrac.org/wp-content/uploads/2020/06/12-1617-NSAC-Response-to-the-NS-MAP.pdf 

49 

 
 
 
 
 
The MAP for the North Sea entered into force at a time when the UK was part of the EU and 
most  of  the  fisheries  in  the  North  Sea  were  regulated  through  the  CFCommon  Fisheries 
Policy. Following Brexit, this is  no longer the case. The CFP  and therefore the MAP  today 
only apply to a minor part of the North Sea as such – the EU waters. It should be investigated 
whether  the  present  wording  of  the  plan  appropriately  reflects  this  situation.  The  UK  and 
Norway  are  not  bound  by  the  plan  despite  the  fact  that  for  several  of  the  most  important 
stocks the UK and Norway have the major part of the stocks according to the allocation keys 
established between the three parties. 

In general, we believe that MAPs may have contributed to an increase in the number of TACs 
set at MSY. In 2020, 62 out of 78 TACs are set at a level that allows a healthy future for the 
fish stocks' biomass, compared to only 5 out of 35 in 2009. In addition, the number of stocks 
fished above Fmsy in the Greater North Sea region has fallen from 12 in 2019 to 9 in 2020.29 
Furthermore, the overall fishing pressure ratio (F/Fmsy) has fallen below 1 for the first time in 
2020,  indicating  a  sustainable  pressure.  It  is  not  clear  whether  the  MAP  was  the  defining 
factor  in  these  improvements,  as  it  also  addresses  stocks  shared  with  the  UK  and  Norway 
where  TACs  are  set  following  bilateral  and  trilateral  consultations,  and  therefore  not 
necessarily determined (solely) by the MAP. 

Despite overall improvements, the cost for fishing communities has been high - much higher 
than indicated by the simple calculations of average gross profits. The rigid way in which the 
theoretically sensible target fishing mortality (Fmsy) has been implemented in the plans has 
led to unstable quotas relying heavily on the latest stock assessments and not considering the 
short-term  implications  for  fishing  communities.  The  medium  to  long-term  socio-economic 
impact on the fisheries concerned when a TAC is set at MSY should in theory be positive, but 
there are cases, such as for saithe in the North Sea, where this has not been the case. There 

are  also  some  stocks,  such  as  haddock,  where  the  stock  dynamics  calls  for  a  more  flexible 
approach, rather than merely setting the TAC at Fmsy yearly. 

On discards (unwanted catches that are returned to the sea) and the landing obligation (LO) 
(Article  15  of  the  CFP  Regulation),  it  is  our  opinion  that  the  landing  obligation  was 
introduced with insufficient consideration of the consequences to the industry as well as lack 
of  analysis  of  the  benefits  for  the  stocks.  First  and  foremost,  the  purpose  of  LO  is  not  well 
described. If it is to reduce the wasting of resources, why then ban the use of small fish? If it 
is  to  push  fishers  into  using  more  selective  gears,  why  then  make  technical  regulations  that 

policy: 

(29)  STECF  ad hoc  report:  Monitoring  of  the  performance  of  the  common 
fisheries 
https://stecf.jrc.ec.europa.eu/reports/cfp-monitoring/-
/asset_publisher/oz5O/document/id/26714692?inheritRedirect=false&redirec
t=https%3A%2F%2Fstecf.jrc.ec. 
europa.eu%2Freports%2Fcfp- 
monitoring%3Fp_p_id%3D101_INSTANCE_oz5O%26p_p_lifecycle%3D0%26p_
p_state%3Dnormal%26p_p_mod 
e%3Dview%26p_p_col_id%3Dcolumn-
2%26p_p_col_pos%3D1%26p_p_col_count%3D2. 

50 

 
 
 
 
force  them  to  use  the  gears  that  generate  discards?  If  it  is  to  work  with  catch  quotas  rather 
than landing quotas, why not just make it compulsory to register it rather than force fishers to 
land it and then throw it out? 

From  a  management  point  of  view,  it  does  make  sense  to  ask  fishers  to  register  their  total 
catch,  as  this  is  important  for  scientific  assessments.  Yet  there  is  no  good  argument  for 
making fishers land all their catch. Also, it should be zrecognized that not all stocks react in 
the  same  way  to  discarding  and  that  practices  vary  between  fisheries,  areas,  and  seasons.  It 
makes good sense to  ban discarding of fish with a swim  bladder, such as cod, haddock and 
saithe, but it makes no or little sense to force fishers to kill and land small plaice known to 
survive  the  release.  Fishers  can  see  that  some  stocks  are  not  affected  by  historic  discard 
practices (e.g. plaice), whereas others might be. Then again it must be remembered that it is 
not  the  discarding  itself  that  has  an  impact,  it  is  whether  the  catch  is  registered  or  not.  The 
stock  does  obviously  not  benefit  from  fish  being  killed  and  landed  rather  than  just  being 
discarded at sea. 

Further  considerations  on  Article  15  and  the  landing  obligation  have  been  gathered  by  the 
NSAC in its advice on the functioning of the landing obligation, which the reader may access 
here. 

2.1 Mixed fisheries considerations 

Most  of  the  demersal  fisheries  target  a  mixture  of  species.  The  composition  of  the  catch  is 
determined  by  multiple  factors  such  as  fishing  gear,  area,  season,  and  abundance  of  the 
various species. This needs to be considered with a high degree of pragmatism. Setting a low 
quota  on  an  abundant  species,  in  order  to  protect  another  species,  while  expecting  full 
compliance  with  a  landing  obligation  has  proven  a  challenge.  Following  a  request  from  the 
Commission,  the  ICES  produces  an  annual  paper  on  mixed  fisheries  considerations.  This 
paper is usually published in the period when the EU, Norway and UK consultations setting 
the  TACs  for  the  coming  year  take  place.  However,  it  is  very  unclear  how  the  relation 
between  the  MAP  and  the  paper  on  mixed  fisheries  considerations  is  to  be  understood  and 
how they align. Moreover, the stocks are shared between the EU, the UK and Norway - states 
and  entities  with  different  management  regimes.  The  ICES  work  on  the  issue  is  not 
sufficiently  developed  to  reflect  the  various  aspects.  It  is  important  that  the  capability  of 
individual  fishers  to  adapt  to  apparently  opposing  trends  and  regulations  is  given  a  much 
higher priority as is currently the case in the present management plans. 

The technical regulations prevent fishermen from increasing selectivity and the NSAC believe 
that more freedom to adapt gears to the individual fishers needs would reduce the incentive to 
discard unwanted catches. Within  the context of  fisheries management in the North  Sea the 
objective  of  implementing  an  ecosystem-based  approach,  and  notably  of  achieving  good 
environmental  status  by  2020,  has  not  been  sufficiently  achieved,  though  there  have  been 
significant improvements in the efforts to implement ecosystem-based fisheries management. 
The rate of overfishing in the North Sea is low and has been falling, which is a direct effect of 

51 

 
 
 
improved  management  and  efforts  of  the  fishing  community,  as  well  as  environmental 
stakeholders. We believe that the MAP has contributed to these efforts. 

In view of the NSAC, the NS MAP has strengthened regional cooperation on the proposal of 
conservation  measures  through  the  submission  of  joint  recommendations,  together  with 
stakeholders, though stakeholder consultations had at times been seen as a mere box-ticking 
exercise with limited time available for proper consideration of documentation by the NSAC 
members, and/or executed when the positions have already been established and were not to 
be diverged significantly notwithstanding the NSAC advice. 

