Legal provisions of COM(2013)85 - Member States' efforts during 2011 to achieve a sustainable balance between fishing capacity and fishing opportunities

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dossier COM(2013)85 - Member States' efforts during 2011 to achieve a sustainable balance between fishing capacity and fishing opportunities.
document COM(2013)85 EN
date February 18, 2013
 

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52013DC0085

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on Member States' efforts during 2011 to achieve a sustainable balance between fishing capacity and fishing opportunities /* COM/2013/085 final */


REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL

on Member States' efforts during 2011 to achieve a sustainable balance between fishing capacity and fishing opportunities

1. Introduction and main findings

Member States are responsible for a stable and enduring balance between their fleets and the fishing opportunities allocated to them. Sustainable management of fisheries implies an economically viable fleet exploiting natural resources below maximum sustainable yield (MSY) levels. This is one of the key principles of the reform of the Common Fisheries Policy proposed by the European Commission.

This report provides an overview of the EU fishing fleets. The information used is that sent by Member States in their 2011 annual reports, in the EU Fleet Register, or as data collected under the Data Collection Framework, see Annex 1. An assessment of these data was made by the Scientific, Technical and Economic Committee for Fisheries (STECF).

The main finding is that significant improvement is needed over the next years in the way Member States evaluate the balance and manage their fleets. As fisheries management develops to include the MSY objective, it is no longer satisfactory to rely on ceilings expressed in static parameters. Economic viability and broader sustainability indicators are needed to manage the EU fleets to attain an economically viable fleet exploiting a resource at its full biological potential. Improvements in stock assessment are crucial, as well as in data collection and provision, analysis and methodology.

2. CAPACITY CEILINGS …

Each Member State must ensure that its fishing capacity in tonnage (in GT) and power (in kW) is always equal to or less than the nominal levels as determined in Regulation 1013/2010. Current entries in the fleet register indicate that all Member States except Romania complied with these nominal levels (see Annex 2). The Union fleet was 14.1% below the GT ceilings and 9.9% below the kW ceilings, with these margins varying from 2% to 62%. In 2011 the number of vessels decreased by 2%, while tonnage and power decreased by 3.7% and 3.1% respectively. Reductions both in tonnage and in power were similar among Member States, with some variations (see Annex 3).

To ensure accuracy of the measurements in the fleet register, Member States are obliged to certify systematically new engines, and replacement and technically modified engines of more than 120 kW for vessels subject to an fishing effort regime as from January 2012 and all vessels as from January 2013. Member States must also undertake data verification on the basis of sampling plans. When information indicates that the engine power is greater than the power stated on the vessel's fishing licence, they have to undertake physical verifications.

A number of Member States have not met the deadlines for the measurement and monitoring. Some Member States are not complying at all with these monitoring obligations. Only a few Member States have adopted the required sampling plans for data verification. As of end November 2012 eleven Member States adopted a sampling plan for the verification of engine power, while nine Member States announced adoption in the near future. Two Member States have not yet done so.

The Commission attaches great importance to the respect of the Control Regulation. This is essential to ensure a level playing field across EU fisheries.

The European Court of Auditors published a Special Report in 2011 on the management of fleet capacity in the EU. The existing definitions of capacity were not considered reliable indicators of the ability of vessels to catch fish. The Commission is aware of the inadequacy of parameters such as GT and kW to capture technical progress, in addition to the practical difficulties in measuring engine power.

Decommissioning has been the most-used management tool to reduce capacity. The Commission estimates that close to €1.3 billion of EU funds will be used for decommissioning in the period 2000-2015, see Annex 4.

In analysing aid for decommissioning the European Court of Auditors concluded that decommissioning schemes that used public funding were not well targeted, and lacked clear eligibility and selection criterions. The Court concluded that scrapping of fishing vessels had little if any impact on the targeted fish stocks.

3. … and capacity indicators

Describing capacity of fleets in terms of engine power and tonnage has shown its limitations over time. Keeping these parameters within ceilings is not, in itself, evidence that fishing fleets are in balance with the state of the resources on which they depend.

Rather, the assessment of imbalances requires an analysis of the performance of the fleets in terms of the state of the resources on which they rely, in economic terms, and in respect to vessel utilisation. This analysis seems to be missing, in all or in part, in a number of the Member States' fleet reports.

