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COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 12.2.2004 SEC(2004) 179 COMMISSION STAFF WORKING PAPER SCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF) Analysis of derogations and non-conformities of data collection National Programmes for 2004 Brussels, December 2003 This report has been adopted by the Scientific, Technical and Economic Committee for Fisheries (STECF) through a fast track procedure by correspondence.

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  • COMMISSION OF THE EUROPEAN COMMUNITIES

    Brussels, 12.2.2004 SEC(2004) 179

    COMMISSION STAFF WORKING PAPER

    SCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF)

    Analysis of derogations and non-conformities of data collection National Programmes for 2004

    Brussels, December 2003

    This report has been adopted by the Scientific, Technical and Economic Committee for Fisheries (STECF) through a fast track procedure by

    correspondence.

  • 2

    TABLE OF CONTENTS

    1. Introduction ……………..……………………………………..3

    2. STECF opinion …………….……………….………………….3

    3. Appendix 1 SGRN report…………………....……….……..5

  • 3

    1. Introduction STECF was requested to advise on derogations and non-conformities of data collection National Programmes for 2004 and implemented within the framework of the Council Regulation (EC) No1543/2000 and the Commission Regulation (EC) No 1639/2001. In view of this, STECF convened a meeting of its subgroup on research need (SGRN) that met on 1-5 December 2003. STECF evaluated by correspondence the report delivered by the SGRN (see Appendix 1). STECF welcomed the report of SGRN on the evaluation of the National Programme Proposals for 2004, in fulfilment of the requirements of EC Regulation 1639/2001, noting the considerable effort involved and the attention to detail. The SGRN Terms of Reference were as follows:

    1)To evaluate derogation and exceptions requested by Member States within their National Programmes under Council Regulation 1639/2001, in order that STECF could formulate advice on these requests to the Commission. 2) To evaluate the NP proposals with regards to Modules J and K of EC Regulation 1639/2001, and to give guidance on future amendments of Modules J and K of the Regulation.

    The report contains chapters listing the following: A Chapter containing general comments, which apply to most, if not all Modules of the Regulation. Separate Chapters covering individual Module of the Regulation, from Module E (Catch and landings data) to Module K (The processing industry). Each of these contains a sub-section with general comments on that Module of the Regulation, which are then followed by SGRN's country-based replies to the Evaluators' comments.

    2. STECF opinion STECF strongly supports the recommendations of SGRN on the need for international co-operation in relation to (a) surveys, (b) length and age sampling of foreign vessel landings, (c) estimates of the discards, and (d) annual, triennial and six-yearly updates of biological parameters (Chapter 4, paragraph on International co-operation). STECF generally agrees with SGRN's comments and suggestions on the use of the results from pilot studies (Chapter 4, paragraph on Use of results from pilot studies). Instead of having separate expert groups to evaluate the results of these pilot studies and to decide on their follow-up, STECF suggests that this be done by SGRN , together with the evaluation of the annual Technical Reports of the National Data Gathering Programs. This would keep the evaluation process within the STECF framework thereby giving greater credence to the results of the evaluations. STECF shares the concern of SGRN on the extra workload that may be created by seven additional National Program proposals that will be submitted by the new EU Member States from 2004 onwards (Chapter 4, paragraph on Evaluation of NP proposals for 2005 and beyond). STECF notes that the Commission has taken the initiative to organise an informative meeting with representatives from the new Member States to streamline the submission of their National Program proposals.

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    STECF recommends that these initiatives be pursued in close co-operation with SGRN via its Chair. STECF generally agrees with the comments made by SGRN in the introductory sections to the Module-based chapters (Chapters 5-10) and with SGRN's replies to the Evaluators' comments. STECF particularly welcomes the comments on Modules J and K, which it considers to be a valuable contribution to the improvement of the collection of economic data on the fisheries and the fish processing industry. STECF stresses the need to collect CPUE data (Module F) in accordance with the requirements specified by the relevant assessment and advisory body. For example ICCAT specifies that catch and effort for longliners targeting large pelagics should be provided in kg or numbers per 1000 hooks deployed. Furthermore, such requirements should be mandatory under the Member States' minimum programmes. STECF notes that steps will be undertaken to elaborate a long-term structural solution for the Atlanto-Scandian Herring Survey (Section 7.1., paragraph on Atlanto-Scandian Herring Survey). STECF urges the Commission to do so by means of multi-lateral (instead of bi-lateral) negotiations with all Member States concerned. STECF agrees with the criteria proposed by SGRN to evaluate future Tuna Tagging Surveys for their eligibility under the Minimum Program of the Regulation (Section 7.1., paragraph on Tuna tagging). STECF recognises that the criteria used so far were probably too ambiguous, which has led to confusion and to different interpretations by different Member States. STECF shares SGRN's concern on surveys for anadromous and catadromous fish, and suggests that an expert group be convened to advice on this issue. STECF does not agree with the SGRN point in section 8.1 of the report that sampling for fat content for maturity studies for mackerel and horse mackerel be included in the minimum programme. De Oliveira et al (2003)1 investigated the use of proxies for fecundity to improve the management of western horse mackerel, and expressed the need to know clearly the underlying relationships before using proxies for fecundity within a stock assessment. STECF notes that work on fat content is needed and very important but that such studies are not suited to data collection under the minimum programme, particularly when it is of such an exploratory nature. STECF therefore recommends that collection of samples of mackerel and horse mackerel for fat content studies be restricted to the extended programme. Taking into account the above comments, STECF endorses the SGRN report.

    1 De Oliveira et al (2003). Investigating the Use of Proxies for Fecundity to Improve the Management of Western Horse Mackerel. ICES CM 2003/X:13

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    APPENDIX 1

    COMMISSION STAFF WORKING PAPER

    SCIENTIFIC, TECHNICAL AND ECONOMIC COMMITTEE FOR FISHERIES (STECF)

    SUBGROUP ON RESEARCH NEED AND DATA COLLECTION

    (SGRN)

    Analysis of derogations and no-conformities

    of data collection National Programmes for 2004

    Brussels, 01 – 05 December 2003

  • 6

    TABLE OF CONTENTS 1. INTRODUCTION.................................................................................................................................... 9

    1.1. LIST OF PARTICIPANTS....................................................................................................................... 9 2. TERMS OF REFERENCE ..................................................................................................................... 9

    3. EVALUATION PROCESS AND STRUCTURE OF THE REPORT............................................... 10 3.1. EVALUATION PROCESS .................................................................................................................... 10 3.2. UPCOMING REVISION OF REGULATION 1639/2001 AND ITS IMPLICATIONS ON THE EVALUATION PROCESS 10 3.3. STRUCTURE OF THE REPORT ............................................................................................................ 10

    4. GENERAL COMMENTS ..................................................................................................................... 11 4.1. PRECISION LEVELS........................................................................................................................... 11 4.2. INTERNATIONAL CO-OPERATION ..................................................................................................... 11 4.3. USE OF RESULTS FROM PILOT STUDIES............................................................................................. 12 4.4. EVALUATION OF NP PROPOSALS FOR 2005 AND BEYOND ................................................................ 13

    5. CATCH AND LANDINGS DATA: MODULE E................................................................................ 14 5.1. GENERAL COMMENTS...................................................................................................................... 14

    5.1.1 Coverage of catches and landings in other MS and by other flag vessels ................................. 14 5.1.2 Sampling of vessels < 10 m........................................................................................................ 14 5.1.3 Discards..................................................................................................................................... 14 5.1.4 Conversion factors..................................................................................................................... 15 5.1.5 Quality assurance ...................................................................................................................... 15

    5.2. BELGIUM ......................................................................................................................................... 16 5.3. DENMARK ....................................................................................................................................... 17 5.4. FINLAND.......................................................................................................................................... 18 5.5. FRANCE ........................................................................................................................................... 19 5.6. GERMANY ....................................................................................................................................... 20 5.7. GREECE ........................................................................................................................................... 22 5.8. IRELAND.......................................................................................................................................... 22 5.9. ITALY .............................................................................................................................................. 23 5.10. NETHERLANDS ................................................................................................................................ 24 5.11. PORTUGAL....................................................................................................................................... 25 5.12. SPAIN .............................................................................................................................................. 26 5.13. SWEDEN .......................................................................................................................................... 26 5.14. UNITED KINGDOM........................................................................................................................... 27

