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Page 1: MSFD reporting on monitoring programmes … · Web viewThe meeting of the ad hoc group on monitoring and reporting should aim to further develop and, where possible, agree the outline

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Marine Strategy Framework Directive (MSFD)

Common Implementation Strategy

Ad hoc group on monitoring and reporting

22-23 January 2013Venue: Avenue de Beaulieu 5, room 0/C, Brussels

Agenda item: 3

Document: AdHocMonitoring 2013/2

Title: Draft document on MSFD monitoring programmes – Concept and principle

Prepared by: ENV D2

Date prepared: 14/01/2013

Background Art. 11 provides legally binding requirements for Member States to establish and implement coordinated monitoring programmes for the on-going assessment of the environmental status of EU waters.

Therefore, MSFD CIS work plan 2012-2014, adopted at the Marine Directors meeting in June 2012, gave the mandate to:

- WG GES to initiate the development of a framework for coordinated monitoring programmes which will deliver data to assess whether GES and associated environmental targets are being achieved, in close cooperation with WG DIKE,

- WG DIKE to assist the Commission, when necessary, in developing any formal Commission proposal on notification / reporting modalities.

In the WG GES, initial discussions on monitoring were held at the JRC workshops on eutrophication/hazardous substances and on biodiversity (October and November 2012 respectively). In the WG DIKE an initial discussion took place at the 31 October 2012 meeting, mainly focusing on reporting structure. MSCG discussed monitoring issues on 13-14 November 2012, where several MS expressed their wish to discuss MSFD monitoring requirements in close cooperation between WG GES and WG DIKE, in parallel with the development of reporting sheets.

In that respect, a practical way to progress was agreed at Marine Directors meeting on 29 November. An ad-hoc group dedicated to the monitoring issue has been scheduled for 22-23 January 2013 gathering a limited number of WG GES and DIKE members

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(joint drafting group format). This group will start to discuss required monitoring elements and look at consequences for reporting.

This draft concept paper on monitoring has been prepared by DG ENV and JRC as a basis for discussion mainly based on the outcomes of the above-mentioned workshops. This document should be seen complementary to the document on monitoring reporting (AdHocMonitoring 2013/3).

The meeting of the ad hoc group on monitoring and reporting should aim to further develop and, where possible, agree the outline or key elements of this draft concept document with a view to bringing an elaborated version to WG GES (meeting in 4-5 March) and, in order to ensure consistency with the reporting approach, to WG DIKE (meeting in 18-19 March).

Ad hoc group on monitoring and reporting is invited to:

a. Agree on the main key message from the draft concept paper;

b. Refine the content of the draft concept paper;

c. Identify the relevant questions that should be further discussed by WG GES and, if need be, by WG DIKE;

d. Agree on timeline to further draft and improve the set of documents discussed at the meeting (draft concept paper, (JRC-led) guidance for monitoring, draft reporting approach/sheets) as outcome of the discussions to be presented to MSCG and endorsed by the Marine Directors in May 2013.

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Monitoring under the MSFD – concepts and principles

Address issues: Reporting Q uality assurance Governance Assessment monitoring link: risk and future assessment (boundary setting, confidence) Practical aspect

1. Introduction

An important milestone in the implementation of the Marine Strategy Framework Directive (MSFD – 2008/56/EC) is the establishment of monitoring programmes by 15 July 2014.

This draft concept document aims to set out some basic monitoring principles and to trigger a discussion within the MSFD Common Implementation Strategy with the aim of finalizing and agreeing this concept document by May 2013. A more detailed and technical JRC-led guidance document on MSFD monitoring could be developed in parallel and finalised at a later stage (end 2013). The guidance should be in accordance with this concept document. A draft outline for such a guidance document is presented in Annex 1. It could include examples, practical experiences, best practices and emerging knowledge and tools and build on the results of the JRC workshops (Annex 2).

Ref to existing docs…

2. Monitoring requirements of the Directive

According to Article 5 (2) (a iv) of Directive 2008/56/EC, an essential element for the preparation of marine strategies is the “establishment and implementation, by 15 July 2014 except where otherwise specified in the relevant Community legislation, of a monitoring programme for ongoing assessment and regular updating of targets, in accordance with Article 11(1)”.

