Marine Strategy Framework Directive (MSFD) Common Implementation Strategy

Monitoring under Marine Strategy Framework Directive Recommendations for implementation and reporting

(Final version agreed by MSCG on 7 May 2013)

1 Foreword

The Marine Directors of the European Union (EU), Acceding Countries, Candidate Countries and EFTA Countries have jointly developed a common strategy for supporting the implementation of the Directive 2008/56/EC, “the Marine Strategy Framework Directive” (MSFD). The main aim of this strategy is to allow a coherent and harmonious implementation of the Directive. Focus is on methodological questions related to a common understanding of the technical and scientific implications of the Marine Strategy Framework Directive. In particular, one of the objectives of the strategy is the development of non-legally binding and practical documents, such as this recommendation, on various technical issues of the Directive. These documents are targeted to those experts who are directly or indirectly implementing the MSFD in the marine regions. The document has been prepared by a workshop of experts and following consultation of the Working Group on Good Environmental Status. It has been agreed by the Marine Strategy Coordination Group (in accordance with Article 6 of its Rules of Procedures).

The Marine Strategy Coordination Group will assess and decide upon the necessity for reviewing this document in the light of scientific and technical progress and experiences gained in implementing the Marine Strategy Framework Directive, in particular following the findings/results of the Art 12 assessment presented by the Commission in late 2013.

https://circabc.europa.eu/w/browse/f088529c-41a7-4b2e-b92a-e8838a6b3396

Disclaimer: This document has been developed through a collaborative programme involving the European Commission, all EU Member States, the Accession Countries, and Norway, international organisations, including the Regional Sea Conventions and other stakeholders and Non-Governmental Organisations. The document should be regarded as presenting an informal consensus position on best practice agreed by all partners. However, the document does not necessarily represent the official, formal position of any of the partners. Hence, the views expressed in the document do not necessarily represent the views of the European Commission.

2 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] document aims to set out some basic monitoring principles for the establishment of monitoring programmes under MSFD. It has been drafted following a discussion within the MSFD Common Implementation Strategy. A more detailed and technical guidance document on MSFD monitoring was developed in parallel which is in accordance with this concept document. It includes examples, practical experiences, best practices as well as emerging knowledge and tools and builds on the results of the JRC workshops held in autumn 2012. The present document has taken into account the following relevant existing documents: - 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.. http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/16069/1/lbna24743enn.pdf - Zampoukas N, Piha H, Bigagli E, Hoepffner N, Hanke G, Cardoso AC (2012). Monitoring for the Marine Strategy Framework Directive: Requirements and options. JRC Scientific and Technical Reports;. http://publications.jrc.ec.europa.eu/repository/bitstream/111111111/23169/1/lbna25187enn.pdf - WFD Guidance No 7 – Monitoring under the Water Framework Directive (http://ec.europa.eu/environment/water/water-framework/facts_figures/guidance_docs_en.htm)

2. 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.” 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 1). 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 resulting from the monitoring programmes (Article 19 (3)).

3 When referring to monitoring programmes, one should distinguish between three phases: establishing, implementing and reporting. It is important, however, that, as part of the implementation, Member States may need to update their national information system on how the monitoring programmes are actually carried out in case it is different from the ones that have been established and reported. Finally, monitoring programmes may, where appropriate, be divided into sub programmes to address different information needs in a structured way (see also reporting paper).