    6. CATCH PER UNIT EFFORT: MODULE F....................................................................................... 28 6.1. GENERAL COMMENTS...................................................................................................................... 28

    6.1.1 Criteria for MP and EP CPUE data series................................................................................ 28 6.2. BELGIUM ......................................................................................................................................... 29 6.3. DENMARK ....................................................................................................................................... 30 6.4. FINLAND.......................................................................................................................................... 30 6.5. FRANCE ........................................................................................................................................... 30 6.6. GERMANY ....................................................................................................................................... 30 6.7. GREECE ........................................................................................................................................... 31 6.8. IRELAND.......................................................................................................................................... 31 6.9. ITALY .............................................................................................................................................. 31 6.10. NETHERLANDS ................................................................................................................................ 32 6.11. PORTUGAL....................................................................................................................................... 32 6.12. SPAIN .............................................................................................................................................. 33 6.13. SWEDEN .......................................................................................................................................... 33 6.14. UNITED KINGDOM........................................................................................................................... 33

    7. SCIENTIFIC SURVEYS: MODULE G............................................................................................... 33 7.1. GENERAL COMMENTS...................................................................................................................... 33

    7.1.1 Priority 1 and Priority 2 surveys ............................................................................................... 33

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    7.1.2 Atlanto-Scandian Herring Survey (ASH)................................................................................... 34 7.1.3 Tuna tagging.............................................................................................................................. 36 7.1.4 MEDITS Survey ......................................................................................................................... 38 7.1.5 Changes in survey design........................................................................................................... 38 7.1.6 Surveys for anadromous and catadromous species ................................................................... 39

    7.2. BELGIUM ......................................................................................................................................... 39 7.3. DENMARK ....................................................................................................................................... 39 7.4. FINLAND.......................................................................................................................................... 40 7.5. FRANCE ........................................................................................................................................... 40 7.6. GERMANY ....................................................................................................................................... 41 7.7. GREECE ........................................................................................................................................... 42 7.8. IRELAND.......................................................................................................................................... 42 7.9. ITALY .............................................................................................................................................. 42 7.10. NETHERLANDS ................................................................................................................................ 43 7.11. PORTUGAL....................................................................................................................................... 43 7.12. SPAIN .............................................................................................................................................. 43 7.13. SWEDEN .......................................................................................................................................... 44 7.14. UNITED KINGDOM........................................................................................................................... 45

    8. BIOLOGICAL SAMPLING OF CATCHES: MODULES H AND I................................................ 46 8.1. GENERAL COMMENTS...................................................................................................................... 46

    8.1.1 Reference period for calculation of sampling levels.................................................................. 46 8.1.2 Sampling levels - General.......................................................................................................... 47 8.1.3 Sampling levels - CPUE tuning stocks....................................................................................... 47 8.1.4 International co-ordination of sampling programmes............................................................... 47 8.1.5 Derogation rules for the Mediterranean.................................................................................... 49 8.1.6 Sampling of biological parameters - Use of survey data ........................................................... 49 8.1.7 Sampling of biological parameters - Maturity and fecundity estimates..................................... 50 8.1.8 Annual, triennial and six-yearly updates of biological parameters ........................................... 51

    8.2. BELGIUM ......................................................................................................................................... 51 8.3. DENMARK ....................................................................................................................................... 52 8.4. FINLAND.......................................................................................................................................... 53 8.5. FRANCE ........................................................................................................................................... 55 8.6. GERMANY ....................................................................................................................................... 56 8.7. GREECE ........................................................................................................................................... 57 8.8. IRELAND.......................................................................................................................................... 58 8.9. ITALY .............................................................................................................................................. 59 8.10. NETHERLANDS ................................................................................................................................ 61 8.11. PORTUGAL....................................................................................................................................... 62 8.12. SPAIN .............................................................................................................................................. 63 8.13. SWEDEN .......................................................................................................................................... 64 8.14. UNITED KINGDOM........................................................................................................................... 66

    9. FLEET ECONOMIC DATA: MODULE J ......................................................................................... 68 9.1. GENERAL COMMENTS...................................................................................................................... 68

    9.1.1 Parameter definition .................................................................................................................. 68 9.1.2 Level of detail in NP proposals.................................................................................................. 68 9.1.3 Recommendations for the future ................................................................................................ 69

    9.2. BELGIUM ......................................................................................................................................... 69 9.3. DENMARK ....................................................................................................................................... 70 9.4. FINLAND.......................................................................................................................................... 70 9.5. FRANCE ........................................................................................................................................... 71 9.6. GERMANY ....................................................................................................................................... 71 9.7. GREECE ........................................................................................................................................... 72 9.8. IRELAND.......................................................................................................................................... 72 9.9. ITALY .............................................................................................................................................. 73 9.10. NETHERLANDS ................................................................................................................................ 73 9.11. PORTUGAL....................................................................................................................................... 74 9.12. SPAIN .............................................................................................................................................. 74 9.13. SWEDEN .......................................................................................................................................... 75 9.14. UNITED KINGDOM........................................................................................................................... 75

    10. THE PROCESSING INDUSTRY: MODULE K............................................................................ 76 10.1. GENERAL COMMENTS...................................................................................................................... 76

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    10.1.1 Recommendations for the future ........................................................................................... 77 10.2. BELGIUM ......................................................................................................................................... 77 10.3. DENMARK ....................................................................................................................................... 78 10.4. FINLAND.......................................................................................................................................... 78 10.5. FRANCE ........................................................................................................................................... 79 10.6. GERMANY ....................................................................................................................................... 79 10.7. GREECE ........................................................................................................................................... 79 10.8. IRELAND.......................................................................................................................................... 79 10.9. ITALY .............................................................................................................................................. 80 10.10. NETHERLANDS............................................................................................................................ 80 10.11. PORTUGAL.................................................................................................................................. 80 10.12. SPAIN.......................................................................................................................................... 80 10.13. SWEDEN...................................................................................................................................... 81 10.14. UNITED KINGDOM ...................................................................................................................... 81

    11. ANNEX 1: LIST OF PARTICIPANTS ........................................................................................... 82

  • 9

    1. Introduction The STECF Sub-Group on Research Needs and Data Collection, hereafter named SGRN, met in Brussels from 1-5 December 2003, to evaluate derogations and exceptions requested by Member States within their National Program proposals for 2004, in order that STECF could formulate advice on these requests to the Commission. On 3-5 December, SGRN was joined by a team of fisheries economists.

    1.1. List of participants STECF members Cardinale Massimiliano Ernst Peter Invited experts Arneri Enrico Degel Henrik Eltink Guus Garcia Mariano Grainne Ni Chonchuir Guyader Olivier Jardim Ernesto Kotsakis Evangelos (JRC observer)

    Koutrakis Emmanuil Le Floc’h Pascal Newton Andrew Pereda Pilar Pönni Jukka Redant Frank (chair) Rodgers Philip Souffez Arnaud Trujillo Valentin STECF Secretariat (EC) Biagi Franco

    The address of the participants is listed in Annex I.

    2. Terms of reference SGRN was requested to:

    a. evaluate derogations and exceptions requested by Member States within their National Program proposals for 2004 with regards to Modules E, F, G, H and I of EC Regulation 1639/2001;

    b. evaluate the NP proposals for 2004 with regards to Modules J and K of EC Regulation 1639/2001;

    c. give guidance on future amendments of Modules J and K of the Regulation.

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    3. Evaluation process and structure of the report 3.1. Evaluation process As in the previous years, SGRN used the Evaluators' Report as a starting point in its evaluation of the NP proposals. Apart from replying to the Evaluators' comments, SGRN also discussed a number of issues of general interest, and formulated advice on the type of information it would like to see included in future NP submissions.