Does a fishing fleet exploit stocks beyond what is sustainable? Do the vessels in the fleet on average earn enough to at least cover their short-term costs? Will vessel profitability be sufficient for replacement of ships and engines when needed? Are the vessels being used fully or are many often idle? These indicators can reveal an imbalance at fleet level.

This report summarises the efforts Member States are making to redress the problems and reviews what we know today beyond what Member States report.

A fleet that is operating sustainably and is economically viable:

· exploits stocks sustainably in the short term and in perspective of keeping exploitation below maximum sustainable yield levels,

· is profitable in both short-term and

· long-term perspectives; and

· is fully utilised, taking account of the seasonal nature of many fisheries in that vessels should normally be working actively.

The Commission has asked STECF to review EU fleets using indicators corresponding to the issues above. So far, and for reasons of time and resources, STECF has addressed only the 92 most important fleets in the 14 Member States with the biggest fisheries, but these cover 72% of EU income from landings, and are therefore indicative of the most important European fishing activities. STECF used the indicator values calculated from Member States' reports, DCF data, and fish stock assessments as appropriate.

The indicators used are listed below (for full description, see Annex 5).

Relied on stocks fished above MSY levels means that on average a fleet was fishing above sustainable levels in a long-term perspective. In the light of the CFP reform objectives, staying below MSY exploitation rates has been used as the standard.

Breaking even means that the fleet was earning enough to cover its short-term expenditure.

Economic underperformance means that in the long term the fleet was not earning enough to replace its large capital items (vessels, engines) when these wear out. Negative returns on fixed and tangible assets can be an indication of economic overcapitalization if observed consistently over a longer period of time.

Underutilised means that vessels were fishing, but were doing so 70% or less compared to the time they could have fished, taking account of the seasonal nature of the fisheries.

Inactive vessels refers to vessels that did not fish at any time during the year.

The indicators are based on averages for each assessed fleet segment. For example, individual economic performance of each vessel in a segment varies; vessels will be performing better or worse than the average values.

4. Fleet capacity by Member State

This overview of the fleet situation by Member State is based on the Member States' reports and findings of the STECF review for the period 2008-2011 where available.

The fleets in Belgium have reduced substantially since 2003, by reduction of existing licences and reallocation of fishing opportunities among the remaining vessels. Detailed information at fleet level was not provided. Belgium concluded that its fleets are in balance with fishing opportunities.

The STECF review indicates that the 18-24m beam trawl fleet on average was not earning enough to be able to replace its large capital items. Both this fleet and the 24-40m beam trawlers relied on stocks fished above MSY levels.

Bulgaria concluded that there seems to be almost a balance between the fish stocks and the fleet size. Bulgaria intends to take measures to reduce the inactive vessels and is currently in the process of changing the legislative framework.

In 2011 over 57 % of all vessels were inactive, most of them vessels smaller than 12m. All fleets above 12m appeared to show weak economic performance in the period reviewed due to higher fuel consumption and high fuel prices, even though they are breaking even. The vessels below 18m were underutilised, fishing at only 70% of the maximum possible fishing time.

Cyprus intends to reduce over-capitalisation by scrapping around 100 small inshore vessels whose effort remains unrestricted, after a decade of increasing the number of smaller vessels subject to effort limitations while reducing capacity in GT and kW.

Underutilisation has been reported in all fleets except for vessels with polyvalent passive gear 12-24m as well as low or negative returns on investments for all fleets.

There has been a substantial reduction in fleet capacity of Denmark (vessels, GT, kW) since 2003, on the introduction of the ITQ system. Denmark considers the situation is rather stable and that there is no significant long-term physical overcapacity. Denmark does identify overcapacity in the fleet using polyvalent passive gears 0-12 m and 12-24m, as well as in the fleets of smaller trawlers (the demersal trawlers and seiners 0-12 m fleet) and the dredgers 12-24m.

The STECF review indicates that all assessed Danish fleets relied on stocks fished above MSY levels. Three fleets were not earning enough to replace their large capital items (polyvalent passive gears 10-12 m and 12-18 m, mobile and passive gears 12-18 m). Two fleets (mobile and passive gear 18-24m, and demersal trawl and seine 18-24m) also showed underutilisation.