3. Recommendations Recommendation 1: The core purpose for the establishment and implementation of coordinated monitoring programmes is the "on-going assessment of the environmental status" and related environmental targets in accordance with the MSFD strategies and management cycles. All other elements of Article 11 (1) and (2) and Annex V are detailed specifications or conditions. To implement this, we need to know and understand what good environmental status (GES) is and, conversely, what is not GES (see also Common Understanding document on GES). We also need to know how far we are away from achieving GES and whether measures are effective to achieve GES. An efficient and effective monitoring programme should thus be established in close relation with a relevant definition of GES (namely Article 3.5, Annex I and Decision 2010/477/EC), based on what Member States did under Article 9, and with the environmental targets set by Member States under Art 10 MSFD, in particular those relating to pressures and measures. The main 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 Member States need to take into account all relevant elements of their initial assessments in designing their monitoring programmes e.g. characteristics, pressures/impacts, socio-economic component and associated human activities.  “ on the basis of the indicative lists of elements set out in Annex III": this means the lists of characteristics and pressures / impacts set out in Tables 1 and 2, which form the elements that may need to be assessed against the characteristics of the GES Descriptors.  "and the list set out in Annex V”: this means that the monitoring programmes should provide data and information that would support assessments of Member States marine strategies in relation to Art 9 and 10 (Annex V 1, 2, 5, 7, 8, 9, 10 and 12) but also may need to include information to assess the impact of measures and activities (Annex V 3, 4, 6) and information to assess major changes and natural variability (Annex V 11 and 12).  “ by reference to the environmental targets established pursuant to Article 10”: this means that monitoring will need to enable assessment of progress towards the achievement of the environmental targets established by Member States in their marine strategies including any 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 and information to support, first and foremost:

1 - Assessment of whether GES has been achieved or maintained, and if environmental status is improving, stable or deteriorating;

2 - Assessment of the progress towards achievement of environmental targets.

In addition, and as long as it supports the assessments above, the monitoring programmes should also support:

4 3 – Assessments of the state of the marine environment (characteristics, pressures/impacts) in accordance with MSFD Annex III; this means that through determining national indicators, a choice is made of those characteristics, pressures/impacts from Annex III that are relevant for national waters. With regards to, specifically, 2014 Monitoring Programmes, it must be taken in consideration that an additional outcome will be the generation of data to fill gaps, where possible, identified during the 2012 Reporting process (for articles 8, 9 and 10), to enable Member States to adapt their monitoring programmes, accordingly. Additional monitoring in relation to Annex III should be limited e.g. to environmental information that is necessary to put indicators and their message into context (e.g. oceanographic parameters relating to changes in the ecosystem) – see point 5 below – and to pressures and human activities. 4 - Assessments of the impact (effectiveness) of measures, at least for the second and following cycles, and the identification of the human activities that cause the environmental changes observed. A distinction should b e made between existing measures and additional measures (due to be operational by 2016). For the latter c ategory, assessment of effectiveness may realistically only be made for the third Art. 8 assessment (2024). 5 – Assess whether there are major changes in the environment, its natural variability and any new and emerging issues (as indicated in Annex V).

This requires the monitoring programme of a Member State to collect data and information on different elements, i.e. biodiversity (species, habitats, ecosystems); physical, hydrological and chemical parameters1; pressures and their impacts (such as physical loss and damage, underwater noise, contaminants), human activities and any other data needed for the effectiveness of measures (mostly starting in the second management cycle). Each part of the monitoring programme should collect data relevant for the GES criteria, targets and related indicators (as established by Member States under Article 9 and 10 by reference to Decision 2010/477/EU). For each criterion/target/indicator used, there needs to be a data and information collection programme which may involve for example:  continuous recording of parameters (e.g. for physical parameters such as temperature, pH);  regular sampling/recording of parameters at certain intervals;  surveys (e.g. seabird surveys, trawl surveys) (may be one-off / discrete surveys, or repeated periodically);  Remote sensing (continuous or on demand); The collection of data could include or be supported by modelling, where necessary, to aid data interpretation, the filling of information gaps and use in hind- and fore-casting.

When implementing all these elements, MS should strive for finding an appropriate balance between them to achieve more efficiency. Data from monitoring and other sources should also be used to support socio-economic considerations for Art 8, 13 and 14 MSFD. Such considerations require a sound data basis. To date the data basis is patchy. When necessary, additional statistical data should be collected for economic indicators on uses as well as for the costs and benefits of measures to provide the evidence base of evaluations e.g. of costs of degradation. While this is not necessarily part of marine monitoring, the need for statistical data should be supported by relevant data collection activities in the EU which should be streamlined accordingly for those purposes. Finally, the WFD monitoring concept differentiates monitoring (surveillance, operational and investigative) with respect to the purpose (state/impacts, pressures, activities/measures) and associated monitoring effort, reflecting observed environmental problems and thereby taking account of risk-based considerations. While for MSFD purposes such monitoring differentiation is not defined at the very outset, the principle idea of the WFD concept could lend itself to some elements of MSFD monitoring and help the approximation of monitoring approaches under various EU and regional frameworks. A common understanding of how EU Member States define their monitoring programmes is needed and justification should be given on how

1 Data on such parameters can be used to compile indicators

5 different elements of the monitoring programmes (e.g. frequency and density of sampling, parameters) are used and varied for different monitoring purposes (e.g. status assessment, progress of targets).