    3.2. Upcoming revision of Regulation 1639/2001 and its implications on the evaluation process

    SGRN has based its evaluation primarily on what is required / acceptable under the provisions of the current version of the Regulation (*), but also with an eye on the upcoming revised version of the Regulation, and more particularly on the recommendations it made on the issue during its July 2003 meeting. This balanced approach can best be illustrated with the surveys as an example. The current Regulation contains a list of almost 60 surveys which are eligible either under the MP (Priority 1 surveys) or the EP (Priority 2 surveys). The revised version of the Regulation most likely will contain a number of new Priority 2 surveys. If this is the case, then these surveys will become eligible for funding under the EP from 2005 onwards. If there are sufficient scientific reasons to give these surveys Priority 2 from 2005 onwards, then SGRN saw no justification to negatively advise on these surveys if they were proposed by a MS for 2004 already.

    3.3. Structure of the report The report contains the following sections: A chapter (Chapter 4) with general comments, which apply to most, if not all Modules of the Regulation. Chapters by Module of the Regulation (Chapters 5-10), from Module E (Catch and landings data) to Module K (The processing industry). Each of these contains a section with general comments, which specifically apply to that Module of the Regulation. This section is then followed by the country-based sections, with SGRN's replies to the Evaluators' comments.

    (*) Unless stated otherwise, "Regulation" refers to EC Regulation 1639/2001.

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    4. General comments 4.1. Precision levels Evaluators' comments: The first Consultant’s report identified particular problems with the determination of whether Member States were likely to meet the required precision levels or not. Few Member States provided sufficient information to assess the likely precision of the results of their sampling programs and many simply mentioned that “precision will be met”. If exhaustive (census) data are being collected, then obviously the highest precision level will be met. However, for other data, which are collected through sampling (e.g. landings, biological data, discards etc) the situation is not so straightforward. Without describing in detail the extent of their sampling and the underlying distribution of sampled data, it is recognised that a determination of whether the precision level is likely to be met or not, will not be possible. The second report for 2003 proposals noted a general improvement in specifications of programmes and clearer indications of the likelihood of precision levels being met although, in most cases, the details were not sufficiently comprehensive in themselves to allow precision to be tested. The SGRN comments confirmed the inevitability of this. The 2004 proposals have a similar approach to precision as in 2003, with a moderate amount of detail but the actual level of precision can only really be taken on assurance. Nevertheless many Member States make provision in their co-ordination budget to be a part of meetings of the sub-group proposed by SGRN (above), and the ICES planning group on commercial catch, discards and biological sampling, and to implement their recommended methods for estimating or achieving required precision levels. All these initiatives, and the attention given to precision in the Member States proposals should all assist in the assurance that precision levels will be met. SGRN comments: SGRN re-iterates its recommendation that a sub-group should be set up to recommend methods for the estimation of precision in sampling programmes, covering catch and landings as well as sampling for other biological parameters. These recommendations should then be provided to every MS. SGRN notes that an ICES PGCCDBS Workshop will be held in January 2004, amongst others on this issue.

    4.2. International co-operation SGRN comments: Although international co-operation with respect to data collection has improved, the situation is still far from being ideal. SGRN has identified a number of areas where there is a clear need for international co-operation or where existing co-operation schemes could be improved:

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    Surveys, and more particularly the pelagic and demersal surveys in the Medi-terranean, and the tuna tagging surveys in virtually all areas. Length and age sampling of landings by foreign vessels: Here, data collection could be improved (and in the process made more cost-efficient) by better task sharing between the countries involved, or by intensified sampling in the flag country of the vessels, to compensate for the lack of sampling in the countries where the catches are landed and sold. Triennial estimates of the discards for the species listed in Appendix XII: The usefulness of these estimates could definitely be increased if all countries fishing for these species/stocks would decide to make the estimates in the same year. Annual, triennial and six-yearly updates of biological parameters: SGRN notes that the ICES PGCCDBS is planning to commence / continue co-ordination of sampling to secure adequate basic assessment data, and to ensure adequate spatial and temporal sampling coverage for the main areas in the Regulation (Baltic Sea, North Sea, NE Atlantic and Mediterranean waters). The inclusion of the Mediterranean waters in PGCCDBS was agreed during the first regional meeting of the Mediterranean area. SGRN understands that several initiatives are currently being undertaken to enhance co-operation between MS (within the framework of ICES Working Groups, as part of individual MS's NP, which have taken the initiative to set up new or to revive existing co-operation schemes, etc.). SGRN also notices that the Commission has plans to set up regional co-ordination groups, with the same area coverage as the upcoming Regional Advisory Councils (RACs). SGRN warmly welcomes these initiatives, and urges all MS to participate in these activities, and to report them in their NP proposals and technical reports.

    4.3. Use of results from pilot studies SGRN comments: Many MS have undertaken pilot studies in 2002 and / or 2003 to make provisional estimates of, amongst others, the importance of recreational and game fisheries, the extent of discarding, etc. Currently, the Regulation does not give guidance on how the findings of these pilot studies should be incorporated into the NP proposals for the ensuing years. In a number of "extreme" cases, the use that should be made of the pilot studies is obvious. If, for example, a pilot study shows that the recreational fisheries are marginal compared to the professional ones, then there is no need to set up a routine data collection program for them. If, for example, it shows that the recreational fisheries represent > 15 % of the total catches taken, it would be scientifically unwise not to set up a data collection programme. SGRN suggests that the findings of the pilot studies be presented to an STECF expert group first, and that, once their advice is available, this be then taken into account when writing the NP proposals for the following years.

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    4.4. Evaluation of NP proposals for 2005 and beyond SGRN comments: In 2004, ten new countries will join the European Union, seven of which are maritime or coastal states, viz. Cyprus, Estonia, Latvia, Lithuania, Malta, Poland and Slovenia. The new MS should comply with the requirements of Regulations 1543/2000 and 1639/2001 by presenting NP proposals on data collection for 2004-2006. Given the period in which they will join the EU (May 2004), the new MS can apply for financial assistance from 2005 onwards. If they all do so, the number of NP proposals for 2005 will be increased by 50 %. This also will substantially increase the workload of the Evaluators and of SGRN. In order to be able to cope with this, it may be necessary to extend the December meeting of SGRN, or at least to fully use the current five days of the meeting (i.e. from Monday morning till Friday evening). This year, most MS have submitted their NP proposals in one physical document, which is an improvement over the situation in the past. For the years to come, SGRN has two further requests with respect to the presentation of the NP proposals: When putting together their proposals, MS are kindly asked to strictly follow the structure of the Regulation, i.e. from Module C to Module K, without renaming or renumbering the Module sections. MS are also asked to submit their budget proposal in a separate physical document instead of including it in the scientific part (i.e. the part explaining what will be done and how) of their submission. Since SGRN only has to deal with the scientific aspects of the proposals, the budgetary information is of little relevance and should be submitted to the attention of the Commission only.

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    5. Catch and landings data: Module E 5.1. General comments 5.1.1 Coverage of catches and landings in other MS and by other flag vessels

    SGRN comments: Both the Evaluators and SGRN noticed that many MS failed to give full details in their NP proposals on how the recording of vessels landing their catches abroad is being dealt with. The recording of such data and their exchange between MS are subject to EU Regulation 2847/93. Hence, SGRN assumes that in all MS there are well established procedures in place to collect these data, and therefore SGRN does not see why this information should not be provided in the NP proposals. 5.1.2 Sampling of vessels < 10 m

    SGRN comments: Here too, the Evaluators and SGRN have noticed that many MS have failed to give full details in their NP proposals on how the vessels < 10 m are being covered for landings and discards. Following its earlier recommendations, SGRN again insists that: (a) MS give full details in their future NP proposals on how they plan to record

    landings and discards of their < 10 m vessels.

    (b) Pilot studies be initiated in all MS where there is no information on the extent of these vessels' landings and discards.