Article 11 (1) then specifies that: “on the basis of the initial assessment made pursuant to Article 8(1), Member States shall establish and implement coordinated monitoring programmes for the ongoing assessment of the environmental status of their marine waters on the basis of the indicative lists of elements set out in Annex III and the list set out in Annex V, and by reference to the environmental targets established pursuant to Article 10. Monitoring programmes shall be compatible within marine regions or subregions and shall build upon, and be compatible with, relevant provisions for assessment and monitoring laid down by Community legislation, including the Habitats and Birds Directives, or under international agreements.”

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In addition, Article 11 (2) provides that “Member States sharing a marine region or subregion shall draw up monitoring programmes in accordance with paragraph 1 and shall, in the interest of coherence and coordination, endeavour to ensure that: (a) monitoring methods are consistent across the marine region or subregion so as to facilitate comparability of monitoring results; (b) relevant transboundary impacts and transboundary features are taken into account.”

Moreover, Annex V sets out a list of needs for monitoring programmes (see Annex 3).

Before the monitoring programmes are finalised and notified to the Commission, Member States must publish and consult the public on summaries of the programmes (Article 19 (2) (c)). Then, Member States have to notify (report) their monitoring programmes to the European Commission by 15 October 2014 (Article 11 (3)) and the European Commission has to assess these programmes within six months of receiving all those notifications (Article 12). An update of the monitoring programmes is required every six years, i.e. by 15 July 2020 at the latest (Article 17 (2) (c)). Finally, the Commission and the EEA must receive access and use rights in respect of data and information from the monitoring programmes (Article 19 (3)).

3. Key principles/messages

Key message 1: The core purpose for the establishment and implementation of the coordinated monitoring programmes is for the “on-going assessment of the environmental status”. All other elements of Article 11 (1) and (2) and Annex V are detailed specifications or conditions.

For this, we need to know and understand what good environmental status (GES) is and, conversely, what is not GES. An efficient monitoring programme should thus be established in close relation with a relevant definition of GES.… Add based on what MS did under Art 9….

Explanation on Key Message…

The main cumulative legal conditions to be taken as a whole in Article 11 (1) are as follows:

“the basis of the initial assessment made pursuant to Article 8(1)”: this means that all relevant elements of the initial assessment should be taken into account for designing monitoring programmes: characteristics, pressures/impacts, and socio-economic component and associated activities (

“on the basis of the indicative lists of elements set out in Annex III": this means the lists of characteristics and of pressures and impacts set out in Tables 1 and 2, which form the elements "may need" to be assessed against the objectives of the GES Descriptors. (link to art 8)

"and the list set out in Annex V”: this means that the monitoring programme should provide data that would support assessments in relation to Art 8, 9 and 10 (Annex V 1, 2, 5, 7, 8, 9, 10 and 12) but also to go a step further (Annex V 3, 4, 6, 9, 11 and 12) mainly in terms of measures and understanding global changes and natural variability. (link to reporting paper ?)

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“by reference to the environmental targets established pursuant to Article 10”: this means that monitoring will need to assess progress towards the achievement ofagainst environmental targets including operational targets linked to programme of measures, which themselves should enable assessment of progress towards achieving GES.

The monitoring programme outcomes would mainly be data to support, first and foremost:1 - Assessment of the achievement, failure and progress towards GES;2 - Assessment of the achievement of environmental targets.

In addition, and as long as it supports the assessments above, it should also:3 - Assess the state of the marine environment (characteristics, pressures/impacts);4 - Allow assessment of the impact (effectiveness) of measures (not in first cycle) and the identification of the activities that cause the changes observed.5 – Assess whether there are major changes in the environment, its natural variability and any new and emerging issues (Annex V.11) and natural variability (Annex V.12).according to Annex V.… monitoring programmes need to be adaptive…

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Key message 2: Coordinated monitoring programmes can be (is - statement) interpreted as coordinated within a marine (sub-) region and/or coordinated with other relevant monitoring programmes. Monitoring programmes should be established for the national part of a marine (sub-) region but then must be coherent and coordinated within the whole (sub-) region and be compatible within that whole area and with assessment and monitoring of other Community legislation. (shorter text)

Monitoring methods must be consistent so as to facilitate comparability of monitoring results, providing consistent data that can be aggregated across Member States. (Specific key message – draft DE with INSPIRE)

This is the main message of Art 11: monitoring programmes have to be "coordinated", "compatible", "coherent" and "consistent". (could be the key message and the box being the explanatory part)

Explain each word ("coordinated", "compatible", "coherent" and "consistent")

Ref to art 11.2 "transboundary"…

Further, Annex V (7), (8) and (10) refers to the need to "aggregate the information on the basis of marine regions or subregions", to "ensure comparability of assessment approaches and methods within and between marine regions and/or subregions" and "ensure compatibility with existing programmes developed at regional and international level".