Recommendation 2: The monitoring programmes have to be "coordinated", "compatible", "coherent", "consistent" and "comparable" The use of the terms “coordinated”, “compatible”, “coherent”, “consistent” and “comparable” in the MSFD needs to be clarified. Based on the wording of the MSFD, different levels should be distinguished where thos e concepts work most appropriately: - Coordinated monitoring programmes, i.e. concepts, parameters2, monitoring cooperation; - Coherent monitoring/sampling strategies; - Consistent monitoring methods and standards; - Compatible monitoring requirements across legislation/frameworks; - Comparable and reliable monitoring methods and results. It is to be discussed whether all attributes act both between countries and between legislation/frameworks. For existing monitoring, further considerations should be given to the need for adjusting differing existing EU requirements and/or implementation by EU Member States where those differences hamper efforts to achieve comparable data. These issues can be addressed at national, regional or EU level as appropriate. To understand better how these terms could be used in the implementation, the following explanations are provided: "Coherent" (Art 5.2 – 11.2 – 12 – 13.4 – 16)3 could be applied where monitoring programmes established for the national part of a marine (sub-)region are compared to those within the whole marine (sub-)region or across the EU "Compatible" (Art 11.1) could be applied for monitoring programmes established for the national part of a marine (sub-)region within areas with the assessments and monitoring of other Community legislation. "Coordinated" (Art 3.9 – 5.2 – 6.1 – 7.1 – 11.1 – 11.2) could be applied for monitoring programmes with neighbours and to the extent possible and necessary with third countries sharing the same marine (sub-)region and/or with other relevant monitoring programmes as a process to achieve coherence and compatibility, plus efficient and effective use of resources. Regional Sea Conventions (RSC) should play a crucial role in this process. Coordination within and between RSCs is therefore a key for a successful implementation. The level of coordination could be measured through the level of inclusion of elements agreed in RSC in national monitoring programmes. If Member States use the agreements made in the RSC in their national reports (without modifications), these monitoring programmes can be considered as coordinated. "Consistent" (Art 8 – 9.3) could be applied for monitoring and assessment methods to be designed so as to facilitate comparability of monitoring results, hence providing data fit for aggregation across Member States sharing the same marine (sub)region and across different scales (see also Recommendation 7). “ Comparable” (Art 11.2 – 11.4) refers to monitoring and assessment approach, methods and also to monitoring and assessment results including data that have to be interoperable and INSPIRE compliant (see also Recommendation 4) Again, these criteria may not necessarily be coordinated bilaterally, but can also be jointly organised within the framework of RSC or on pan-European level. For fisheries-related monitoring existing coordination

2 Based on the needs as defined by MS under art 8, 9 and 10 3 Only Art 1.4 talks about coherence between policies and legislation

6 mechanisms such as Regional Coordination Meetings held under the Data Collection Framework, or coordination through ICES should be used where possible. Moreover, Art 11.2(b) highlights the need for taking into account relevant transboundary impacts and transboundary features. 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". Lastly, Annex V (9) together with Art 11.4 stipulates that "standardised methods at EU level" are one possibility to allow and improve comparability of information. According to Piha & Zampoukas (2011), some agreed methodologies exist but mostly for coastal waters and not for all indicators and marine regions. Existing methodologies in Regional Sea Conventions and international standards from ISO and CEN should be taken into account.