    5.1.3 Discards

    Evaluators' comments: Concerning discard monitoring, SGRN (Mar 2002) tried to clarify the requirements for discard sampling in Commission Regulation 1639/2001 and pointed out the major difficulties faced in order to comply with the Regulation:

    i. Heavy costs, especially when sending observers to sea.

    ii. Non co-operation from the industry on carrying discard observers leading to non random selection of vessels, or the number of available vessels is too limited to achieve the level of precision specified in the Regulation.

    iii. Issues related with the safety of discard observers on-board commercial fishing vessels.

    Some MS proposed to monitor discards using self-sampling (i.e. sampling of discards by the crew of a commercial vessel) in addition to on-board observers. Whereas the former is a less expensive method of getting discard information, many doubts arise about the reliability of such a sampling scheme namely because of the problematic nature of discard practices. Clear evidence should be provided on the degree of

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    reliability of self-sampling schemes before they can be accepted. To be assessed by STECF.

    SGRN comments: In general, SGRN prefers sea-going observers over self-sampling as a means to collect discard information (be it on quantities discarded or on their length and / or age composition), particularly since for the latter, data quality is often difficult to check and to guarantee. However, SGRN also recognises that in some particular cases, self-sampling might be the only workable way to collect discard information. SGRN insists that all MS currently applying or planning self-sampling programmes, operate some form of verification on a regular basis.

    5.1.4 Conversion factors

    SGRN comments: Both the Evaluators and SGRN have noticed that many MS have failed to provide details on the conversion factors used. However, since these factors are unlikely to change very often, SGRN sees no need to repeat this information in all NP proposals. Instead, SGRN recommends that the conversion factors should only be given in the NP proposal when changes have taken place.

    5.1.5 Quality assurance

    Evaluators' comments: This aspect is not fully addressed in NPs. The quality of basic data should be ensured both by internal practices, including data management and cross-checking and cross-validation of data from different sources (logbooks, sales notes, landing declarations), and by external practices, namely international co-opera-tion at the EU level, including monitoring of landings and discards, biological sampling and scientific surveys.

    Concerning the use of logbooks as the basis for calculating the landings under Module E, it is in general dubious as the fishermen are usually not very precise in their estimates and as the coverage in many cases are not 100 %. Thus these landings are likely to be underestimates. MS should perform all possible checks on these figures. The possibilities are to compare them with sale slips, auction data (including landing declarations) and to send observers on board vessels. This is a crucial issue of quality control and bias avoidance.

    SGRN comments:

    Quality control: SGRN agrees with the Evaluators' comments and considers that MS should implement such quality control, if not already implemented, and document these actions in their future NP proposals. However, SGRN also notes that there are no references to quality control in the Regulation.

    Logbooks for landings estimation: SGRN agrees with the Evaluators' comment and urges MS that use logbooks to estimate landings and to take the appropriate action in order to guarantee the reliability of the estimates.

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    5.2. Belgium Evaluators' comments: Belgium states that the required data on commercial landings will be collected but a non exhaustive, restricted list of species to be recorded is provided. They do not include all the species in Appendix XII of Regulation 1639/2001. As in 2003 evaluation some demersal and pelagic species, crustaceans and mollusc are not included in the list of landing species. Nevertheless Belgium states that “species that do not figure in the 'restricted' list are not deliberately omitted from the data recording system, they are simply not landed by the Belgian fleet. And if they are, it is in very small quantities only. As such, the list should not be seen as an attempt 'to get away with the minimum, but rather as a reflection of the actual composition of the Belgian fish and shellfish landings. There is a historical background to the 'restricted' list, which is based on the peculiarities of the Belgian sea fisheries: The geographical distribution of Belgian fishing effort is limited to the North Sea, the English Channel, the Irish Sea, the Celtic Sea, South of Ireland and the inner part of the Bay of Biscay. The consequence being that all typically northern and southern species are absent from the landings. Belgium has no industrial, no distant and no deep-water fisheries. Again, this implies that all species which are typical to such fisheries are absent from the landings.” To be evaluated by STECF. SGRN comments: SGRN sees no contradiction between the requirements of the Regulation and the use of a restricted list of species for which landings data are recorded, as long as the restricted list is a correct reflection of the species composition of the landings (which seems to be the case). SGRN however, insists that the MS extends the restricted list to any new species that are under a recovery or action plan (e.g. European eel, Anguilla anguilla). Evaluators' comments: As in 2003 Belgium NP, there is no mention on how vessels < 10 m will be dealt with. Although the number of vessel < 10 m seems to be very small, SGRN recommended to set up a pilot sampling study to provide an estimate of the quantities of Crangon that are landed by these vessels. Non-conformity. SGRN comments: SGRN re-iterates its recommendation that a pilot study be set up in 2004 to provide an estimate of the Crangon landings by vessels < 10 m. Also see comment on sampling of vessels < 10 m in this chapter.

    Evaluators' comments: Precision is stated to be exhaustive, but it remains unclear whether this applies to vessels smaller than 10 m. SGRN comments: SGRN was informed that Belgium has no registered fishing vessels of < 10 m. Vessels of that class are all recreational vessels, fishing almost exclusively for brown shrimp, Crangon crangon (See also previous comment).

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    Evaluators' comments: Pilot studies initiated in 2002 by Belgium to collect basic information and decide on the most appropriate design for the discards will be further expanded in 2004. Belgium states that “The only major fishery for which Belgium is not collecting discard information, is the flatfish directed fishery in the North Sea. The Netherlands however, do have a discard sampling program on their beam trawler fleet in the area, and since both fleets have roughly similar characteristics, it is proposed that – for the time being – the Dutch data also be used to estimate the discards by the Belgian North Sea beam trawler fleet. The possible future extension of the Belgian discard sampling program to the North Sea is currently under investigation, with particular emphasis on its logistic and financial implications.” To be evaluated by STECF. SGRN comments: SGRN was informed that Belgium and the Netherlands are currently exploring the possibility of co-operating on this issue in order to establish some form of task sharing with respect to discard sampling in all sea areas where they both have beam trawl fisheries. SGRN agrees with the approach taken by the MS, and suggests that the results of these negotiations be awaited before it formulates a final opinion. Evaluators' comments: Belgium states that it has no recreational fisheries for salmon and bluefin tuna and therefore requests a derogation for this part of the Regulation. The SGRN considered that this derogation was acceptable in previous years. SGRN comments: SGRN considers that a derogation is justified.

    5.3. Denmark Evaluators' comments: International co-operation is considered by Denmark in order to record landings of other MS vessels in Danish harbours but not mention is made about Danish landings of in other MS or in third countries. To be evaluated by STECF. SGRN comments: SGRN was informed that the amount of landings in foreign countries by Danish fishermen is limited. The most significant amount is the landings of Atlanto-Scandian herring (Norwegian spring spawning herring) in Norway. For this reason, arrangements have been made with Norway to have samples from this fishery collected in Norwegian harbours. The samples are frozen and sent to Denmark for working up. The agreement with Norway is on a sample exchange basis and therefore the arrangement is economically neutral and hence not included in the NP proposal. Also see general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