The report of Germany is not based on the existing guidelines and indicators. The balance was examined only qualitatively by fleet. Germany’s stated objective is to retain sufficient overall capacity to use their quotas. Reductions of 5.6% in vessels, 4.4% in GT, 6.4% in kW took place in 2011. No exits from the fleet were publicly funded.

The STECF review identified that the fleets using passive gear <10m, demersal trawls 12-18m, 18-24m, 24-40m and beam trawls 24-40m relied on stocks fished above MSY levels (but were economically sustainable). Vessels were underutilised and there was a large inactive fleet of smaller vessels (including 458 inactive vessels <10m).

Estonia reported overcapacity, mainly in the trawlers >12 meters. The fleet was reduced by 7 vessels in 2011 (eliminating 371 GT and 1056 kW).

The STECF review indicates that the pelagic trawlers 24-40m relied on stocks fished above MSY levels and had underutilisation, but were economically sustainable.

Greece has not presented an assessment of the balance, nor has it assessed its fleet policy or provided data under the DCF. Greece reported indications of overfishing for hake and shrimp in the Aegean Sea, but no details were provided. In 2011 the fleet reduced by 488 vessels (and decreased by 3.6% in GT and 4.0% in kW). Management plans including special licensing have been drawn up for bottom trawlers and for purse seine fishing (anchovies and sardines).

Due to lack of data (biological, economic, technical) it is impossible to assess the balance of the Greek fleets with the resources.

Spain reported that the capacity of the fleet still exceeded opportunities somewhat and that the fleet was capable of catching more than its allocated quota. Spain makes continued efforts to reduce fleet capacity both with and without public aid, adding up to 4.6% in GT and 3.7% in kW during 2011. Regarding the technical indicator, Spain reported underutilisation for part of the fleet in both national fishing zones and international waters, but observed a decreasing trend from 2008 to 2011. Information was only provided on current revenue/break-even revenue of the fleets. This is due in part to disaggregated data on catches not having been supplied. The national Spanish report states that all fleets are operating profitably. Subsidies received by ship owners were included in the calculation of income.

A comparable and objective evaluation of overfishing and of economic sustainability is not possible due to absence of data. The revenue calculated by STECF (which does not include revenue from subsidies) indicate that fleets using mobile and passive gears <10m, demersal trawls and seines 18-24 and 24-40m and hooks 24-40m and >40m did not break even.

France reported on mainland vessels together and concluded that most fisheries are in balance. Biological, technical and economic indicators were not provided. France decommissioned 133 vessels, 7653 GT and 20408 kW with public aid in 2011. Specific fleet exit plans resulted in the withdrawal of almost 60 vessels in different categories of sensitive fisheries.

The STECF review reveals a range of different situations. Fleets with drift and fixed nets <10m, 10-12m, 12-18m, 18-24m, 24-40m were relying on stocks fished above MSY levels - but appeared economically sustainable and breaking even in the period reviewed. The fleets with hooks 24-40m and polyvalent mobile gears 24-40m also relied on stocks fished above MSY levels. The indicators suggest weak economic performance during the years analysed.

Fleets using dredges 12-18m, pelagic trawlers 18-24m and >40m, demersal trawls and seines 18-24m, 24-40 m and >40m and purse seines >40 m also appeared to show weak economic performance in the period assessed. The fleets using pots and traps <10m, hook <10m, demersal trawl and seine 10-12m, demersal trawl and seine 12-18m on the other hand were economically sustainable but the state of the resources on which they depend is poorly known.

Ireland reported that some imbalances may remain in some fleets, but did not specify which. More work is needed on data availability.

STECF indicates that pelagic trawlers 24-40m were relying on stocks fished above MSY levels and were not earning enough to replace their large capital items. Pelagic trawlers >40m also relied on stocks fished above MSY levels and were underutilised, but they were breaking even and appeared to be economically sustainable. The fleets using dredges 10-12m and demersal trawls and seines 18-24 m appeared to show economic over-capitalisation. The fleet using pots and traps <10m appeared to be economically sustainable but the state of the stocks is poorly known.

Italy identified overcapacity in purse seiners and in bottom trawlers over 24 m and is planning a broad decommissioning scheme.

The STECF review indicates that the fleets using demersal trawls, seines 24-40m and beam trawls 24-40m were not earning enough to replace their large capital items, and the latter fleet also had low capacity utilisation. The fleets with polyvalent passive gear 6-12m, dredges and demersal trawls and seines 12-18m and 18-24m fleets appeared economically sustainable.