Recommendation 3: Build upon and integrate as much as possible, existing well-established monitoring programmes and relevant guidance under Habitats and Birds Directives, the 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 learning from the philosophy (or concept) and using relevant components of WFD monitoring also outside the geographical scope of the WFD (taking appropriate account of differences in geographic scale, ecological character and pressure differences) rather than setting up a separate monitoring programme which is not coherent with the WFD approach. The same applies mutatis mutandis to monitoring established in the context of the Habitats and Birds Directives. This does not replace the need to address MSFD aspects not covered by the WFD or HBD (e.g. zooplankton and other biodiversity features, noise, litter). This could also lead to reflections on the evolution of the current WFD and HBD monitoring programmes, for example to better address some marine issues jointly for WFD, HBD and MSFD. In case of conflicts or incompatibilities of specific marine monitoring methods, recommendations adopted under Regional Sea Conventions and other international agreements should not take precedence over EU law for those contracting parties that are also EU Member States. For some descriptors there should already be monitoring in place for other EU legislation. The table below shows an initial overview of the MSFD descriptors that are considered to be 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 considers the analysis in the related JRC report (Zampoukas et al., 2012).

7 Table 1: Initial overview for each Descriptor of which areas of marine waters are addressed, partly addressed or not addressed at all by existing EU legislation. Area Part of MSFD 'marine GES descriptors that GES descriptors for GES descriptors waters' could be sufficiently which there is insufficiently covered by partial coverage by covered by monitoring monitoring monitoring requirements under requirements under requirements under other EU law other EU law other EU law 1 Coastal waters (WFD) D5, D84, D9 D1, D2, D3, D4, D6, D10, D11 D7 2 Territorial waters5 D86, D9 D1, D3, D4, D6 D2, D5, D7, D10, D11 3 EEZ or similar D3 D1, D4, D6, D9 D2, D5, D7, D8, D10, designation D11 4 Continental shelf D3 D1, D4, D6, D9 D2, D5, D7, D8, D10, beyond EEZ (or D11 territorial waters) – (relevance to seabed and subsoil seabed/subsoil to be only assessed) Note: D1 (biodiversity), D2 (non-indigenous species), D3 (commercial fish species), D4 (food webs), D5 (eutrophication), D6 (sea floor integrity), D7 (hydrographical conditions), D8 (contaminants), D9 (contaminants in seafood), D10 (marine litter) & D11 (Introduction of energy) For descriptors which could be fully or partially covered by obligations under other EU legislation, a specific and more detailed analysis needs to be carried out as part of the technical guidance. From the results of such analysis, MS redesigning of existing programmes under other EU legislation may be necessary to better fit with the purpose and overarching framework of MSFD. These different parts of MSFD 'marine waters' have a consequence for assessment and monitoring, e.g. no or limited extra monitoring may be needed for descriptor 8 in coastal and territorial waters as this should already be addressed under WFD and the EQS Directive. Further analysis is needed for the other descriptors, especially considering relationships between MSFD reporting elements (Annex III features and COM Decision 2010/477/EU) and monitoring requirements of other EU legislation, to fully establish the links and synergies between MSFD requirements and existing monitoring obligations. It would also be useful to look for modern tools in addition to traditional ship-based monitoring such as airborne surveillance (e.g. under the BONN agreement for the North Sea and airborne surveys under the Habitats Directive), ships of opportunity, ferry boxes and moorings in order to increase temporal and spatial resolution. The aim is an appropriate cost-effective mixture including bi- or multilateral cooperation in the regions to achieve better resolution in time and space and to reduce costs. Furthermore, the aspects of monitoring which are not currently addressed should be identified and addressed by appropriate actions. Furthermore, a risk- and effort-based management of the monitoring programmes would increase (cost-) efficiency and reduce uncertainties (see also Recommendation 6).