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    5.4. Finland Evaluators' comments: Regarding discarding data no information is given in Module E of Finnish NP. Nevertheless in Module H, Finland declares that discarding rates will not be estimated for plaice and Norway lobster due to negligible catches: “Norway lobster that does not live in the Baltic Sea is thus not caught by the Finnish vessels, and this also applies to plaice that is found in the ICES area IIIb-d, but not in the northern Baltic Sea”. For the stocks in the Finnish catch, derogations are requested for the discard sampling. Finland, according to the recommendation of SGRN states that it is not necessary a discard sampling for herring and sprat due to the fact that all catches are sold either for human consumption of for fodder markets. To be (re)evaluated by STECF SGRN comments: The arguments on the geographical distribution and Finnish catches of Norway lobster and plaice, as well as on marketing of Finnish herring and sprat catches remain. SGRN considers that a derogation is justified. Evaluators' comments: The pilot study for comparison of cod discards has been performed in 2003 in co-operation with Danish and Swedish institutions as recommended by SGRN. For that purpose, an ad hoc group met and compiled information on catch composition and amount of discards. The effect of discarding in Finnish cod fisheries and fleets have been evaluated and shown to be negligible. To be (re)evaluated by STECF. SGRN comments: The abundance of cod in the northern Baltic is negligible at present. Therefore, practically all Finnish cod catches are taken from the southern Baltic (by a fleet of less than 10 gill-netters and trawlers), which is the same area that is used by Danish and Swedish vessels. Finnish landings of cod represented 2.7 % of the EU quota in 2001 and 2.3 % in 2002. In a pilot study, the Finnish discard levels and catch composition were estimated from data for similar Danish and Swedish fisheries in the same area. The Finnish discarding rates (0.5-2.2 % in numbers) were insignificant, and their contribution to the total discarding was found to be negligible. Therefore, SGRN considers that a derogation for cod discard sampling is justified. Evaluators' comments: In relation to salmon and trout the pilot study that was recommended by the SGRN, was carried out in 2003. The study was based on the catch statistics, and an attempt to derive a more accurate quantitative estimate was conducted. In addition, the need to carry out a field survey in the future to attain more reliable estimates on salmon discarding has been evaluated. The preliminary results indicate a need to carry out a field study on the quantity of killingly harmed undersized salmon in gears, particularly in long lines. In 2004, a field survey based on visual estimation on the proportion of harmed undersized salmon will be conducted on long line, drift net and trap net fisheries. To be evaluated by STECF.

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    SGRN comments: SGRN was informed that the Finnish commercial salmon catch is taken in a coastal fishery, mainly by trap nets (49 % of total catch in 2002), and in an offshore fishery by drift nets or long-lines (38 % and 12 % respectively). In terms of data needs for the stock assessments, the monitoring program referred to in the pilot study, gives an adequate understanding of the discards of salmon and sea trout in the trap and drift net fisheries, but there are no data available concerning the proportion of undersized salmon, the rate of injury caused by hooks, or the survival of released fish in the long-line fishery. At the moment, the share of long-line catches is small, but the anticipated ban on drift netting in the Baltic may change the structure of the salmon fishery in favour of the long-line fishery. SGRN agrees with the approach taken by the MS. Evaluators' comments: Recreational catches are estimated by surveys every second year. The last survey was completed in 2002. In the year 2004, a survey for the statistical year 2004 will be planned and a preparatory work will be done. This includes planning the inquiry forms, commissioning the frame register and designing and extracting the sample. The actual inquiry period of the survey will begin in the early 2005 followed by data handling, estimation and reporting during 2005. The detailed sampling, measuring and estimation procedures will be decided on the basis of the pilot study results that are available after the end of October 2003. To be evaluated by STECF SGRN comments: SGRN agrees with the approach taken by the MS.

    5.5. France Evaluators' comments: France states that all French landings abroad will be reported but no mention is made about landings of other flag landings in French harbours. Non-conformity. SGRN comments: See general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    Evaluators' comments: With relation to discard sampling, France proposed a pilot study in its NP for 2002, aimed to determine levels of discards for several fisheries. Fleets identified in 2002 pilot studies were monitored in 2003 by placing observers on board vessels. The work targeted primarily, but not solely, species whose discard levels are to be assessed annually. The study methodology provides for an exhaustive analysis of catches taken on board, so that information is available for all the species listed in Annexes XII and XV, at least in terms of presence or absence, numbers or weight. All of this information must be included in the report to be delivered on 31 October 2003, in accordance with paragraph E-1(c) of the implementing Regulation. France states that “The actions that will be taken in 2004 on the English Channel-North Sea, Atlantic and Mediterranean coastlines of metropolitan France, will be a continuation of those undertaken in 2003, whose protocols will have been validated on the ground. However, depending on the information made available by the initial work at sea and also on the expert reports and opinions

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    that will have been delivered on the national reports presented to the Commission in late October 2003, these protocols may be revised and adapted so as to monitor better in 2004 the fisheries, gears and species which prove to be responsible for generating the highest levels of discards. Any amendment of these protocols may only be made, however, within the allocation of days at sea provided for in the 2004 programme”. Although the fleet > 40 m, fishing in the Celtic fleet is not included, France asked for a derogation last year and it was accepted. However, SGRN accepted the derogation, “provided that the request is fully documented”. In addition, SGRN recommended that “discards in deep-sea fisheries should be carried out on an international co-ordinated project including all countries involved in these fisheries”. These aspects are covered by the French NP but they are not fully clarified, namely concerning deep sea fisheries. To be evaluated by STECF. SGRN comments: SGRN was informed that the French discard program in 2004 will try as much as possible to follow the conclusions of the Discard Workshop held in Charlottenlund, Denmark. This goes from the selection of the vessels, to the raising methodology and the implementation of quality control. The deep-sea discard program driven by EU Regulation 2347/2002, is not included in Regulation 1639/2001, and will be undertaken separately. SGRN draws attention to the fact that the deep-sea species falling under Regulation 2347/2002 will be included in the revised Regulation 1639/ 2001, and hence that sampling of their catches, landings, discards, etc. will have to become part of the NPs from 2005 onwards. Evaluators' comments: Concerning recreational fisheries, France states that there are not recreational fisheries targeting salmon in the North Sea or in the Baltic and that during a recent survey recreational bluefin tuna catches in the Mediterranean were estimated to be negligible with respect to commercial catches (0.25 %). Nevertheless, with a view to clarifying the situation and updating the share of catches of recreational fisheries in the Mediterranean, a new estimate was made in 2003, based on surveys of associations singled out along the French Mediterranean coastline. The results of this pilot study are to be used to draw up the report that will be presented to the Commis-sion for 31 October 2003 in accordance with subparagraph E-1-(c) of the implementing Regulation. France states that “Consequently, and unless the Regulation is amended following the examination of all the Member States' reports, France is not planning any operation in 2004 for Module E - Recreational fisheries”. STECF should check if any action is to be carried out in 2004.

    SGRN comments: SGRN was informed that the report on this pilot study has not yet been submitted to the Commission, and therefore SGRN was unable to formulate recommendations on any future action.

    5.6. Germany Evaluators' comments: Germany states that landings data of fishing vessels under German flag are given in weight and value based on EU Regulations 2807/83, 2847/93 and 104/2000. Data collection, aggregation and precision level requested seem to be met by German program. Nevertheless, it is stated

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    that data related with vessels < 10 m are based on landing declarations and cannot be related to gear and effort. To be evaluated by STECF. SGRN comments: Vessels < 10 m are not obliged to keep logbooks. They are only obliged to fill in landings declarations. SGRN was informed that the landings of these vessels are recorded by the MS. These data can not be separated by gear and effort, but almost all use static gears and are not equipped to operate mobile gears. SGRN suggests that discussions are developed over pilot studies on these fisheries. Also see general comments on sampling of vessels < 10 m in this chapter.