The NSAC believe that the NS MAP could be significantly improved with more focus on the 
role  of  fisheries  in  providing  healthy,  low-carbon  food  as  well  as  social  benefits  to  coastal 
communities, which would require a more pragmatic use of MSY. The NSAC is in favour of 
using the concept and supports the objective of the CFP, but believes that there are benefits to 
a more pragmatic use of the ranges of Fmsy. This is particularly important in respect of the 
mixed fisheries, but also has benefits in other cases. Therefore, the three conditions for using 
the Fmsy upper range should be abolished (or softened) or expanded with a socio-economic 
clause. A more flexible approach could even be applied, where the objective is to be within a 
range of fishing mortality which allows for the stock to be rebuilt over a longer period. If the 
stock is below target, the TAC should be set at a level that – according to scientific advice – 
leaves the stock closer to the target after the regulation than it was before the regulation was 
set. 

3.  Conclusion 

In conclusion, the NSAC believes that the  NS  MAP  has positively  contributed to  improved 
sustainability of the North Sea demersal fisheries and more pragmatic management. However, 
there are still some shortcomings/aspects that could be addressed to make the MAP work for 
and with the fisheries for an environmentally, economically, and socially viable industry. The 
NSAC thanks the Commission for the opportunity to comment on the public consultation on 
the North Sea MAP and invites any further discussion on the matter. 

52 

 
 
 
 
9.9. Citizens 

Western Waters MAP 

According  to  the  Western  Waters  MAP,  MSY  was  to  be  achieved  for  all  relevant  stocks  by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY  

There has been a gradual improvement in the status of stocks in relation to MSY targets in the 
Celtic  Sea  ecoregion  since,  amongst  other  things,  the  introduction  of  the  MAPs  
https://doi.org/10.17895/ices.advice.21641312. The recent communication from Commission 
regarding  the  orientations  for  the  2023  fishing  opportunities  recalled  that  in  recent  years, 
fishing opportunities have been set in line with the MSY for most stocks.  

However, several cod and whiting stocks (i.e. cod in 6a, 7a and 7b-k; whiting in 7a and 7b-k) 
in  North-western  Waters  remain  in  poor  condition  despite  various  management  measures 
being introduced. This includes remedial technical measures implemented under Article 8 of 
the WWMAP for the Celtic Sea cod stock in recent years.  

The  MAP is an EU only regulation and third countries are not legally bound by the content of 
the  plan.  Article  15  of  the  MAP  offers  is  limited  as  a  legal  framework  for  the  EU  position 
when cooperating on fisheries management on stocks shared with third countries, especially 
the  UK.  A  substantially  larger  number  of  stocks  are  jointly  managed  with  UK  as  a  third 
country  in  the  post-Brexit  context,  which  somewhat  limits  the  ability  of  the  EU  to  use  the 
MAP as a tool to set fishing opportunities on shared stocks. It is important to find a new joint 
approach with the UK to avoid unilateral plans and measures, especially through work on new 
long term management plans for jointly managed stocks. 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY?  

It is too soon to see evidence of medium or long-term impacts associated with reaching MSY 
taking into account that it is also related to specificities of some fisheries (ie mixed fisheries’s 
related  species).   There  have  been  no  medium  or  long-term  socio-economic  simulations  to 
date specifically carried out for the North-western Waters. 

On  a  short-term  basis,  the  answer  varies  depending  on  the  stocks  considered  and  the 
importance of TAC fluctuations. In principle, brutal changes of TAC level, particularly in  a 
decreasing trend, have zdestabilizing effects on the activities of fishing operators. 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)?  

The MAPs are working well and do a good job in clarifying the understanding of how MSY is 
to be implemented as a management objective.  

53 

 
 
 
In  addition,  the  flexibility  allowed  by  the  regulation  when  giving  access  to  MSY  ranges  is 
important. Notably, it allows taking into account the specificities of mixed-fisheries, intra an 
inter-species dynamics and to limit TAC fluctuations to 20%. 

In case of shared stocks, it is however necessary that the third Party involved also agrees to 
implement such ranges (which was not the case for Norway regarding the NS MAP). 

However, the criterias on which the list of target stocks lies is unclear, for example when the 
scientific information is not sufficient to provide MSY advice (e.g., Pollack in area 7) 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion:  

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented?  

2.  To what extent has the MAP contributed to achieving the current situation in terms of 
the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management of 
mixed fisheries – management of by-catch stocks and avoidance of choking situations?  

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

While there is evidence in a decrease in discards, it is clear that the landing obligation has not 
met  its  objective,  given  implementation  issues,  reportedly  widely  by  Member  States. 
Notwithstanding  this,  considerable  efforts  have  been  dedicated  by  the  fisheries  sector  since 
the  introduction  of  the  landing  obligation  to  understand  and  then  implement  this  policy  as 
well as actively engaging with research institutes to develop ways of avoiding and reducing 
unwanted  catches,  as  well  as  improving  general  knowledge  on  these  species  (i.e. 
survivability).  The  considerable  revolution  this  obligation  introduced  in  the  fishing  sector 
should be underlined here once again.  

For  example,  Member  States  have  put  great  effort  into  providing  scientific  knowledge  on 
survivability  of  fish  caught  in  different  gears.  Member  States  are  also  conducting  multiple 
research projects to develop gear that is more selective.  

One  of  the  key  issues  associated  with  the  landing  obligation  is  that  it  currently  ignores  the 
very  different  levels  of  discarding  and  very  different  levels  of  difficulty  to  achieve  full 
implementation  of  the  landing  obligation.  This  is  particularly  important  in  Western  Waters 
given the predominance of mixed fisheries in the region.  

54 

 
 
 
On  regionalisation,  the  MAP  has  provided  the  mechanism  for  exemptions  to  the  landing 
obligation under regionalisation so in this regard has contributed to the implementation of the 
landing obligation. 

The  Member  States  in  the  North  wwestern  waters  Group  have  continuously  addressed  the 
challenges  encountered  when  implementing  the  landing  obligation,  particularly  endeavoring 
to  make  it  workable  within  the  legal  framework  while  encouraging  a  change  in  fishing 
patterns towards further selectivity. 

The  flexibilities  introduced  by  the  discard  plans are  necessary  for  the  industry,  including  in 
the context of mixed fisheries. While some discards can be beneficial for the stocks (MS have 
put great effort into providing scientific knowledge on survivability of fish caught in different 
gears),  others  cannot  be  avoided  when  selectivity  cannot  be  increased  or  that  a  full 
implementation of landing obligation leads to disproportionate costs (de minimis exemptions). 

Requesting derogations from the landing obligation or technical measures requires extensive 
work  by  national  administrations,  but  these  exemptions  and  derogations  provide  necessary 
practical  flexibility  for  fishermen  to  mitigate  challenges,  while  continuing  trying  to  further 
develop more selective gears.  

However,  how  the  MAP  has  contributed  to  the  elimination  is  unclear.  The  provision  for 
FMSY  ranges  included  in  the  MAP  provides  some  scope  to  reconcile  different  fishing 
opportunities in mixed fisheries and reduce discards. However, there are few, if any examples 
of  where  the  full  MSY  ranges  have  been  used  with  the  objective  of  reducing  discards  in 
North-western Waters.    