4 Except for indicator 8.2.2 in Decision 2010/477/EC 5 In most cases, this will be 12nm 6 Except for indicator 8.2.2 in Decision 2010/477/EC

8 Recommendation 4: Data and information resulting from the monitoring programmes should be made available in a comparable format and for interoperable use taking into account the "Marine Knowledge 2020"7 process. This means that in accordance to the requirements of Article 11 2. (a) (Monitoring methods are consistent across the marine region or subregion so as to facilitate comparability of monitoring results): a) Data and information from monitoring programmes need to be made accessible to the EU Commission in a format that supports the EU Commission in the performance of its tasks in relation to the Directive, in particular the review of the status of the marine environment under Art. 20(3)(b) MSFD, (see Art 19.3). b) Monitoring data should be described with standard compliant, sufficient and comprehensive metadata and should be made available in accordance with the INSPIRE Directive c) Data and information concerning commercially exploited fish stocks should be made accessible in a format convenient to ICES and to STECF To ensure such comparability, all data from MSFD monitoring should aim to be interoperable and INSPIRE compliant, fulfil certain minimum quality standards and that institutes conducting the monitoring should have quality control management systems established in accordance with EN/ISO/IEC 17025 or equivalent internationally accepted standards. This will be facilitated through the longer term process to support the implementation of Art 19.3 MSFD which will, ones its strategy has been agreed, facilitate the work of member States to deliver the next Art 8 assessment due in 2018. Under the Marine Knowledge 2020 initiative, the Commission has set out a vision of a seamless multi- resolution digital seabed map of European waters by 2020. This will aim to be of the highest resolution possible, covering topography, geology, habitats and ecosystems and accompanied by access to timely observations and information on the present and past physical, chemical and biological state of the overlying water column, by associated data on human activities, by their impact on the sea and by oceanographic forecasts. The aim is that this should be easily accessible, interoperable and free of restrictions on use. It should be nourished by a sustainable process that progressively improves its fitness for purpose and helps Member States maximise the potential of their marine observation, sampling and surveying programmes. Marine Knowledge 2020 is therefore aiming to ensure that authorities from Member States can benefit not only from data collected solely for the purpose of satisfying the requirements of the Marine Strategy Framework Directive but also data collected by others including the research community and those responsible for safe navigation or coastal protection. There is also an ongoing discussion as to how data from the private sector can be incorporated. As part of this initiative over a hundred organisations from Member States have created a European Observation and Data Network (EMODnet) facilitating access to harmonised data, metadata and data products ranging from seabed sediments and habitats through to chemical pollution in the water column, sediments and biota. Authorities in Member States are encouraged to engage with the Marine Knowledge process making data and information collected in the context of the MSFD available through EMODnet. The practical implementation of the link between MSFD aspects and EMODnet are mainly discussed in the working group on Data Information and Knowledge Exchange.

Recommendation 5: Monitoring programmes need to be adaptive to enable appropriate reaction on e.g. changes in the marine environment, new understanding and emerging issues. Annex V of the MSFD, in particular point (11) and (12) identify the need to assess major changes in the environment, its natural variability and any new and emerging issues. The monitoring programmes need to

7 Green Paper: Marine Knowledge 2020: from seabed mapping to ocean forecasting COM(2012)473

9 be reviewed regularly (at least every six years) and be designed in such a way that they can be easily and timely adapted to these changing conditions as well as to changes in the determination of GES, environmental targets, the evaluation of risks and technical and scientific developments. In particular, it will be important to factor in the increasing challenges for management of the marine environment as a result of the climate changes.

Recommendation 6: Linking monitoring to assessment needs, including the use of risk-based approach and the precautionary principle8, as the basis of a flexible monitoring design.

In a risk-based approach, flexibility is needed on the choice of elements and parameters/indicators, frequency and density of sampling, depending on the varying risks from anthropogenic pressures in the different regions to maintaining or achieving GES. Art 14.4 introduces the concept of “significant risk”; a lack of such risk would exempt Member States from taking specific steps in relation to elements of the marine strategies referred to in Art. 5(2). As this potentially includes monitoring programmes, further discussions are necessary in the context of the MSFD CIS to improve common understanding. The use of a risk-based approach also has relevance to the application of the precautionary principle. This states that where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation. Based on this, there may situations where it is appropriate to apply the precautionary principle in the development of monitoring programmes e.g. within the context of managing risk, the choice on what to monitor and how intensively may be adapted or where there is a high degree of uncertainty, e.g. regarding emerging pressures. It might also be necessary, as the state of the marine environment is approaching the boundary for GES, an adjustment of the monitoring design for the underlying parameter(s) may be necessary to improve precision of the monitoring results and support conclusive statements about (non)achievement of GES. This may include changes in monitoring programme design to increase confidence in the assessment results or to refine the threshold boundary for GES.