Last, Annex V (9) together with Art 11.4 foresees wider harmonisation by defining "standardised methods at EU level". (see Ospar comments)According to Piha & Zampoukas (2011)1 some agreed methodologies exist but mostly for coastal waters and not for all indicators and marine regions.( take into account existing methodoly in RSC for Marine)

Key message 3: Do not start from scratch! Build upon and integrate, as much as possible, existing well established monitoring programmes fits for MSFD purpose under Habitats and Birds Directive, Water Framework Directive and other relevant EU legislation as well as under Regional Sea Conventions and other international agreements.

Whilst this message is self-evident, it should be applied in an exhaustive way, e.g. by extending (inclusion?) the WFD monitoring also outside the scope of the WFD rather than setting up a separate monitoring programme which is incoherent with the WFD approach2. In case of conflicts or incompatibilities, EU legislation monitoring methods should take precedent over international agreement monitoring.

1 Piha H, Zampoukas N. (2011). Review of methodological standards related to the marine strategy framework directive criteria on good environmental status. JRC Scientific and Technical Report. EUR 24743 EN. http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/16069/1/lbna24743enn.pdf2 WFD Guidance No 7 – Monitoring under the Water Framework Directive (http://ec.europa.eu/environment/water/water-framework/facts_figures/guidance_docs_en.htm)

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A gap analysis would be useful: risk and effort management through reduction of uncertainties…more clarity, less monitoring. It would then be useful to define different types of monitoring mainly based on WFD experience (see below).

Feedback process…

Key message 4

Should be adaptive… (Uli draft)

Key message 5

Risk management

Key message 6

State of maturity of monitoring programmes (Richard draft)

Key message 7

Inspire

Link to 19.3 (Dike work)

[4.] Relevant assessment aspects for monitoring

4-1. Scope: different areas of application within MSFD 'marine waters'

For some descriptors there should already be monitoring in place for other EU legislation. The table below shows an initial analysis of the MSFD descriptors that are sufficiently covered, partially covered or not covered by monitoring required by other EU law. These requirements are associated to the four different parts (zones) of MSFD 'marine waters', according to UNCLOS jurisdictions. This table

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considers the analysis in the related JRC report (Zampoukas et al., 2012)3.

Table title: Different areas for marine waters which require a different monitoring approach (designing)

Area Part of MSFD 'marine waters'

GES descriptors sufficiently covered by monitoring under other EU law

GES descriptors for which there is partial coverage by monitoring under other EU law

GES descriptors clearly not covered by monitoring under other EU law

1 Coastal waters (WFD) D5, D8, D9 D1, D2, D3, D4, D6, D7

D10, D11

2 Territorial waters (out to 12nm)

D8, D9 D1, D3, D4, D6 D2, D5, D7, D10, D11

3 EEZ or similar designation

D3 D1, D4, D6 D2, D5, D7, D8, D9, D10, D11

4 Continental shelf beyond EEZ (or territorial waters) – seabed and subsoil only

D3 D1, D4, D6 D2, D5, D7, D8, D9, D10, D11

(relevance to seabed/subsoil to be assessed)

Draft an explanation of Art 6 (How to take into account RSC)…

These different parts of MSFD 'marine waters' have a consequence for assessment and monitoring, e.g. no extra monitoring programme is needed for descriptor 8 in coastal and territorial waters as this should already be addressed under WFD and the EQS Directive. Some further analysis is needed for the other descriptors, especially considering relationships between MSFD reporting elements (Annex III features) and monitoring requirements of other EU legislation, to fully establish the links and synergies between MSFD requirements and existing monitoring obligations.

4-2. Methodology

The central aim of the monitoring programmes is to produce evidence to enable the assessment of environmental status and the related targets. This requires the monitoring programme of a Member State to collect data on different elements, i.e. biodiversity (species and habitats); physical, hydrological and chemical parameters; pressures and their impacts such as physical loss and

3 Zampoukas N, Piha H, Bigagli E, Hoepffner N, Hanke G, Cardoso AC. Monitoring for the Marine Strategy Framework Directive: Requirements and options. JRC Scientific and Technical Reports 68179; 2012. http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/23169/1/lbna25187enn.pdf

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damage, underwater noise, contaminants; human activities and effectiveness of measures taken (wrong place).