For most fleets knowledge on the biological situation of stocks is poor, making a review of reliance on stocks fished above MSY levels impossible.

Latvia reported overcapacity in the trawlers 12-24 m and 24-40m and in the netter 24-40 m fleet. The Latvian fleet decreased by 14.9% in GT and 14.3% in kW. Latvia had a permanent cessation scheme available for 2011-2012.

The STECF review indicates that the 24-40m pelagic trawlers were economically sustainable but relied on fish stocks that were fished slightly above MSY levels.

Lithuania aims to retain sufficient overall capacity to be able to fish its quotas. In 2011 the number of vessels was significantly reduced (- 12 %), but fleet capacity reduced only slightly in tonnage (- 1.6% GT), and hardly at all in engine power. Lithuania did not apply the indicators in its report.

The STECF review indicates that the fleets using 24-40m demersal trawls and seines did not fish overfished stocks, and was economically sustainable. There was, however, large underutilisation.

While Malta reported overcapacity for the whole fleet for 2009 and 2010, it was not conclusive for 2011 because of the absence of economic and social data. The Maltese fleet capacity was reduced significantly (- 32.8% in GT and 9.2% in kW).

Vessel utilization was less than 50%.

The Netherlands reported that some demersal vessels were rarely used and it would be possible to fish the available quota with fewer vessels. For the demersal sector the biological indicator is still somewhat above its target level, but moved into the right direction from 2008 to 2011. For the pelagic fleets, the biological situation was reasonably good in the Northeast Atlantic but fishing pressure on stocks targeted in West African and other distant-water fisheries was too high.

The STECF review indicates that all five assessed fleets other than beam trawl 18-24m relied on stocks fished above MSY levels. In addition, the demersal trawls and seines fleet was underutilised. The pelagic fleets showed signs of economic over-capitalisation.

Poland concluded that the fleet requires no further reduction. For central Baltic Sea herring, mainly caught by the pelagic trawlers of 24-40m, fishing mortality was too high. In 2009, there was noticeable improvement in economic indicators for the Baltic Sea fleet, except for longline vessels of 12-18m and demersal trawls of 18-24m. In 2011 2/3 of the Baltic Sea cod fleet received aid for temporary cessation. These vessels will soon return to fishing. 13.8% of the vessels were inactive, representing 16% of GT.

Portugal concluded that the fleets are in balance with fishing opportunities. In 2011 the total capacity of the Portuguese mainland fleet was virtually unchanged (a 1% reduction).

Large parts of the catches were made up of unassessed fish stocks. However, the indicators calculated by STECF showed that fleets relied on stocks fished above MSY levels.

The STECF review shows that the fleets with mobile and passive gears 0-10m, and hooks 24-40m fleets showed weak long-term economic performance. Fleets using polyvalent passive gears 0-10m, drift nets and fixed nets 12-18m, pots and traps 12-18m and purse seines 18-24m and 24-40m were underutilised. Fleets using polyvalent mobile and passive gears, with demersal trawls and seines and with hooks 24-40m were economically sustainable but no assessment of biological sustainability was available.

Romania did not submit a report for 2011. No Romanian DCF-data were available.

Slovenia reported overcapacity in most of its fleets. Slovenia plans to use public aid for scrapping in the first half of 2012, and to adjust fishing effort for various fleets.

The fleet was characterised by significant underutilisation, with 55% of the vessels being inactive, but this includes part-time fishing on migratory species.

Knowledge on the biological situation of stocks is poor and assessments are not available.

Finland did not apply the guidelines in its report nor were any other indicators included to assess capacity in relation to fishing opportunities. Finland stated that its fleet is in an acceptable balance with the fishing resources. In 2011 effort increased by 12.2% in relation to 2010, mostly in pelagic fisheries. From the 75 vessels of the offshore segment, 28% were inactive during 2011.

Sweden reported that overcapacity can still be observed in several fleets and is attempting to tackle this by decommissioning. Two schemes have targeted cod trawlers. A total of -26% in GT and -19% in kW was withdrawn from the fleet.

The STECF review indicates that many assessed fleets relied on stocks fished above MSY levels. In addition, the fleets using passive gears 10-12 m, and with demersal trawls and seines 24-40 did not earn enough to replace large capital items. There was underutilisation in some sectors.