Recommendation 7: Take account of the differences in scientific understanding for each descriptor in the monitoring programmes. To ensure that monitoring programmes used by Member States reflect best practice and scientific understanding, it is necessary to recognise that our understanding of the various GES descriptors, criteria and indicators are at different levels of maturity. The guidance document will assist in the identification of the latest scientific state of the art when designing monitoring programmes. Furthermore, the monitoring programmes in 2014 should include specific targeted monitoring activities (e.g. investigative monitoring) or initiate research to enable a full assessment of the issues at stake by 2018 with a view to establishing, or revising and adapting, monitoring programmes by 2020.

4. Costs, benefits and governance of the monitoring programmes The Directive itself does not require an assessment of the cost and benefits of the monitoring programmes. H owever it is obvious that prioritising the monitoring programmes to address the most significant risks, and fin

8 See COM (2000) 1 on the precautionary principle http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2000:0001:FIN:en:PDF

10 ding more innovative and efficient ways of doing the monitoring will be key assets to meeting the MSFD mon itoring requirements in an environment of economic constraints. This implies specific work because prioritis ation should take place at theme and indicator level in order to respond to environmental problems and asse ssment / management needs. One criterion for prioritisation is the relevance of criteria and indicators for me asures / pressures as they directly link back to management. The Commission is currently assessing the potential monitoring costs and saving potentials through implementation of the Marine Knowledge 2020 agenda. Currently available estimates are considered to significantly underestimate the costs9 involved as, in many cases the decisions on new monitoring programmes have not yet been made and hence, it is difficult for the Member States to provide estimates at that stage. It should also be noted that the resources needed are closely associated to the extent of the marine waters and the level of pressure and impact which take into account the relationship between water surfaces per habitant within each Member States. Despite this, a Commission research study indicates that the benefits of marine monitoring outweigh the costs by far, e.g. by reducing the cost of degradation, improving effectiveness of measures and demonstrating the added value of the marine ecosystem services. One of the elements in this is the possibility for Member States to cooperate in the execution of the monitoring programme to reduce efforts and costs. There is opportunity for the EU to contribute to cost- efficiency through the Copernicus marine core services by offering data products in relevant resolutions for national and regional uses in support of the MSFD. Another element could be the development and use of models which are based on ground-truth monitoring but cover a much wider area and 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 environmental 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 countries10. As part of this exercise, the development of integrated multi-disciplinary monitoring programmes should aim to maximise the use of existing resources (e.g. ship time), by improving the efficiency of existing programmes (i.e. use of spare capacity). In support of integration and cost-efficiency, existing monitoring requirements of EU legislations should be explored for streamlining and adjustment. Furthermore, the current and future Marine Research Infrastructure can be used more efficiently and there are EU programmes in place to support this11. Moreover, joint monitoring programmes in (sub) regions may help forge synergies between Member States on the ways in which they are monitoring and assessing the marine environment, and which can potentially reduce overall costs. The Commission intends to encourage cost reduction by incentivising the pooling of national resources on a regional level in the next generation of legislation concerning the collection of fisheries-related data (data collection multiannual programmes). Decision-making tools may also help design effective and efficient monitoring programmes (e.g. to determine the spatial and temporal resolution needed or possibilities for integration of techniques). This is part of several pilot projects or research projects that are currently delivering where this concept could be tested. Finally, it should be clear how the governance of monitoring programmes is organised (e.g. clear attribution of responsibilities, allocation of resources etc…). There should be also clear coordination arrangements in case of various administrations playing a role in the implementation of the monitoring programmes. The

9 [Draft] report from the study: https://webgate.ec.europa.eu/maritimeforum/content/3252 Current results indicate that MSFD monitoring will cost in the order of 65-72 million Euros per year (including 20 million for new monitoring programmes). 10 \\net1.cec.eu.int\Env_Units\U51\1.ADMIN\1.3 BUDGET & FINANCE\1.3.5 CLOSED CONTRACTS\2010 SI2. 579390 SER_MILIEU_MSFD_ Year 1\4. Reports\FINAL REPORT\Industrial monitoring report final.doc 11 For more detail, refer to the Final Report of the MRI Expert Group “Towards European Integrated Ocean Observation”, January 2013.