Since  the  inception  of  the  landing  obligation,  choke  species  have  been  considered  as  the 
biggest  risk  to  the  viability  of  the  fishing  industry  in  particular  in  mixed  fisheries.  The 
Council  has  regard  for  unavoidable  by-catches  in  mixed  fisheries,  using  the  flexibility 
provided  for  in  the  WWMAP  when  setting  TACs  and  this  has  contributed  to  limit  the 
incidence  of  choke  situations  to  date  in  most  cases.  Given  the  predominance  of  mixed 
fisheries,  there  is  a  constant  concern  that  choke  situations  will  develop,  closing  critically 
important  commercial  fisheries  (for  example  influence  of  –77%  reduction  TAC  for  PLE  in 
ICES area 7fg for some fisheries).   

Since  2020,  the  fishing  sector  has  been  impacted  by  several  significant  economic  shocks  – 
Covid, Brexit and the conflict in Ukraine. Any economicsocioeconomic impacts observed are 
almost certainly attributable to these factors rather than the landing obligation.  For instance, 
the  Trade  and  Cooperation  Agreement  between  the  EU  and  UK  has  resulted  in  significant 
transfers of quota to the UK as part of this Agreement. These quota transfers have put added 
pressure on the economic viability of certain fleets from 2021 onwards and will continue to do 
so up until 2025.  

From  a  socio-economic  perspective,  it  is  also  vital  to  ensure  a  smooth  process  for 
development of more selective gears that decrease unwanted catch as much as possible while 

55 

 
 
 
keeping  the  Catch  per  Unit  of  Effort  (CPUE)  for  the  wanted  part  of  the  catch  as  high  as 
possible. 

An  evaluation  of  the  landing  obligation,  which  also  looks  at  possible  alternatives  that  are 
more  workable  and  therefore  contribute  better  to  the  policy  objectives  of  the  landing 
obligation, is therefore desirable. 

On the ecosystem-based approach to fisheries management, in your opinion:  

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved?  

In  general,  implementation  of  the  Ecosystem-based  approach  across  fisheries  in  wwestern 
waters has been limited and it is unclear whether  GEGood Environmental Status (GES) has 
been achieved by 2020 in North-western waters. The WWMAP was introduced in 2019 and 
according to ICES there has been a trend of declining fishing mortality since the mid-1990s 
for  the  benthic  and  demersal  stocks  with  known  stock  status.  The  average  F/FMSY  ratio  is 
below 1 for assessed benthic stocks and just above for the assessed demersal stocks. The trend 
for  stock  size  in  assessed  benthic  and  demersal  stocks  has  been  increasing  over  the  same 
period.  The  average  F/FMSY  ratio  is  below  1  for  the  crustacean  stocks,  and  the  average 
biomass has been above 1 in the past decade. The average F/FMSY ratio for pelagic assessed 
stocks has been above 1 in recent years, and the average stock size indicator is declining in 
recent years but remains above MSY Btrigger.   

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach?  

Article  3(3)  of  the  WWMAP  sets  out  one  of  the  objectives  of  the  plan  is  to  implement  the 
ecosystem-based approach to  fisheries management  in  order to  ensure that negative impacts 
of fishing activities on the marine ecosystem are zminimized. However, the plan contains few 
specific measures associated with the ecosystem-based approach, other than the measures to 
set FFishing Opportunities in accordance with the CFP.   

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks?  

See question 1.  

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned?  

Currently, the fisheries sector in all Member States are facing challenges from the economic 
impacts of ovidCovid, Brexit, high fuel prices as well as increased logistics costs and higher 
prices  for  equipment  due  to  the  conflict  in  Ukraine.   This  combination  of  external  drivers 
the  ecosystem-based 
to  focus  on 
makes 
approach. Therefore, at this stage, we have not yet seen the full impact.  

it  difficult  for  fishermen 

implementing 

56 

 
 
 
In  your  opinion,  to  what  extent  has  the  MAP  strengthened regional  cooperation  on the 
proposal  of conservation  measures through  the  submission  of  joint  recommendations, 
including with stakeholders?  

This regulation provides a legal basis for adopting the discard plans, which is the topic that 
mainly occupied MS groups when they developed their joint work. In that regard, the MAP 
contributes to the “bottom-up” approach promoted by the CFP.   

Regional  groups  then  progressively  explored  other  topics,  such  as  technical  measures. 
However,  the  specific  impact  of  the  MAP  in  that  regard  is  unclear  since  the  number  of 
regionally  specific  measures  that  have  put  in  place  under  the  WWMAP  have  been  limited. 
This is partially due to the relationship between a article 9 of the WWMAP and a article 15 of 
the  tm’r.technical  measures’  regulation  (Reg.  2019/2041),  as  well  as  articles  8  (fish  stock 
recovery areas) and a article 11 (ecosystem measure) of the CFP. 

The  WWMAP  does  allow  for  the  development  of  regional  management  measures  but  the 
process to adopt such measures remains complex and is lengthy.  

While  it  cannot  be  directly  attributed  to  the  MAP  itself,  the  governance  structure  is  unduly 
complex and cumbersome, in particular in the process of renegotiating the exemptions to LO 
every year. When possible, this should be simplified going forward to increase the utility of 
the MAP.  

However, based on the experiences of regionalisation thus far, as well as the changes to the 
decision-making  process  arising  from  the  UK’s  departure  from  the  EU,  a  review  of 
regionalisation is required to reinvigorate and realign to the new reality that now pertains. the 
new  decision-making  process  in  operation  following  from  the  Trade  and  Cooperation 
Agreement (TCA) between the EU and the UK, whereby the negotiations are carried out by 
the Commission and the UK create challenges for the NWW Member States Group. 

The  ability  of  the  Group  to  agree  joint  recommendations  now  develops  in  a  smaller 
geographical area, as there is no certainty or obligation on the UK to agree such measures.  

A new governance equilibrium is needed to clarify the articulation between MS group and the 
work  conducted  within  the  SCF,  both  for  the  coherence  of  management  considerations  and 
the  need  to  preserve  a  level  playing  field  tbenefitting  to  EU  fleets.  In  any  case,  this  new 
governance needs to allow Member States at regional level to feed effectively into the EU/UK 
negotiations  organised  at  EU  level  by  the  Commission.  Discussions  both  at  DG  MARE 
technical meeting with MS and at MS Group level may be one option, provided that sufficient 
human  and  technical  resource  is  provided  in  this  respect,  and  without  prejudice  to  MS 
individual positions in the bilateral EU – UK fisheries negotiations.  

Regarding  stakeholders,  the  MAP  only  provides  that  ACs  may  recommend  to  the 
Commission a management approach that seeks to limit year-to-year variations in the fishing 
opportunities  for  a  particular  stock  listed  in  Article  1(1).  Such  advice  may  be  taken  into 
account by the Council when fixing fishing opportunities.  

57 

 
 
 
Are  there  any additional  measures that  would  contribute  to  the  faster  achievement  of  the 
objectives provided for in Article 3 of the MAP?  

The main changes needed to the WWMAP are in relation to the governance structures, which 
are complex and have become heavier since Brexit and need to be articulated 

Some thought should therefore be given on how to update the MAP if necessary.  

58 

 
 
 
 
 
9.10. 