    Evaluators' comments: From the above it is supposed that German landings abroad will be obtained, in fact the major part of landings under German flag are landed outside of Germany. No mention is made about foreign landings in German harbours. Non-conformity. SGRN comments: SGRN was informed that the foreign vessel landings in Germany are analysed in the same manner as German flag vessels. Also see general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    Evaluators' comments: Discards will only be recorded for those stocks to be sampled in Module H after applying derogation rules. Germany states that to comply with all listed species in App. XII would in the case of Germany result in establishing illegal fisheries (no quota) or reactivating non-active fisheries only in order to get estimations on discards for these stocks and they give some examples: No active fishery of German vessels in NAFO except for redfish in 1F which is covered by the stock in the Irminger Sea Long distance migratory stocks (tuna, no quota for Germany) Plaice VIId (no quota for Germany) Non-conformity: All populations in Appendix XII should be recorded with the given disaggregation. SGRN comments: The Evaluators seem to have mis-interpreted the NP proposal. SGRN considers that a derogation is justified. Evaluators' comments: Germany states that discard monitoring of all stocks listed in App. XII would result in no rational cost-gain relationship. Germany will not be able to give the precision levels of discard sampling. Germany states that results of the 2002 data sampling has to be taken into account first, which is exactly the same which was reported by Germany last year. To be re-evaluated by STECF. SGRN commented in 2002 that “The evaluators seem to have mis-understood the text in the NP. SGRN was informed that the MS intends to sample discards volume for all species in Appendix XII as part of the at-sea sampling program. However, biological sampling by length and age will just be done for the species in the list provided. The text of the NP proposal might need some rewording”. SGRN comments: SGRN was informed that the 2002 data concerning precision levels were not available at the time when the NP proposal for 2004

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    was written. Subsequently these data have become available and the analysis will appear in the 2003 Technical Report. SGRN understands that Germany has discard sampling programmes for all its major fisheries, and that discard data are being collected for all species which are listed in the Regulation. As such, SGRN sees no non-conformity. Evaluators' comments: Concerning recreational and game fisheries data, as well as disaggregation and precision level, Germany states that depending on the evaluation of the report on the pilot study to be send in by 31.10.03 either a monitoring programme will be started or no action will be necessary. To be evaluated by STECF. SGRN comments: SGRN was informed that the “Report of the Pilot Study on Catches of Salmon and Bluefin Tuna in the German Recreational and Game Fisheries” was submitted to the Commission on schedule. SGRN was also informed that sampling on Baltic Sea salmon will be continued.

    At its July 2003 meeting, SGRN recommended that the recreational species listed in Appendix XI be expanded to also contain cod (Gadus morhua) in ICES Areas III, IV, V, VI and VII (given that cod is the subject of a recovery plan in these areas), with tech-nical specifications similar to that for salmon, and that pilot studies be carried out (in 2005 at the latest, SGRN) to assess the feasibility of collecting such data. Germany proactively has planned such a pilot study for 2004. SGRN welcomes the approach taken by the MS.

    5.7. Greece Evaluators' comments: No mention is made about recreational fisheries. A derogation from the Regulation 1639/2001, Module E and the relevant Appendix XI, concerning recreational bluefin tuna fisheries was requested within the 2003 Greek NP. SGRN was informed that there was no evidence of a bluefin tuna fishery, either by recreational or by game fishery in Greece but a pilot study was recommended in co-operation with other relevant countries, under supervision of ICCAT to clarify this issue. To be evaluated by STECF. SGRN comments: SGRN was informed that the pilot study will be performed in 2004. Evaluators' comments: No mention is made about international co-operation. SGRN comments: See general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter, and on international co-operation in Chapter 4.

    5.8. Ireland Evaluators' comments: No mention is made about Irish landings abroad. To be evaluated by STECF. Landings of foreign vessels in Irish harbours appear tabulated.

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    SGRN comments: SGRN was informed that Ireland does gather information on Irish landings into foreign ports. This is done through international co-operation with countries such as Norway and Spain. Both Norway and Spain provide Ireland with summaries of Irish landings. This data is cross-checked with official figures produced by the Irish Department of the Marine for confirmation. Sampling also takes place of Irish landings into Northern Ireland and the UK but on a more ad hoc basis. Also see general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    Evaluators' comments: Ireland states that it will provide catch data on its only recreational fishery, e.g. bluefin tuna. Last year it was commented that Ireland would send a report with the conclusions about the pilot study on bluefin tuna carried out in 2000, 2001 and 2002. We do not know what the conclusions of the pilot are at this point. A contradictory statement appeared last year in Module H of the Irish NP, where it was said that “it has not been established recreational fisheries for salmon or bluefin tuna in Ireland”. To be evaluated by STECF. SGRN comments: The Evaluators seem to have mis-understood the Irish NP proposal. Ireland has a developing, not established, recreational fishery for bluefin tuna. Ireland has carried out pilot studies on this fishery since 2000, the results of which were submitted to the Commission in October 2003. SGRN was informed that Ireland intends to continue monitoring this fishery in 2004 and beyond.

    5.9. Italy Evaluators' comments: Italy will obtain data covering landings abroad of vessels flying their flag, but it states that landings of foreign vessels will not be recorded because they do not exist in Italy. To be evaluated by STECF. SGRN comments: See general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    Evaluators' comments: Concerning discard programme, Italy states that “since no requirement for discards is specified in Appendix XII of Regulation CE No. 1639/01 for the Mediterranean, a pilot study has to be carried out to supply the information required for planning the collection of data. The results of the pilot study will be forwarded by 31 October 2003. Programme work for future years will be based on the results of the pilot study”. Discards for all Mediterranean species/populations in Annex XII should be recorded in a triennial based and previously analysed through a pilot study as the one proposed by Italy. No action is planned for 2004. To be assessed by STECF. SGRN comments: SGRN agrees with the Evaluators' comments that new estimates of the discards will have to be made 2005 or in 2006 (regardless of what the outcome of the pilot study has been). See general comments on the use of results from pilot studies in Chapter 4. Evaluators' comments: The same is declared about recreational fisheries; “a specific pilot study is being carried out in 2003 for overall evaluation of

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    recreational bluefin tuna fishing. The study will be based on the TR forms submitted to Port Offices in 2001 and 2002; the data will be processed, and information on how to improve the data recording and collection system will be supplied by 31 October 2003. Programme work for future years will be based on the results of the pilot study”. No action is planned for 2004. To be assessed by STECF. SGRN comments: Given the importance of recreational bluefin tuna catches, as described in the 2003 pilot study, SGRN recommends that a routine data recording system be set up to monitor this fishery as quickly as possible and at the latest from 2005 onwards. Evaluators' comments: Italy states that conversion factors will not be applied to landing-weight-based quantities as all species are landed ungutted. Conversion factors could be necessary only for marginal share of landings. For these species, quantities will be converted to live weight by the FAO and Eurostat conversion factors and the NP gives the reference where these values can been found. However, SGRN stated that conversion factors were necessary for large pelagic. Non-conformity. SGRN comments: See general comments on conversion factors in this chapter. Evaluators' comments: No mention is made about international co-operation in this Module. Non-conformity. SGRN comments: See general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    5.10. Netherlands Evaluators' comments: An extensive discard survey is proposed in the NP using on board observers and related to Modules H & I. Regulation requirements will be met but the general problem of not random selection of vessels gives uncertainly to the level of precision required to be met. In any case, Netherlands assures that disaggregation levels will be reached but from the information supplied in the NP it is not clear if Netherlands is running a pilot study for estimating precision levels. To be evaluated by STECF. SGRN comments: SGRN was informed that Netherlands is running a pilot study for estimating precision levels. See general comments on precision levels in Chapter 4. Evaluators' comments: A list of conversion factors is not provided although Netherlands states that a list with conversion factors will be made available. To be evaluated by STECF. SGRN comments: See general comments on conversion factors in this chapter.

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    5.11. Portugal Evaluators' comments: Portugal states that whenever Portuguese landings occur abroad, the country is asked to send to Portugal the relevant information. Nevertheless no mention is made about other flag landings in Portuguese harbours. To be checked by STECF. SGRN comments: There are EU regulations which define how this should be done and Portugal complies with them. Also see general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    Evaluators' comments: Discard sampling methodology is described. Sampling will be carried out by trained observers on vessels larger enough to accommodate an additional person on board and In the case of small-scale local fishing vessels (non-industrial fleet), which in most cases do not have space on board for an observer, the volume of discards will have to be estimated from surveys carried out (on land) with the master/crew. Disaggregation level requirements seem to be met, but no explicit mention to the precision level is made. On the other hand, Portugal declares that pilot studies for evaluating discards of the main fishing gears used in Azores and Madeira are being carried out since 2003, although no reference is made about reports including the conclusions of these studies. To be checked by STECF. SGRN comments: Precision of discard sampling is still an open matter. Although precision levels are required by the Regulation, it will only be possible to compute them in a few years. Even then, there may be a possibility that the Regulation's requirements may not be achieved or only at excessive cost. Also see general comments on precision levels in Chapter 4. In the NP proposal, there is no reference to a pilot study for 2004 in Madeira. For the Azores, it is proposed to have a new pilot study in 2004, due to the fact that new and larger fishing vessels are operating in the region. SGRN agrees with the approach taken by the MS. Evaluators' comments: No pilot study on game and recreational fisheries was mentioned to be implemented by Portugal, neither in continental Portugal nor in Azores and Madeira in 2003 NP. Nevertheless, regarding recreational fisheries Portugal states that reports with the conclusion of pilot studies about catching of bluefin tuna in Azores and Madeira will be presented to the Commission by 31 October 2003. Based on these conclusions the need of continuity of this kind of study in 2004 will be evaluated and, if justified, it will be considered in a future budget. To be evaluated by STECF. SGRN comments: SGRN was informed that there are no recreational fisheries for the species in Annex XI on the Portuguese mainland coast, Madeira and the Azores (see "Report on the Pilot Studies" submitted by Portugal to the Commission in November 2003), and therefore concludes that there is no need for further action. Evaluators' comments: Conversion factors are mentioned to be provided. SGRN comments: See general comments on conversion factors in this chapter.