Each part of the monitoring programme should aim to collect data relevant for the GES criteria, targets and related indicators (as established by Member States under Article 9 and 10 and Decision 2010/477/EU). For each criterion/target/indicator, there needs to be a data (information) collection programme (info collection) which may involve at least: EEA presentation?

continuous recording of parameters (e.g. for physical parameters temperature, pH, etc); regular sampling/recording of parameters in certain intervals surveys (e.g. seabird surveys, trawl surveys) (may be one-off / discrete surveys, or repeated

periodically). Remote sensing continuous or on demand Modelling

4-3. Types of monitoring

A similar typology of monitoring programmes as the one of the WFD could be used: surveillance, operational and investigative. In the surveillance monitoring, it has to be defined what is needed: monitoring of state, against impacts, of pressures, of activities/measures. At the same time, some issues still need to be solved (what should be the balance of effort? what periodicity of monitoring is needed? what spatial coverage and intensity? how to aggregate the data? what role for ‘supporting’ information (e.g. one-off surveys)?)

There may be other types of monitoring such as “supportive” monitoring. These should be defined and agreed in the concept paper and further developed in the JRC guidance.

A first proposal would be to start from these four types:

Surveillance monitoring for GES

Operational monitoring for environmental targets

Supportive monitoring: characteristics, pressures/impacts

Investigative monitoring: gaps, specific questions, climate change….

4.[5.] Cost of the monitoring programmes

The Directive itself does not require an assessment of the cost and benefits of the monitoring programmes. However it is obvious that prioritising the monitoring programmes to address the most significant risks, and finding more innovative and efficient ways of doing the monitoring will be key assets to meeting the MSFD monitoring requirements in an environment of economic constraints.

One of the elements in this is the possibility for MS to cooperate in the implementation of the monitoring programme to reduce efforts and costs.

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Another element could be the development and use of models which are based on ground-truth monitoring but cover a much wider area against reduced costs.

Lastly, the potential to use monitoring by industry of the environmental effects of their activities (following initial impact assessments) can be an effective way to assess the nature and extent of impacts within marine waters. If such monitoring is done to specified standards, is quality assured and provides data that are compatible with other MSFD monitoring programmes, then it could reduce the costs to Member States. Such approaches are in place for some sectors in some countries.

5.[6.] Outcome of JRC workshops and preparation of JRC-led guidance document

The JRC workshops in October 2012 (on eutrophication and contaminants) and in November 2012 (biodiversity) discussed already in more detail the particular aspects of assessing and monitoring these descriptors. They were a platform to exchange ongoing work in the Regional Sea Conventions and the Member States and were useful for the preparation of this concept paper (see Annex 2 for summary of results). The concept paper is generic and introduces some conceptual considerations for policy makers and marine environment managers. However, when establishing a monitoring programme, more detailed technical information and specifications would be useful.

Building on this concept paper, it is proposed to prepare a more detailed technical guidance under leadership of the JRC. The technical guidance would take into account the results of the workshops, the existing and ongoing work under the MSFD Common Implementation Strategy (e.g. in the TSG marine litter or noise) and the work in the Regional Sea Conventions and the Member States. The guidance could develop the concepts in this document in more detail (e.g. the monitoring types) and include examples, practical experiences, best practices and emerging knowledge and tools with the aim to foster adequate, comparable, coherent and coordinated monitoring programmes under the MSFD. A draft outline for this JRD-led guidance document is enclosed in Annex 1.

The WG GES would be associated to this guidance development and discuss and agree at its next meeting the detailed process and timelines. The work could start already and envisage to be finalised by the end of 2013. The MSCG and then the Marine Directors would endorse the process, timelines and outline of the guidance in May 2013.

+ ref to other guidance

6.[7.] Questions for discussion

1 – Process Do we agree on the main outline of the concept paper? What are the relevant points to be addressed to WG GES and to WG DIKE? Which timeline to further draft and improve a relevant set of documents (draft

concept paper, (JRC-led) guidance for monitoring, draft reporting approach/sheets – see also document 3)?