North Western Waters Advisory Council 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On the ecosystem-based approach to fisheries management, in your opinion: 

59 

 
 
 
 
 
 
1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

60 

 
 
 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

The  NWWAC  recognises and  welcomes  the long-term  progress made  overall  towards  more  sustainable 
EU fisheries reflected in the Commission’s Communication COM(2022)253. This is especially true in the 
Northeast Atlantic EU waters, where “thanks to the efforts made by the sector, in 2020 the overall fishing 
mortality ratio fell below 1 for the first time” . Overall, the NWWAC notes that for all the NWW stocks 
the FMSY has been the reference for setting TACs & quotas. 

By defining ranges of fishing mortality based on the best available scientific advice, the Western Waters 
Multi-Annual Plan (WW MAP) allows a certain flexibility in setting fishing opportunities. However, the 
NWWAC notes that the FMSY ranges provided by the MAP have not been put into use in TAC & quota 
setting for NWW stocks. 

Moreover, ICES has not been requested to assess under which conditions Article 4.5 a and b could apply, 
regarding  the  setting  of  fishing  opportunities  for  a  stock  in  accordance  with  the  upper  range  of  FMSY 
available. 

The NWWAC agrees that while the NWW MAP can help clarify how MSY is to be implemented as a 
management objective, the list of targeted stocks included in the plan is too rigid and with no clear criteria 
on  what  constitutes  a  target  stock.  A  clear  example  in  the  NWW  is  pollack  in  area  7,  which  is  not  a 
targeted species and for which scientific information is insufficient to provide MSY advice. 

Another limitation of the MAP is the lack of measures to be taken when a stock falls below Blim, other 
than  following  the  ICES  advice  for  zero  catch.  This  needs  to  be  addressed  urgently  through  the 
development of rebuilding plans with clear targets and timeframes for stocks below Blim based on best 
available scientific advice. 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

61 

 
 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

With the full implementation of the landing obligation, significant progress has been made in advancing the 
understanding  of  chokes,  and  several  measures  have  been  identified,  including  technical  gear  modifications 
and  avoidance  measures informed  by  advanced  knowledge  on  the  spatial  distributions  of  choke  species  and 
unwanted catches. 

However,  avoiding  choke  issues,  and  thus  a  premature  closing  of  a  fishery,  remains  one  of  the  biggest 
challenges  in  the  mixed  and  dynamic  NWW  fisheries.  This  is  explained  in  detail  in  the  NWWAC  advice 
“Addressing choke risk in the NWW after exemptions” submitted on 9 December 2022. As mentioned in the 
advice, it remains clear that the implementation of the CFP in a mixed fisheries context requires creative and 
innovative solutions involving spatial management, technical measures, and in some cases balancing short- and 
long-term socio-economic trade-offs. 

In this regard, the NWWAC welcomes the focus on avoidance of unwanted catches characterising Article 3.2 
of  the  WW  MAP.  Indeed,  frequently  the  AC  has  stipulated  that  avoidance  and  minimisation  of  unwanted 
catches are baseline tools to achieve the selectivity objective. For this reason, it is important to emphasise the 
role  of  Article  14  of  the  CFP,  whereby  Member  States  may  conduct  pilot  projects  with  the  aim  of  fully 
exploring  all  practicable  methods  for  the  avoidance, minimisation  and  elimination  of  unwanted  catches in a 
fishery. This has incentivized research on more selective fishing methods and promoted the prioritization of 
measures which minimise the amount of unwanted catches, ensuring survivability of fish escaping the net. 

The  NWWAC  believes  that,  in  order  to  improve  the  practical  implementation  of  the  landing  obligation, 
avoidance  and  minimisation  of  unwanted  catches  should  be  better  incentivised  and  that  more  achievable 
objectives should be fixed, recognising stocks and individual fisheries’ peculiarities. 

The  NWWAC  acknowledges  that  the  flexibility  in  TAC  setting  afforded  by  the  implementation  of  FMSY 
ranges  would  represent  a  relevant  element  in  the  implementation  of  the  landing  obligation.  However,  it  is 
important  to  take  into  account  the  implications  of  using  FMSY  ranges  provided  for  by  the  WW  MAP  in  a 
mixed fisheries context. The additional flexibility provided by these ranges for a stock may be constrained by 
other, more limiting stocks. Indeed, it is already apparent that the zero-catch advice for several stocks continues 
to pose significant challenges this year 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

62 

 
 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

Article  3.3  of  the  WW  MAP  states  that  “The  plan  shall  implement  the  ecosystem-based  approach  to 
fisheries  management  in  order  to  ensure  that  negative  impacts  of  fishing  activities  on  the  marine 
ecosystem are minimized”. NWWAC members believe that MAPs could be an opportunity to allow for 
ecosystem-based measures  to  be implemented at the scale  of a  regional  basin. However, two  important 
aspects need to be considered: 

1) 

The concept of ecosystem-based approach to fisheries management embeds all three pillars of 
sustainability - environment, social responsibility, and economic – and this should be accounted for 
in the MAPs. Indeed, according to the Food and Agriculture Organisation of the United Nations, 
“the purpose of an ecosystem approach to fisheries is to plan, develop and manage fisheries in a 
manner that addresses the multiple needs and desires of societies, without jeopardizing the options 
for future generations to benefit from the full range of goods and services provided by marine 
ecosystems” . In order to effectively implement the CFP, the NWWAC believes that the socio-
economic dimension of the policy should be strengthened and wishes to point out the importance of 
CFP article 2.1, which at all times should be taken into account when vetting any management 
measure. 

2)  When considering the impacts on the marine ecosystem, the MAP should not only take into 

consideration fishing pressure on fish stocks but adopt a holistic approach considering impacts from 
all the pressures on the marine environment (climate change, pollution and other anthropogenic 
impacts). 

The  need  for  more  flexibility  in  the  implementation  of  the  WW  MAP  is  also  justified  to  ensure  an 
adaptive management of NWW fisheries, which are highly dynamic and currently subject to ecosystem 
changes  which  can  result  in  distributional  shifts  in  fish  species.  Changes  in  stock  biology  and  natural 
phenomena,  such  as  recruitment  pulses  prevalent  in  gadoid  species,  may  create  choke  situations  not 
originally forecast. In light of this, modifications to the targeted species list should be allowed with clear 
conditions and criteria establishing why a stock should be listed as a target species. This approach would 
allow  accounting  for  not  only  the  impacts  of  environmental  variables,  and  thus  make  fisheries 
management  more  resilient  and  adaptive  to  climate  change,  but  also  for  changes  in  food  production 
requirements. 

Furthermore,  the  NWWAC  notes  the  importance  of  implementing  FMSY  ranges  if  scientific  advisory 
bodies  are  to  integrate  the  ecosystem  indicators  to  adjust  the  target  fishing  mortality,  for  example  as 
suggested by ICES WKIRISH 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

63 

 
 
 
very beneficial, beneficial, neutral, negative, very negative, no opinion 

The NWWAC recognises the role of the WW MAP in providing the framework for Member States 
having a direct interest in the NWW to cooperate among themselves at the level of the regional sea 
basin  through  the  submission  of  joint  recommendations.  Accordingly,  the  NWWAC  regularly 
provides advice on joint recommendations produced by the NWW MS Group on technical measures 
and discard plans in the NWW. In this regard, the NWWAC emphasises the continued need for good 
communication  and  recommends  strengthening  collaboration  between  the  Member  States  and  the 
AC. 