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    Evaluators' comments: The only explicit mention to international co-operation is about obtaining Portuguese landings abroad (mainly with Spain). SGRN comments: See general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    5.12. Spain Evaluators' comments: Regarding tropical tuna fisheries abroad, the presence of an Spanish expertise in the area is necessary for obtaining catching data in a correct and fast way. This is the only reference about data of Spanish landings abroad and there is no mention about other flag landings in Spanish harbours. To be evaluated by STECF. SGRN comments: Apparently, this is an omission in the NP proposal, considering that all Spanish landings abroad are recorded, following the current legislation that governs the reporting of landings. See general comments on coverage of catches and landings in other MS and by other flag vessels in this chapter.

    Evaluators' comments: Regarding recreational fisheries Spain states that for the recreational and game-fishing of bluefin tuna, a pilot project (described in detail in Annex 2 of the NP) will be set up to compile the data stipulated in Appendix XI of the Commission Regulation. Nevertheless, this pilot study was planned in 2003 NP and a report is expected to be submitted before 31 October 2003. STECF should check if any action is to be carried out in 2004. SGRN comments: The Evaluators seem to have mis-interpreted the NP proposal, since the annex just explains how the estimates for the recreational and game-fishing of bluefin tuna in 2004 will be calculated. SGRN was informed that the report of the pilot study on recreational fisheries of bluefin tuna in the Mediterranean has already been submitted. Evaluators' comments: Conversion factors are not provided, although Spain states that the conversion factors used to convert processed landings into live weight landings will be presented for each species and process type in the form of a table in the corresponding annual report. To be evaluated by STECF. SGRN comments: See general comments on conversion factors in this chapter.

    5.13. Sweden Evaluators' comments: Sweden will carry out a discard monitoring, and random selection is guaranteed only for vessel measuring more than 12 m. Disaggregation levels are met, but the only mention made about precision levels is that the ICES Planning Group on Commercial Catch, Discards, and Biological Sampling concluded that there are still difficulties to overcome before good estimates of precision can be given. To be evaluated by STECF. SGRN comments: See general comments on precision levels in Chapter 4.

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    Evaluators' comments: A pilot study on game and recreational fisheries of salmon was carried out in 2003 and conclusions must be reported to the Commission by 31.10.2003 at the latest. Sweden states that no sampling of game and recreational fisheries will take place in 2004. To be evaluated by STECF. SGRN comments: Results from the pilot study revealed that game and recreational fisheries catch around 31 % in the coastal areas and 6 % offshore of the total Swedish catch of salmon. Therefore, SGRN recommends that sampling of game and recreational fisheries should be performed as established by the Regulation and included in the MP. See general comments on the use of results from pilot studies in Chapter 4.

    5.14. United Kingdom Evaluators' comments: United Kingdom will provide commercial landings data for all stocks included in the Appendix XII of Regulation 1639/2001. This data are based upon information registered in logbooks (> 10 m vessels), landing declarations and sales notes (all vessels) and will be provide according to a level 2 of disaggregation. No mention about precision level is reported. To be evaluated by STECF. SGRN comments: Apparently, this is an omission in the NP proposal. SGRN insists that the MS takes the necessary steps to remedy this omission, and to make sure that the Regulation is correctly implemented. Evaluators' comments: Extensive discard surveys will be developed, namely using observers on board and some self-sampling. It applies to vessels > 10 m. No sampling of vessels < 10 m will be undertaken for Health and Safety reasons. UK states that since, this segment of the fleet contributes only a small proportion of overall landings, this is not expected to bias the results. However, it is expected that some samples from vessels < 10 m will be obtained using a self-sampling scheme. Disaggregation level requirements seem to be met, but no explicit mention to the precision level is made. Non-conformity. SGRN comments: SGRN was informed that results of the calculations of precision levels had shown that coefficients of variation for the fleet level estimates often exceeded +/- 25 %. The 95 % confidence levels were half as precise. This problem arises from the substantial variation in both estimates of discarding and of raising factors between trips. This implies that a very large number of trips would have to be observed to consistently achieve the precision called for by the Regulation. This would involve excessive cost and therefore the UK requests a derogation from the precision requirements on discard estimates as offered in paragraph 2 of E(1)c. Also see general comments on precision levels in Chapter 4. Evaluators' comments: Regarding game and recreational fisheries UK states that the review of the extent of commercial landings of other species in Appendix XII from recreational fisheries apart from salmon carried out in 2003

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    will be reported in October 2003. If shown to be necessary, more detailed studies will be conducted in 2004. To be evaluated by STECF. SGRN comments: SGRN was informed that consultations within the UK had established that there were no marine recreational fisheries for species listed in Appendix XII. For salmon, recreational fishing exists, but it is confined to inland waters (i.e. river fishing for salmon when it is returning for spawning). Similarly for bluefin tuna, there is no recreational fishery in the UK. The UK is aware of a limited recreational fishery off the west coast of Ireland, but none around the UK coast. Evaluators' comments: Conversion factors are not supplied. Non-conformity. SGRN comments: SGRN was informed that the UK had supplied the current conver-sion factors to the Commission on 18th November 2003. See general comments on conversion factors in this chapter.

    6. Catch per unit effort: Module F 6.1. General comments 6.1.1 Criteria for MP and EP CPUE data series

    Evaluators' comments: The Sub-Group on Research Need (SGRN) met in March 2003 to: Analyze the national reports on the utility of catch and effort data (1995-2000) within stock assessment work, Set up a list of CPUE series to be integrated into the MP, and Give advice on the proposed new CPUE indices to be included in the EP. STECF formulated its advice on this topic as follows: SGRN considers that the MP should contain only data series for catches and effort for: Fleets which have been used at any time from 1995 onwards in stock assess-ments (analytical or production model). Fisheries where there is no stock assessment and where CPUE were the only way for an international Working Group to estimate trends in the stocks abun-dance at any time from 1995 onwards. Fisheries where there are International Organisation requirements (large pelagic fisheries of ICCAT for example). SGRN considers that the extended programmes should contain data series for catches and effort for: Fleets which have not been used in stock assessments but where stock assess-ments are expected to be conducted in the near future e. g. Mediterranean waters, deep sea resources.

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    Fleets where data collection started in recent years until these data series are used in stock assessments. Fleets which data series are available but are only used for biological purposes (length and age composition). SGRN considers that if the data series are not included under the minimum or the extended programmes, they should be funded nationally if necessary. When going through the STECF report on CPUE data series evaluation, we have found a number of inconsistencies in several NPs when applying the criteria set up by STECF for admission of CPUE series. Several series that appear in the tables as admitted by STECF for the MP, do not comply with the requirements above. SGRN comments: SGRN re-affirms its opinion on the criteria that should be used to make the distinction between MP and EP CPUE data series (see above). On top of that, SGRN also urges MS to take the necessary steps to guarantee the quality of the data series and their usefulness for assessment purposes, be it analytical or other.