2 – Content Do we agree on the main key messages for monitoring?

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Could we agree on the scope of the monitoring? Which types of monitoring should we consider?

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Annex 1

DRAFT OUTLINE FOR A JRC-led MONITORING GUIDANCE DOCUMENT ON MONITORING

Summary / outlook

1. INTRODUCTION

1.1 Aims of the guidance document

1.2 Definition of terms

1.3 What is included and what is out of the scope

Policy context

Involvement of RSC

2. OVERARCHING PRINCIPLES OF MONITORING

2.1 Adequacy (key principle 1)

2.2 Coherence / Interoperability (key principle 2)

2.3 Coordination of existing monitoring efforts (key principle 3)

3. STATE OF THE ART IN MARINE MONITORING

3.1 What is already monitored?

3.2 Coordination within and between OSPAR & HELCOMRSC

3.3 Transfer of knowledge between European Seas

3.4 List of recent relevant pilot project and research projects and contribution

4. TYPES OF MONITORING

4.1 Surveillance monitoring for GES

4.2 Operational monitoring for environmental targets

4.3 Supportive monitoring: characteristics, pressures/impacts (+activities)

4.4 Investigative monitoring: gaps, specific questions, climate change….

Cumulative effect…

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5. MONITORING TO BE FURTHER DEVELOPED

5.1 BIOVERSITY MONITORING (Descriptors 1, 2, 4 & 6)

5.1.1 How to aggregate monitoring data in space in time

5.1.2 Use of monitoring in MPAs

5.1.3 Available related biodiversity models

5.2. HYDROMORPHOLOGY MONITORING (Descriptor 7)

5.2.1 Identification of questions to address

6. MONITORING WITH EXISTING REFERENCE

6.1 MONITORING OF COMERCIALLY EXPLOITED FISH AND SHELLFISH POPULATIONS (Descriptor 3)

Reference and summary of the developments in the CFP and the work of ICES (+fisheries in Med)

6.2. EUTROPHICATION MONITORING (Descriptor 5)

6.2.1 WFD monitoring and considerations for monitoring out of the coastal waters (frequency and location of sites)

6.2.2 Data aggregation

6.3. CONTAMINANTS MONITORING (Descriptor 8 & 9)

6.3.1 Links with WFD and EQS

6.3.2 Open and deep-sea monitoring

6.3.3 Acute pollution events

6.4. LITTER MONITORING (Descriptor 10)

Reference and summary of the developments in the relevant Technical Sub-group

Feasibility / How to use the results? (TSG?)

6.5. NOISE MONITORING (Descriptor 11)

Reference and summary of the developments in the relevant Technical Sub-group

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7. GOOD PRACTICES

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Annex 2

Summary on the outcome of JRC workshops

1. Workshop on biodiversity descriptors (1, 2, 4 & 6)

It took place in Brussels on the 7 & 8 of November 2012 with 46 participants from Member States, Regional Seas Conventions, the European Commission, the EEA, ICES, stakeholders and research projects. Outcomes are summarized below:

There is an obvious need for coordination of monitoring for different policies. The initial assessment triggered such considerations and revealed available data sources and gaps. Some good practices exist but in many countries different “policy communities” are separated. The need to have access to CFP related data (VMS and logbooks) was highlighted. Sharing and particularly transfer of know-how from North to South is needed. There is some interregional cooperation but mainly in pilot projects and not in a regular basis. It is also needed to align time lines between different organizations (national, European, regional) that do or require monitoring in order not to duplicate work.

Key gaps in existing monitoring were identified in rocky bottoms, off-shore areas and for microbes, non-commercial fish species and non-indigenous species. Priority should be given in areas where there is a general lack of knowledge, where there are high pressures and where mitigation measures have been taken. MPAs also have a particularly role in setting monitoring programmes. Aggregation issues between different spatial and temporal scales were identified as particularly important.

Modeling tools are already been considered by several MSs but there are not many available for biological data and for pelagic habitats. Molecular techniques could also be considered and there is a huge potential for stakeholders and public involvement in monitoring. The need to map activities and pressures relevant to biodiversity was also highlighted.