The scope of the WW MAP is very wide covering a large area encompassing North Western Waters, 
South  Western  Waters  and  CECAF  zones  around  Madeira  and  the  Canary  Islands.  These  areas 
include a wide range of diverse fisheries and cover most of the demersal stocks and deep-sea stocks. 
By  combining  the  areas  and  stocks  into  one  plan,  it  moves  away  from  the  regional  definitions 
included in Article 4 paragraph 2 of the Basic Regulation (i.e. there is no differentiation between the 
NWW and SWW). It also does not acknowledge the differences in the stocks and fisheries considered 
by  the  NWWAC  and  SWWAC.  Furthermore,  the  NWWAC  notes  there  are  overlaps  for  several 
stocks included in this plan with the North Sea MAP. For instance, megrim in divisions 4a and 6 and 
hake in subareas 4, 6, and 7 are included in the WW MAP, whilst other stocks such as haddock and 
saithe in divisions 4 and 6a, as well as Anglerfish in subareas 4 and 6 are included in the NSMAP. 
This  overlapping  creates  management  difficulties  and  complicates  regional  cooperation,  while 
MAPs’ scopes should coincide with the regional structure established in the CFP. 

The  NWWAC  also  wishes  to  point  out  that  its  remit  area  includes  four  different  subregions,  each 
with specific characteristics, issues and needs in terms of fisheries management, ecosystem dynamics 
and  socio-  economic  aspects.  Having  different  MAPs  for  West  of  Scotland,  Irish  Sea,  English 
Channel and Celtic Sea could be a further step in the regionalisation approach strengthening fisheries 
management. 

64 

 
 
 
 
 
 
Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

In  relation  to  Article  3.4  a  and  b,  the  NWWAC  refers  to  its  joint  advice  with  the  North  Sea 
Advisory  Council  on  the  MSFD  review  from  22  March  2022,  which  contains  recommendations 
aiming  at  ensuring  that  the  MSFD  descriptors  are  measurable  and  regionally  coherent  in  their 
progress  towards  GES,  that  measures  are  effective  and  their  impact  quantified,  and  coordination 
within and across marine regions improved. 

Regarding Article 3.5, the NWWAC invites the Commission to reflect on the definition and criteria 
of  “best  available  scientific  advice”,  to  ensure  this  provides  the  most  accurate  stock  assessment. 
The NWWAC also recommends following the developments of the application of the Management 
Strategy  Evaluation,  which  is  becoming  an  increasingly  popular  tool  for  developing,  testing,  and 
implementing fisheries management regimes, utilizing participatory modelling. 

Letter from NWWAC to DG MARE C Director 

Dear Mr Donatella, 

Subject: Targeted consultation on the MMultiannual Plans for the North Sea and the Western 
Waters 

The North Western Waters Advisory Council (NWWAC) welcomes the letter received on 18 
January 2023 consulting AC members on their assessment of the Western Waters 
MMultiannual Plan (WW MAP) performance in meeting its objectives and identifying any 
weaknesses that undermine its effectiveness. 

Following instructions, the NWWAC has provided its response to the targeted online survey. 
However, members felt that an official reply to your letter should also be submitted, allowing 
for reflection on a number of overarching aspects setting the context for the questionnaire 
exercise. The response to the online survey is also attached to this communication for 
completeness of information. 

The NWWAC agrees with the principle that MAPs should offer a legislative basis to manage 
certain fisheries targeted by the plan (mainly the most important ones commercially) in a 
dedicated sea basin in the long term. Management measures include mainly MSY ranges, 
implementation of the landing obligation and technical measures. For the NWWAC, the 
added value of the MAPs would be to provide regional long-term ecosystem-based 
management of those fisheries that allow for stability, visibility and flexibility for the 
stakeholders concerned. Whereas that is a very virtuous principle, it seems that, in practice, 
the full ambition of the Western Waters MAP is not achieved. Focus appears to be TACs & 
quotas management and on delegated acts for the implementation of the Landing Obligation. 

65 

 
 
 
 
 
As the NWWAC agrees with the principle of the MAPs, we recommend investigating how to 
use their full potential. 

Another important aspect to consider relates to the post-Brexit landscape, which cannot be 
ignored when reflecting on the effectiveness of the WW MAP. As a consequence of Brexit, 
the dynamics in terms of achieving sustainable fishing have inevitably changed. EU-UK 
bilateral consultations have become a key step towards setting FFishing Opportunities for the 
75 shared fish stocks, whose majority are in the North Western Waters. It is also important to 
note that the UK has not transposed the MAP nor the MSY objective in its national 
regulations. Thus, it would be desirable to consider measures in the MAP evaluation which 
integrate EU and UK fisheries management. Therefore, the NWWAC wishes to point out that 
the reporting exercise on the implementation of the WW MAP should not be done in isolation 
but should take the Trade and Cooperation Agreement into account. 

A final point relates to the consultation process for this reporting exercise. The NWWAC 
would like to point out that this exercise relates to complex matters, as demonstrated by the 
questions included in the survey, and thus requires time and focus to be properly addressed. 
The AC would like to recall that all its advice aims to make submissions that are based on 
consensus. To reach this, all AC members need to be consulted in a thorough and appropriate 
manner, which takes time. Therefore, the NWWAC would appreciate to be given more time 
for considerations, especially of complex issues such as this. 

Thank you for your attention on this matter. We remain at your disposal to further elaborate 
on this exercise should this be necessary. 

Yours sincerely, 

NWWAC  

66 

 
 
 
 
 
9.11. 

 Member of STECF 

Member of the Scientific, Technical and Economic Committee for Fisheries 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Beneficial 

2. Very Beneficial 

3. Beneficial 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Neutral 

2. Neutral 

3. Neutral 

4. Beneficial 

67 

 
 
 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Beneficial 

2. Neutral 

3. Neutral 

4. No opinion 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

Very beneficial 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Beneficial 

68 

 
 
 
 
 
 
 
 
 
Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Beneficial 

2. Beneficial 

3. Neutral 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Negative 

2. Beneficial 

3. Negative 

4. Beneficial 

69 

 
 
 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. Negative 

2. Neutral 

3. Neutral 

4. Negative 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

Very beneficial 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

Beneficial 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

70 

 
 
 
 
 
 
 
 
 
9.12. 

Member of STECF 

Member of the Scientific, Technical and Economic Committee for Fisheries 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. beneficial, the importance of following the MSY advice in setting the final TAC has increased. 

2. beneficial when in the context of mixed fisheries all stocks are fished at MSY. 

3. neutral, generally the Fmsy value and not the ranges is the objective for setting the final TAC in the most 

recent years. 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. negative. 

2. negative. The procedure of adopting delegated acts is in many cases essential to avoid closure of the 

71 

fisheries. 

3. negative. 

4. neutral. 

 
 
 
 
 
On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. neutral 

2. neutral 

3. neutral 

4. neutral 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

beneficial 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Multispecies/ecosystem based advice 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

72 

 
 
 
 
 
 
 
2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. beneficial, the importance of following the MSY advice in setting the final TAC has increased. 

2. beneficial when in the context of mixed fisheries all stocks are fished at MSY. 

3. neutral, generally the Fmsy value and not the ranges is the objective for setting the final TAC in the most 

recent years. 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. negative. 

2. negative. The procedure of adopting delegated acts is in many cases essential to avoid closure of the 

fisheries. 

3. negative. 

4. neutral. 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

73 

 
 
 
 
 
2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1. neutral 

2. neutral 

3. neutral 

4. neutral 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

beneficial 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Multispecies //ecosystem based advice 

9.13. 