The UK considers that many fleets operate sustainably because the resources they exploit are fished within the precautionary fishing mortality, though there is an imbalance in some areas (e.g. for stocks covered by recovery regimes). Since October 2010 a license parking facility has allowed fleets to restructure. The UK has reported on achieved capacity reductions, but does not present plans for further adjustments.

The STECF review indicates that many fleets relied on stocks fished above MSY levels. For the fleets using pots and traps <10m, and with demersal trawls and seines 12-18m, 18-24m and >40m no assessment of reliance on the resources is available, but these fleets were economically sustainable.

5. Conclusions

This review of the efforts of Member States to achieve a sustainable balance between fleet capacity and fishing resources proves that the capacity of Europe's fishing fleet is still too high. Despite reductions in the size of many European fishing fleets over the last decade, many vessels across a range of Member States did not break even financially and were underutilized. Many vessels also had too small revenues to make necessary investments such as modernisation of vessels and gears.

In the reviewed period too many fleets were dependent on overfished stocks with respect to maximum sustainable yield, one of the core objectives of the reformed CFP.

The current fleet management policy has failed to bring fleets into balance with the resources they exploit. It is not sufficient to rely on compliance with national capacity ceilings (expressed in vessel size (GT) or power (kW)) only.

Ensuring the balance between fleet capacity and fish resources is one of the key issues for reforming the Common Fisheries Policy. The primary responsibility for fleet management lies with the Member States. Potential consequences of overcapitalisation of fleets and continued reliance on stocks fished above maximum sustainable yield are the proof that we need better fleet management instruments under the reformed CFP. This requires that Member States manage their fleets to exploit fish stocks below maximum sustainable yield levels and in a way that enables them to be economically viable.

Annex 1: Quality of information

1 Qualitative and Descriptive Information

Areas of concern where no or limited information was provided in national reports are listed with (X) in the table below.

|| Link-ages between fleets and fisheries || Fleet development || Statement of effort reduction schemes || Impact of effort reduction schemes || Assessment of fleet management system || Plans to improve fleet management system || Statement of Compliance Entry/Exit scheme || Changes to admin. procedures || Assessment of balance

BE || || || X || X || || || || ||

BG || X || || || X || || X || || X ||

CY || || || || || || || || ||

DE || || || X || X || X || X || || || X

DK || || || || || || || || ||

EE || || || X || X || X || || || X || X

EL || || || || || X || X || || X || X

ES || || || || || || || || ||

FI || X || || || || || X || || X || X

FR || X || X || X || || X || || X || || X

IE || || || || || X || X || || ||

IT || || || || || || || || ||

LT || X || || || || X || X || X || || X

LV || || || || X || || X || || || X

MT || X || X || || || X || || || X ||

NL || || || X || || || X || || X || X

PO || || || || || X || || || ||

PT || || || || X || || || || ||

RO || X || X || X || X || X || X || X || X || X

SI || X || || || || || X || || || X

SE || || || || X || || X || X || ||

UK || X || X || || || X || X || || || X

Source: table 5.3 of report STECF-12-18 Review of national reports on Member States efforts to achieve balance between fleet capacity and fishing opportunities.

2 Quantitative Information

Evaluating the dependence of a fleet on stocks fished above MSY levels depends on the availability of quantitative fish stock assessments. These are available for most stocks in the Baltic and North Seas, but coverage in the Celtic Seas is incomplete. In the Mediterranean Sea many fleets fish on stocks of unknown status, but this area of knowledge is improving rapidly. While some Member States provided information on catch rates, this cannot be used to draw conclusions about sustainability.

Most Member States reports did not address questions of balance at the level of fishing fleets as defined in the DCF. This hampers quantitative evaluation of the balance as the data available do not correspond to the fleets being evaluated.

Data are also needed from Member States on the catches and the value of the catches for each fleet. This information is required by the DCF, but was not provided by all Member States.

Information on return on fixed tangible assets (ROFTA) was missing or incomplete for some Member States.

Information on the numbers of inactive vessels is available by length-class (irrespective of the target fishery or gear type) for most Member States from DCF data. However, the quality of this data source is in some cases questionable.