    6.2. Belgium Evaluators' comments: The plan presented by Belgium incorporates to the MP the series fixed by SGRN. However, some inconsistencies appear between both tables concerning the populations to be sampled. According to table 9.1 of the SGRN report, Crangon in IVc East should be included into the MP. To be evaluated by STECF. SGRN comments: SGRN was informed that the MS is routinely updating the CPUE data series for a number of stocks, and that no costs are being charged for this. Nevertheless, SGRN insists that the different stocks be included under the relevant programme proposals (MP or EP) in future applications. Also see general comments on criteria for MP and EP CPUE data series in this chapter. Evaluators' comments: The plan presented by Belgium follows the STECF advice concerning the series to be included in the EP. However, some inconsistencies appear between both tables concerning the populations to be sampled. According table 9.1 of SGRN report, plaice VIIaefg should be EP. To be evaluated by STECF. SGRN comments: See previous comment.

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    6.3. Denmark No comments.

    6.4. Finland Evaluators' comments: Finland specifies that 13 fleets will be studied for the provision of CPUE series. According to the SGRN table, the long line series for salmon in area 32 was not accepted since no fishing with this gear was registered after 1996. To be evaluated by STECF. SGRN comments: SGRN was informed that, according to the catch statistics for the Finnish commercial marine fishery, the long-line fishery in ICES Sub-division 32 has been recorded regularly every year, i.e. also in years 1997-2003. However, the assessment in Sub-division 32 is not making use of these CPUE data as it is based on tagging and information from the trap net fishery. The data series does not comply with any of the criteria for funding under the MP. It is however, used to provide general background information on the fisheries, and as such, it helps to improve the overall assessment process. Therefore SGRN considers that this data series should be eligible under the EP. Also see general comments on criteria for MP and EP CPUE data series in this chapter.

    6.5. France No comments.

    6.6. Germany Evaluators' comments: Germany will maintain all CPUE series in 2004 as previously provided to assessment working groups. It is implicit that this work will be included within the MP. However, the SGRN admitted a total of 6 German series, including 3 series for the MP and 3 for the EP, respectively. To be evaluated by STECF. SGRN comments: SGRN was informed that the MS is routinely updating the CPUE data series for a number of stocks, and that no costs are being charged for this. Nevertheless, SGRN insists that the different stocks be included under the relevant programme proposals (MP or EP) in future applications. Also see general comments on criteria for MP and EP CPUE data series in this chapter.

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    6.7. Greece Evaluators' comments: Greece will elaborate the 3 CPUE series admitted by SGRN. Data appears to be extracted from a specific survey devoted to get catch and effort data for the target species. This implies a relatively high budget. However, it appears that this specific survey largely overlaps with the ones described for large pelagics in Modules D (action 2.2.2 in the Greek NP) and E (action 3.1.2 in the Greek NP). Being the standard procedure that eligible costs for this Module are exclusively those coming from the analysis of the series, whereas the catch and effort data making them derive from Modules D and E, Greece should clarify the degree of overlapping of these actions and the splitting of costs among them. SGRN comments: SGRN was informed that this task includes the elaboration of the CPUE series and some additional collection of day by day data (on top of what is done under Modules D and E), following an ICCAT recommendation. SGRN agrees with the approach taken by the MS. Financial implications to be discussed between the Commission and the MS.

    6.8. Ireland Evaluators' comments: Ireland will continue to build and update the various CPUE and/or specific effort of specific commercial fleets for use in stock assessment by various working groups. Although the NP rewrite the series admitted by the STECF, it does not fully clarify whether they will exclusively work out the STECF selected series or other, not selected series will also be worked out. To be evaluated by STECF. SGRN comments: SGRN was informed that Ireland intends to continue to update the various CPUE series of its commercial otter trawl fleets as outlined under the MP in the 2004 NP submission. Ireland also intends to examine the usefulness of a CPUE series in VIa and VIIhjk beam trawlers, as recommended by STECF, under the EP. No funding is requested for this exploratory work in 2004. However, if the data series are useful for stock assessments, then Ireland will apply for funding in 2005.

    6.9. Italy Evaluators' comments: Italy rewrote the SGRN advice for the CPUE series to be maintained by Italy. They are a total of 4 series, including 3 MP and 1 EP. However, only one series is included in the MP for the Italian NP. Technical arguments are given to abandon the trap and purse-seine series for bluefin tuna. To be assessed by STECF.

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    SGRN comments: SGRN considers that CPUE data collection for the two concerned fisheries (trap and purse seine) should be continued, as stated by the STECF-SGRN report of March 2003 on CPUEs. Also see general comments on criteria for MP and EP CPUE data series in this chapter. Evaluators' comments: Costs for the only one series to be maintained are very high. It appears that the specific survey devoted to this action largely overlaps with the collection of effort (Modules D) and catch data (Module E), in addition to the collection of biological (Module H&I) and economic data (J). Being the standard procedure that eligible cost for this Module are exclusively those coming from the analysis of the series, whereas the catch and effort data making them derive from Modules D and E, it should be clarified the degree of overlapping of these actions and the splitting of costs among them. SGRN comments: SGRN has no comments. Financial implications to be discussed between the Commission and the MS. Evaluators' comments: EP includes the CPUE data series for catches and effort for demersal trawl fishery, as recommended by the SGRN. However, as it was the case for the only one series to be maintained in the Italian MP, costs appear to be very high. It appears that the specific survey devoted to this action largely overlaps with the collection of effort (Modules D) and catch data (Module E), in addition to the collection of biological (Module H&I) and economic data (J). Being the standard procedure that eligible cost for this Module are exclusively those coming from the analysis of the series, whereas the catch and effort data making them derive from Modules D and E, it should be clarified the degree of overlapping of these actions and the splitting of costs among them. SGRN comments: SGRN has no comments. Financial implications to be discussed between the Commission and the MS.

    6.10. Netherlands No comments.

    6.11. Portugal Evaluators' comments: Portugal states that current CPUE series will be maintained. SGRN advised to admit 10 series for the MP and 1 for the EP, but it was not specified whether or not non selected series will be worked out. To be evaluated by STECF. SGRN comments: SGRN was informed that work on all selected data series will be continued. Also see general comments on criteria for MP and EP CPUE data series in this chapter.

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    6.12. Spain Evaluators' comments: The NP states that a total of 10 (sic) series have been admitted by SGRN. However, it appears that that figure (10) is a mistake since it is stated that 24 person men are necessary to work out the series at a rate of one per week (meaning 104 series). SGRN advised to include 120 series in the MP and 31 in the EP. No EP is proposed for this Module. To be evaluated by STECF. SGRN comments: The Spanish NP proposal is confusing, in the sense that only 10 CPUE data series are mentioned explicitly, while the budgeted costs for manpower refer to the calculation of the full set of over 100 data series. SGRN urges Spain to clarify which CPUE series will be included in its 2004 NP, and which series will be at national expense, in order to make sure that the Regulation is correctly implemented. Financial implications to be discussed between the Commission and the MS. Since there seems to be some confusion on the CPUE data series that should actually be included in the Spanish NP (either under the MP, or under the EP), SGRN also recommends that the classification of the Spanish CPUE series, as agreed in March 2003 meeting, should be reconsidered. Also see general comments on criteria for MP and EP CPUE data series in this chapter.

    6.13. Sweden No comments.

    6.14. United Kingdom No comments.

    7. Scientific surveys: Module G 7.1. General comments 7.1.1 Priority 1 and Priority 2 surveys

    SGRN comments: In its evaluation of the derogations and non-conformities in relation to surveys, SGRN has used the following general criteria: Priority 1 surveys in the current version of the Regulation are compulsory and should be part of the relevant MS's MP proposal.

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    Priority 2 surveys in the current version of the Regulation are optional and can be included in the MS's EP proposal. Priority 2 surveys in the draft version of the revised Regulation were considered to be eligible for funding under the EP in 2004. In doing so, a MS that adapted their NP proposals for 2004 to the upcoming revision of the Regulation are being rewarded for their proactive approach. All proposals for new surveys or for upgrades from Priority 2 to Priority 1 that are not include