SWWAC 

Avis 163 : Consultation sur le plan de gestion des eaux occidentales 

Par cet avis, les membres du secteur du CC SUD (France, Espagne, Portugal) ont souhaité 
prendre part à la consultation de la Commission européenne sur le plan de gestion des Eaux 
Occidentales (règlement (UE) 2019/472), ils travaillent en effet depuis la création, et même 
depuis sa préparation (Avis 98, 103, 120 de 2015 à 2018), à sa bonne mise en œuvre (Avis 
134 en 2019), et notamment concernant la mise en place de mesures de long terme pour les 
stocks du golfe de Gascogne et des eaux ibériques permise par son article 6 (Avis 153 en 
2021). 

74 

 
 
 
 
 
 
Les membres du CCSUD considèrent que l’adoption de cet outil législatif a permis d’ouvrir 
de nombreux débats et possibilités de gestion pour les pêcheries mixtes de ses eaux de 
compétences, cependant la désillusion quatre années après est grande. C’est ce paradoxe qui 
est détaillé ci-après par les membres du secteur du CCSUD. Les membres des ONG 
environnementales ayant préféré répondre individuellement à la consultation en ligne. 

A.  Possibilité de pêche, RMD et fourchettes de captures. 

Le plan de gestion des eaux occidentales s’est appuyé sur la possibilité d’utiliser des 
fourchettes de captures autour du RMD (Art. 4), afin de prendre en considération la 
complexité de gestion des pêcheries mixtes, particulièrement présentes dans les eaux 
occidentales sud. Toutefois, 'l'objectif politique du RMD s’est traduit de manière trop 
précautionneuse, en actant que la fixation des possibilités de pêche ne pouvait dépasser, sauf 
rares et insuffisamment mises en œuvre exceptions, la valeur du TAC associée à Frmd 
médian, pour tous les stocks. Ce choix politique devrait utilement être corrigé afin que les 
possibilités de pêche soient à l’avenir fixées au sein d’ une « fourchette » de valeurs de F 
permettant la bonne gestion globale des pêcherie du point de vue des écosystèmes et socio-
économiques. Le CIEM propose ainsi des scénarios avec des probabilités d’au moins 95% 
d’atteindre le RMD, offrant ainsi de très larges marges de manœuvre pour faire évoluer la 
gestion des pêcheries dans une zone RMD, tout en y intégrant les enjeux socio-économiques. 
Cette intégration des aspects socio-économique étant essentielle dans les eaux occidentales 
sud, comme mentionné à plusieurs reprises par le CC SUD, notamment dans son avis 153. 

Cependant, le constat est que ces possibilités n’ont pas été saisies par la Commission 
Européenne dans ses propositions annuelles, qui se concentrent toujours uniquement sur les 
aspects halieutiques de manière mono-spécifique, avec un respect strict des avis du CIEM. En 
effet, le plan de gestion (Art.4, 7, 8) contraint les décisions. Il n’est plus possible pour les 
décideurs de s’en écarter, quand bien même les avis présenteraient des problèmes 
méthodologiques (benchmark trop ancien dans le temps, absence de campagne, données 
manquantes..). De même, il n’autorise pas ou très difficilement de logiques pluri-annuelles. 
Les interprétations juridiques de l’Article 8, ont de plus imposé des contraintes de gestion 
inimaginables (chalut décollé pour le cabillaud VII, -37% pour la sole VIII). Le plan n’a donc 
pas permis, ou trop peu, de tenir compte des enjeux socio-économiques, dans la fixation des 
possibilités de pêche. 

B.  Obligation de débarquement et rejets 

Si les membres du CCSUD estiment que l’obligation de débarquement a permis, à sa mise en 
place, de lancer de nombreux programmes pour améliorer la sélectivité et réduire les prises 
non désirées, ce qui s’est donc avéré positif. Il est cependant noté que cette norme ne prend ni 
en compte les impacts socio-économiques, ni la réalité des pêcheries : son impact sur 
certaines flottilles a alors été disproportionné. 

En effet, l’obligation de débarquement a affecté l’ensemble des pêcheries quel que soit leur 
niveau de sélectivité, cette obligation ne tenant pas compte des quotas attribués à chaque État, 

75 

 
 
 
a entrainé des situations d’étranglement, les exemptions à l’obligation de débarquement 
devenant alors essentielles pour ne pas dégrader les exploitations. C’est le cas par exemple 
des palangriers par exemple, dans la flotte espagnole avec du cabillaud ou du merlan. 

De même, l’application du plan de gestion n’a que très peu tenu compte de la dimension 
multi-spécifique des principales flottilles évoluant dans le territoire du CC Sud, au moment de 
déterminer les possibilités de pêche. Les membres de l’industrie du CC Sud recommandent de 
mettre en œuvre l’article 4.5.a dans cette perspective, et qu’ainsi, les travaux du CIEM 
nécessaires soient développés. L’obligation de débarquement est donc devenue un objectif en 
soi et non plus un moyen d’amélioration de la sélectivité, elle réduit la visibilité de certaines 
pêcheries avec des impacts socio-économiques négatifs sans avoir de plus-value pour la 
ressource car certaines captures restent inévitables. Dans le contexte actuel, la mise en œuvre 
de l’obligation de débarquement est donc devenue négative. 

C.  Approche écosystémique 

Alors même que la plupart des stocks des eaux occidentales sont dans une situation optimale, 
l’approche écosystémique n’a été que très partiellement utilisée, notamment par manque de 
connaissances et de données sur les différentes pressions anthropiques, et leur hiérarchisation 
rationnelle. Aujourd’hui, on se contente donc de faire de la pression de pêche la variable 
d’ajustement pour maintenir (à court terme) une exploitation au RMD sans agir suffisamment 
sur les autres causes de dégradation des écosystèmes. Cette situation ne peut pas donner de la 
visibilité aux acteurs socio-économiques des pêcheries, pourtant conscients de la nécessité de 
maintenir ou restaurer un bon état écologique du milieu. 

Les membres du CC SUD recommandent donc : 

- 

  D’améliorer les connaissances sur l’ensemble des facteurs anthropiques (dont 
les effets sont par ailleurs affectés par le changement climatique qui s’opère) 
impactant les zones fonctionnelles halieutiques. 

-  D’utiliser pleinement les dispositions du plan de gestion, en demandant au CIEM 

les expertises scientifiques nécessaires à l’application de l’article 4.5.b. 

-  De hiérarchiser l’impact des différents facteurs anthropiques sur le renouvellement 

des ressources et le maintien ou la restauration d’un bon état écologique ; 

- 

Sur la base de ces connaissances, de réduire l’impact de l’ensemble des facteurs 
anthropiques ayant une responsabilité majeure dans le renouvellement des 
ressources et le maintien ou la restauration d’un bon état écologique en général ; 

-  De permettre le cas échéant le maintien d’un minimum d’exploitation (minima 

socio- économique à définir) lorsque l’impact du facteur pêche est reconnu comme 
mineur dans le renouvellement de la ressource ou dans le maintien/restauration du 
bon état écologique 

76 

 
 
 
D.  Coopération régionale 

Malgré son adoption tardive, le plan de gestion a favorisé la coopération régionale selon les 
membres du CC SUD, permettant d’ouvrir de nombreux sujets et débats, notamment au sein 
des conseils consultatifs, comme le révèle le nombre d’avis et de réunions du CC SUD dédié à 
ce sujet. Cependant comme démontré précédemment ces débats non que peu aboutis à des 
mesures concrètes, suffisamment étayées scientifiquement pour être retenues par la 
Commission européenne face aux rigidités réglementaires. 