2. Eutrophication – Contaminants Workshop

The JRC workshop on eutrophication and contaminants (descriptors 5, 8 and 9) took place at the Joint Research Centre in Ispra (Italy) on October 23 & 24, 2012. Discussions took place in group sessions for eutrophication and contaminants to identify main issues and gaps with respect to monitoring, as well as to propose way forwards. Outcomes are summarized below:

Eutrophication (descriptor 5)

A direct application of the assessment and monitoring methods deployed for the Water Framework Directive (WFD) varies substantially between Member States, with some limitations due to too much difference between water types under consideration in both WFD and MSFD Directives. There is a need to identify assessments Units in a consistent way, accounting for hydromorphological differences of water types.

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Also, the full suite of indicators as identified in MSFD for eutrophication are not systematically monitored by Member States for different reasons which need to be justified. Guidance on indicator prioritization is essential to ensure optimized monitoring effort. Due to lack of resources, open and deep marine water areas are currently much less sampled than the near coast systems. Best use of cost efficient monitoring alternatives (e.g.ship of opportunities, ferry box systems, satellite imagery) and large databases (e.g. GMES Marine Core Service, JRC-Environmental Marine Information System) can resolve some of the spatial gaps. More modelling effort is also recommended for optimizing monitoring programmes with respect to space and time.

Contaminants (descriptors 8 and 9)

A close cooperation between MSFD and WFD is envisaged. The experience from Regional Sea Conventions should be used and a harmonized approach should ensure coherence across Europe.

A three step approach for the implementation of the MSFD descriptor 8 on chemical contaminants is recommended. Within that, the relevant substances should be selected by taking into account WFD priority pollutants, substances listed in seafood regulation and other substances identified to be of relevance beyond WFD waters. The appropriate matrices, water and/or sediment and biota for monitoring the marine environment should be selected. Threshold values should be developed and set according to WFD guidance, which should take the characteristics of the marine environment fully into account. If WFD EQS are not available then other approaches could be considered.

The monitoring programs should be developed for selected contaminants and be compatible and integrated between MSFD and WFD. Different types of monitoring, such as trend, pressure, GES assessment and investigative monitoring should be included. The discussion about chemical monitoring strategies should be conducted under the MSFD CIS and have a close link with the WFD. Methodologies of monitoring, such as sampling and analytical procedures and their quality assurance/quality control should be harmonized in order to allow coherent assessments within and between marine regions.

Acute pollution events, such as significant operational oil slicks should be considered. A review of the on-going activities should be made and a common harmonized strategy be prepared. The role of biological effect monitoring and the technical issues regarding different approaches should be discussed in the existing forum in WG E under the WFD CIS.

Possible synergetic links between the monitoring under MSFD and under European Seafood legislation should be further discussed as well as possible benefits through information exchange between the monitoring authorities.

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Annex 3

ANNEX V

Monitoring programmes(referred to in Articles 11(1) and 24)

(1) Need to provide information for an assessment of the environmental status and for an estimate of the distance from, and progress towards, good environmental status in accordance with Annex III and with the criteria and methodological standards to be defined pursuant to Article 9(3).

(2) Need to ensure the generation of information enabling the identification of suitable indicators for the environmental targets provided for in Article 10.

(3) Need to ensure the generation of information allowing the assessment of the impact of the measures referred to in Article 13.

(4) Need to include activities to identify the cause of the change and hence the possible corrective measures that would need to be taken to restore the good environmental status, when deviations from the desired status range have been identified.

(5) Need to provide information on chemical contaminants in species for human consumption from commercial fishing areas.

(6) Need to include activities to confirm that the corrective measures deliver the desired changes and not any unwanted side effects.

(7) Need to aggregate the information on the basis of marine regions or subregions in accordance with Article 4.

(8) Need to ensure comparability of assessment approaches and methods within and between marine regions and/or subregions.

(9) Need to develop technical specifications and standardised methods for monitoring at Community level, so as to allow comparability of information.

(10) Need to ensure, as far as possible, compatibility with existing programmes developed at regional and international level with a view to fostering consistency between these programmes and avoiding duplication of effort, making use of those monitoring guidelines that are the most relevant for the marine region or subregion concerned.

(11) Need to include, as part of the initial assessment provided for in Article 8, an assessment of major changes in the environmental conditions as well as, where necessary, new and emerging issues.

(12) Need to address, as part of the initial assessment provided for in Article 8, the relevant elements listed in Annex III including their natural variability and to evaluate the trends towards the achievement of the environmental targets laid down pursuant to Article 10(1), using, as appropriate, the indicators established and their limit or target reference points.

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