In the national reports, values of the technical indicator (the average vessel days-at-sea divided by the maximum for the fleet) were provided by most Member States but this information was not complete. Seven Member States did not provide technical indicator values in their national reports.

Annex 2:

Table 2.1: Compliance with the entry-exit ceiling at 31.12. 2011 (except outermost regions)

NB: Data extracted from the Union Fleet Register based on snapshot of 1.09. 2012 (Romania: snapshot of 1 March2012)

Annex 3:

Table 3.1. Member States' fleet evolution (vessels, tonnage and engine power) during 2011 (except outermost regions)

NB: Data extracted from the Union Fleet Register based on snapshot of 01.09. 2012 (Romania: snapshot of 01.03 2012)

Annex 4

Table 4.1. EFF commitments in permanent cessation (2007 – 31.07. 2012)

Source: MS data based on formal request by DG MARE (08. 2012) to submit cumulative EFF data for the period 01.01 2007 to 31.07. 2012)

%s: Percentage of EFF commitments so far in scrapping;

NS: Number of scrapping operations (vessels);

R%: Percentage of EFF committed to reassignment of vessels;

NR: Number of reassignments (vessels);

%S + %R: Total percentage scrapping + reassignment

Annex 5:

Indicators used by STECF

The 'sustainable harvest rate indicator' is an average of the fishing mortality rates experienced by the fish stocks exploited by each fleet, with the importance in the average weighted according to the economic importance of each stock in the catches. When this indicator equals 1, then on average the stocks are being exploited at a maximum sustainable yield rate. For values above 1, the fleet is, on average, relying on overexploited stocks and vice versa. This measure does not take account of the fact that some stocks in the mix of catches may be more or less seriously overexploited or depleted, nor does it take account of the extent of the impact of other fleets on the exploitation of the resources.

Two 'Economic sustainability indicators' are used. The Return on Fixed Tangible Assets (ROFTA) (a proxy for the Return on Investment) is a measure of long-term economic health. It measures the net profit divided by the value of capital investments. If this rate is higher than the risk-free interest available elsewhere (nominally 2%) then the fleet is in a healthy economic state and is able to replace large capital items as this becomes necessary. If the ROFTA is below 2% this means that such investments are not worthwhile in financial terms because greater gains may be obtained by investing funds elsewhere.

The ratio 'Current Revenue/Break-Even Revenue' (CR/BER) is a measure of short-term viability. If it is less than one then vessels cannot cover their operating costs and will have to stop fishing when they run out of cash; and above one the vessels can cover their operating costs, but this does not mean that they generate sufficient income to replace large capital items.

Two measures are used to assess whether vessels are 'fully utilised'. A 'Technical Indicator' is defined as the ratio of the average time spent at sea divided by the maximum feasible fishing time in the relevant activity. It takes a value of unity when all vessels are fishing as much as practicable, even though the fishing season may be short. Values less than one indicate that parts of the fleet are fishing less than they could. A threshold value of 70% is usually taken as a sign of a significant under-use. However, some vessels may not fish at all in the entire year and are 'inactive'. If there are many inactive vessels in a fishing fleet, this is an indication that the fleet is not in balance with the resources.

               Article 11 of Council Regulation (EC) No. 2371/2002

               As obliged under Article 14 of Council Regulation (EC) No 2371/2002

               According to Article 15 of Council Regulation (EC) No 2371/2002 and Article 11 of Commission Regulation (EU) No. 1013/2010 laying down implementing rules on the Union Fleet Policy as defined in Chapter III of Council Regulation (EC) No 2371/2002

               In accordance with Council Regulation (EC) No 199/2008 concerning the establishment of a Community framework for the collection, management and use of data in the fisheries sector and support for scientific advice regarding the Common Fisheries Policy

               Review of national reports on Member States' efforts to achieve balance between fleet capacity and fishing opportunities (STECF-12-18). In press 2012, JRC Scientific and Policy Reports.

               Article 7 and 8 of Commission Regulation 1013/2010 of 10 November 2010

               Romania not included.

               ECA Special Report No 12/2011 – Have EU measures contributed to adopting the capacity of the fishing fleets to available fishing opportunities? – paragraph 21 of the Report

               ECA Special Report No 12/2011 – Have EU measures contributed to adopting the capacity of the fishing fleets to available fishing opportunities? – paragraph 76 of the Report