E.  Propositions de mesures supplémentaires pour atteindre les objectifs 

'L'atteinte des objectifs ne peut être accélérée sans analyser la situation mondiale actuelle et 
les répercussions que 'd'autres politiques ont sur 'l'espace maritime et le secteur de la pêche. 
La poursuite de l’amélioration des connaissances scientifiques est primordiale et nécessaire 
pour la mise en place effective de l’approche écosystémique. Mais aussi pour éviter 
l’utilisation, parfois abusive, de l’approche de précaution, préjudiciant grandement les 
exploitations par manque de données et non pas par une dégradation du stock (par exemple le 
merlu du sud - HKE/8C3411). 

Conclusion 

Selon les membres du secteur du CC SUD, les opportunités offertes par le plan de gestion des 
eaux occidentales sud n’ont pas été saisies. D’un côté, son application a principalement porté 
sur la fixation des possibilités de pêche, de manière trop précautionneuse, et sans prise en 
compte des impacts socio-économiques ou de la dimension multi-spécifique des captures. De 
l’autre, il n’a pas permis la mise d’une réelle approche écosystémique limitant efficacement 
l’ensemble des impacts anthropiques ou facilité l’obligation de débarquement qui n’a eu 
qu’un effet très limité sur l’amélioration de la sélectivité. Il n’a enfin pas permis non plus 
d’améliorer la durabilité socio-économique des entreprises de pêche en mettant en place des 
mesures de long terme. 

Les membres du secteur du CC SUD considèrent que tant que la gestion des pêches restera 
basée uniquement sur des critères halieutiques annuels et mono-spécifiques, elle ne permettra 
pas d’évolutions majeures pour faire face aux défis à venir. 

Dictamen 163: Consulta sobre el Plan de Gestión de las Aguas Occidentales 

Con este dictamen, los miembros del sector del CCSUR (Francia, España, Portugal) han 
querido participar en la consulta de la Comisión Europea sobre el plan de gestión de las 
Aguas Occidentales (Reglamento (UE) 2019/472), e incluso desde su elaboración 
(Dictámenes 98, 103, 120 de 2015 a 2018), a su correcta aplicación (Dictamen 134 en 2019), 
y, en particular, en lo relativo a la aplicación de medidas a largo plazo para las poblaciones 
del Golfo de Vizcaya y aguas ibéricas que permite su artículo 6 (Dictamen 153 en 2021). 

Los miembros de la CCSUR consideran que la adopción de esta herramienta legislativa ha 
abierto muchos debates y posibilidades de gestión para las pesquerías mixtas en sus aguas 

77 

 
 
 
jurisdiccionales. Sin embargo, cuatro años después hay mucha desilusión. Esta paradoja es la 
que detallan a continuación los miembros del sector CCSUR. Los miembros de las ONG 
ecologistas prefirieron responder individualmente a la consulta en línea. 

A.  Posibilidades de pesca, RMS e intervalos de capturas. 

El plan de gestión de las aguas occidentales se ha basado en la posibilidad de utilizar 
intervalos de capturas en torno al RMS (art. 4), con el objetivo de tener en cuenta la 
complejidad de la gestión de las pesquerías mixtas, especialmente presentes en las aguas 
suroccidentales. Sin embargo, el objetivo político del RMS se ha traducido de manera 
demasiada cautelosa, mencionando que la fijación de las posibilidades de pesca no podía ir, 
salvo raras y insuficientes instauraciones de exenciones, más allá, el valor del TAC asociado a 
Frms mediano, para todas las poblaciones. Esta opción política tendría que corregirse de 
manera útil para que, en el futuro, las posibilidades de pesca se fijen dentro de un «intervalo» 
de valores de F, permitiendo la buena gestión global de una pesquería, desde un punto de vista 
ecosistémico y socioeconómico. 

Así pues, el CIEM propone situaciones con una probabilidad de al menos el 95% de alcanzar 
el RMS, lo que ofrece márgenes de maniobra muy amplios para desarrollar la gestión de la 
pesca en una zona de RMS, integrando al mismo tiempo las cuestiones socioeconómicas. Esta 
integración de los aspectos socioeconómicos es esencial en las aguas suroccidentales, como 
ha mencionado en varias ocasiones el CCSUR, especialmente en su Dictamen 153. 

Sin embargo, es evidente que la Comisión Europea no ha recogido estas opciones en sus 
propuestas anuales, que siempre se centran únicamente en los aspectos pesqueros de manera 
mono especifica, con estricto cumplimiento de los dictámenes del CIEM. 

De hecho, el plan de gestión (Art. 4, 7, 8) condiciona las decisiones. Ya no es posible que los 
responsables de la toma de decisiones se desvíen de ella, incluso si los dictámenes presenten 
problemas metodológicos (referencias demasiado antiguas en el tiempo, ausencia de campaña, 
falta de datos, etc.). Asimismo, no permite, o solo con gran dificultad, lógicas plurianuales. 
Además, las interpretaciones jurídicas del artículo 8 han impuesto limitaciones de gestión 
inimaginables (arrastre relevado para el bacalao VII, -37% para el lenguado VIII). El plan no 
ha permitido tener en cuenta las cuestiones socioeconómicas, o no lo suficiente, a la hora de 
fijar las posibilidades de pesca. 

B.  Obligación de desembarque y descartes 

Los miembros de la CCSUR consideran que la obligación de desembarque, cuando se puso en 
marcha, dio lugar numerosos programas para mejorar la capacidad de selección y reducir las 
capturas no deseadas, algo que ha sido positivo. Sin embargo, se observa que esta norma no 
ha tenido en cuenta ni las repercusiones socioeconómicas ni la realidad de las pesquerías: su 
impacto en determinadas flotas ha sido, por lo tanto, desproporcionado. 

De hecho, la obligación de desembarque ha afectado a todas las pesquerías, 
independientemente de su nivel de selectividad. Esta obligación no tiene en cuenta las cuotas 

78 

 
 
 
asignadas a cada Estado y ha provocado situaciones de estrangulamiento, haciendo 
imprescindibles las exenciones de la obligación de desembarque para no degradar las 
operaciones. Es el caso, por ejemplo, de los palangreros de la flota española con el bacalao o 
el merlán. 

Del mismo modo, la aplicación del plan de gestión solo ha tenido poco en cuenta la dimensión 
multi-especifica de las principales flotillas que faenan en el territorio del CC SUR, en el 
momento de determinar las posibilidades de pesca. Los miembros de la industria del CC SUR, 
recomiendan la instauración de artículo 4.5.a en esta perspectiva, y también que se desarrollen 
trabajos necesarios del CIEM. 

Determinadas capturas siguen siendo inevitables. La obligación de desembarque se ha 
convertido, así, en un objetivo en sí mismo y ha dejado de ser un medio para mejorar la 
selectividad, reduciendo la visibilidad de determinadas pesquerías, a las que le supone 
repercusiones socioeconómicas negativas, sin tener ningún valor añadido para el recurso. En 
el contexto actual, la aplicación de esta obligación se ha vuelto, por tanto, negativa. 

C.  Enfoque ecosistémico 

Aunque la mayoría de las poblaciones de aguas occidentales se encuentran en una situación 
óptima, el enfoque ecosistémico solo se ha utilizado de forma parcial, debido, sobre todo, a la 
falta de conocimientos y datos sobre las distintas presiones antropogénicas y su priorización 
racional. Por lo tanto, hoy nos contentamos con hacer de la presión pesquera la variable de 
ajuste para mantener (a corto plazo) la explotación en el RMS, sin tomar medidas suficientes 
sobre las demás causas de degradación del ecosistema. Esta situación no puede dar visibilidad 
a los agentes socioeconómicos de la pesca, que sin embargo son responsables de la necesidad 
de mantener o restaurar un buen estado ecológico del medio ambiente. 

Por consiguiente, los miembros del CCSUR recomiendan: 

-  Mejorar el conocimiento de todos los factores antropogénicos que repercuten en 
las zonas de pesca funcionales (cuyos efectos también se ven afectados por el 
cambio climático). 

-  Utilizar plenamente las disposiciones del plan de gestión, pidiendo al CIEM los 

peritajes científicos necesarios a la aplicación del articulo 4.5.b 

-  Priorizar el impacto de los diversos factores antropogénicos en la renovación de 
los recursos y el mantenimiento o la restauración del buen estado ecológico; 

-  A partir de esta información, reducir el impacto de todos los factores 

antropogénicos que tienen una gran responsabilidad en la renovación de los 
recursos y el mantenimiento o la restauración del buen estado ecológico en 
general; 

79 

 
 
 
-  Permitir, en su caso, el mantenimiento de un nivel mínimo de explotación (mínimo 
socioeconómico por definir) cuando se reconozca que el impacto de la pesca es 
menor en la renovación del recurso o en el mantenimiento/restauración del buen 
estado ecológico. 

D.  Cooperación regional 

A pesar de su tardía adopción, el plan de gestión ha fomentado la cooperación regional según 
los miembros del CCSUR, abriendo numerosos temas y debates, sobre todo en el seno de los 
consejos consultivos, como demuestra el número de dictámenes y reuniones del CCSUR 
dedicados a este tema. Sin embargo, como se ha demostrado anteriormente, estos debates no 
han desembocado en medidas concretas, respaldadas, lo suficiente, por pruebas científicas, 
para que la Comisión Europea las adopte frente a las rigideces normativas. 

E.  Propuestas de medidas adicionales para alcanzar los objetivos 

La consecución de los objetivos no puede acelerarse sin antes analizar la situación global 
actual y el impacto que otras políticas tienen en el espacio marítimo y el sector pesquero. Es 
esencial y necesario seguir mejorando los conocimientos científicos para aplicar eficazmente 
el enfoque ecosistémico. Pero también para evitar el uso, a veces abusivo, del criterio de 
precaución, que perjudica enormemente las explotaciones por falta de datos y no por 
degradación de la población (por ejemplo, merluza austral - HKE/8C3411). 

F.  Conclusión 

Según los miembros del sector del CCSUR, no se han aprovechado las oportunidades que 
ofrece el Plan de Gestión de las Aguas Occidentales. De un lado, su aplicación ha llevado 
principalmente sobre la fijación de las posibilidades de pesca, de manera demasiada cautelosa, 
y sin tomar en consideración de los impactos socio económicos o la dimensión multi 
especifica de las capturas. Por otro lado, no ha permitido la instauración de un verdadero 
enfoque ecosistémico, que limite eficazmente todas las repercusiones antropogénicas, o 
facilitado la obligación de desembarque, que ha tenido un efecto muy limitado en la mejora de 
la selectividad. Tampoco ha permitido mejorar la sostenibilidad socioeconómica de las 
empresas pesqueras mediante la aplicación de medidas a largo plazo. 

Los miembros del sector del CCSUR consideran que mientras la gestión de la pesca siga 
basándose únicamente en criterios pesqueros anuales y mono específicos, no permitirá 
grandes cambios para hacer frente a los retos que se avecinan. 

80 

 
 
 
 
 
9.14. 

Member of the SWWAC 

Member of the South Western Waters Advisory Council 

North Sea MAP 

According to the North Sea MAP, MSY was to be achieved for all relevant stocks by 2020. 
Out of the 11 stocks covered by the MAP, the ICES provides an analytical assessment for 9 
stocks. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values, 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the North Sea, to what extent 

has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

81 

 
 
 
3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conser vation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

Western Waters MAP 

According to the Western Waters MAP, MSY was to be achieved for all relevant stocks by 
2020. In your opinion: 

1.  To what extent has the MAP contributed to increase the number of TACs set at MSY? 

2.  What is the medium to long-term socio-economic impact on the fisheries concerned 

when a TAC is set at MSY? 

3.  What change was brought by the establishment of the target fishing mortality (F) that 
corresponds to the objective of reaching and maintaining MSY as ranges of values 
which are consistent with achieving MSY (FMSY)? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

1 - neutro 

2 - benéfico; 3 - benéfico 

On discards (unwanted catches that are returned to the sea) and the landing obligation 
(Article 15 of the CFP Regulation), in your opinion: 

1.  To what extent discards have been eliminated and the landing obligation has been 

actually implemented? 

2.  To what extent has the MAP contributed to achieving the current situation in terms of 

the elimination of discards and implementation of the landing obligation? More 
specifically, to what extent does the MAP allow taking into account the management 

82 

 
 
 
 
of mixed fisheries – management of by-catch stocks and avoidance of choking 
situations? 

3.  What is the impact of the current situation in terms of the elimination of discards and 

implementation of the landing obligation on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the elimination 
of discards and implementation of the landing obligation on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

benéfico 

On the ecosystem-based approach to fisheries management, in your opinion: 

1.  In general, within the context of fisheries management in the Western Waters, to what 
extent has the objective of implementing an ecosystem-based approach, and notably of 
achieving good environmental status by 2020, been achieved? 

2.  To what extent has the MAP contributed to the current situation in terms of the 

ecosystem-based approach? 

3.  What is the impact of the current situation in terms of the ecosystem-based approach 

on the relevant stocks? 

4.  What is the socio-economic impact of the current situation in terms of the ecosystem-

based approach on the fisheries concerned? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

benéfico 

In your opinion, to what extent has the MAP strengthened regional cooperation on the 
proposal of conservation measures through the submission of joint recommendations, 
including with stakeholders? 

very beneficial, beneficial, neutral, negative, very negative, no opinion 

muito benéfico 

Are there any additional measures that would contribute to the faster achievement of the 
objectives provided for in Article 3 of the MAP? 

83 

 
 
 
 
 
 
 
 
 
 
very beneficial, beneficial, neutral, 
negative

sem opinião 

84 

 
 
 
 
 
 
 
 
10. Glossary 

AC: Advisory Council 

CFP: Common fisheries policy 

CNPMEM: Comité National des Pêches Maritimes et des Élevages Marins 

FMSY: Fishing mortality consistent with maximum sustainable yield 

ICES: International Council for the Exploration of the Sea 

MSG: Member States Group 

MAP: Multiannual plan 

MSY: Maximum sustainable yield 

NWW: North Western Waters 

NWWAC: North Western Waters Advisory Council 

NSAC: North Sea Advisory Council 

SSB: Spawning stock biomass 

STECF: Scientific, Technical and Economic Committee for Fisheries 

SWW: South Western Waters 

SWWAC: South Western Waters Advisory Council 

TAC: Total allowable catch 

85