11 answer to these questions will allow streamlining existing resources, increase transparency and enhance accountability amongst other benefits.

5. Outcome of workshops and preparation of technical guidance document The workshops organised by the Commission Joint Research Center 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 on-going work in the Regional Sea Conventions and the Member States and were useful for the preparation of this concept paper. 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, a more detailed technical guidance is developed. The technical guidance takes into account the results of the workshops, the existing and on-going work under the MSFD Common Implementation Strategy (e.g. in the TSG marine litter or noise), the work in the Regional Sea Conventions and the Member States and the relevant guidance under other EU legislation (in particular WFD and Habitats and Birds directives). For RSC, their role has to be clearly defined. The guidance develops the concepts in this document in more detail (e.g. the monitoring types) and includes examples, practical experiences, good practices and emerging knowledge and tools with the aim to foster adequate, comparable, coherent and coordinated monitoring programmes under the MSFD. An outline for this technical guidance document is enclosed in Annex 1.

6. Reporting Article 11(3) provides "Member States shall notify the Commission of the monitoring programmes within three months of their establishment" (15 October 2014). The Directive assumes that Member States are basing their monitoring programmes on the specifications of article 9/ 10 and 8 reported in 2012. If Member States modify their GES criteria or targets and adapt their monitoring programmes accordingly, an update needs to be reported to the Commission to be consistent. The 2012 report also includes gaps in knowledge and 2014 monitoring programmes can generate data to feed into the update process. Following the experience during the first round of MSFD reporting in 2012, the approach has to be improved in developing the appropriate reporting formats as regards both timelines and process. Therefore, the content of the reporting formats, including development of schemas and database tools, should be developed well before the reporting deadline of 15 October 2014. Before discussing the details of reporting on the monitoring programmes, it is important to recall the main purpose of reporting and the joint objective and interest that the European Commission and the Member States, together with the Regional Sea Conventions (RSC) and the European Environment Agency (EEA), should have in making reporting a success and an important exercise which is worthwhile investing in. The uses and benefits of reporting at national, regional, European and global levels are outlined in Approach to reporting for the Marine Strategy Framework Directive (2012)12. The requirement in EU legislation to report is a result of the legal system of the EU and the special role of the European Commission in this system, namely its role as "Guardian of the Treaty". However, this role has to be seen increasingly in the wider context of accountability and good governance of EU action and the responsibility for the European Commission and the Member States together to demonstrate that:  EU legislation achieves its results in an effective and efficient manner;

12 http://ec.europa.eu/environment/marine/publications/index_en.htm

12  The level of ambition, efforts and level playing field for the internal market are comparable, if not harmonised, between the Member States;  Member States respect the letter and the spirit of the law;  Effective policy implementation leads to the envisaged policy objective, which in this case is the improvement of the state of the marine environment leading to GES. For these purposes, comparable reporting information is a prerequisite. Any flexibility that is introduced in the reporting system (e.g. text fields, options) is counterproductive to achieving these purposes. This issue should be distinguished from acknowledgement that Member States have some flexibility in developing their monitoring programmes and that some programmes may need to be further improved and refined after 2014. However to assess the reporting of monitoring programmes, the information needs to be made available in a consistent, comparable format. Another important change is that the process has started with a discussion of the assessment purpose and questions to be answered in order to fulfil the Article 12 assessment of Member States notifications on monitoring programmes. The questions, related to the provisions of the Directive, are an essential starting point for developing reporting requirements for Article 11. In summary, when setting up Article 11 monitoring programmes, it is most important that the Member States consult the public and demonstrate to the Commission the extent to which they have set up their MSFD monitoring programmes in a way which is "complete, adequate, consistent, coherent and coordinated". These are the headline criteria which need to be assessed and the results presented as a key part of the Commission's Article 12 report. More detailed are provided in Annex 2 (general approach for reporting) and Annex 3 (assessment questions).

7. Conclusion The stage of developing and establishing monitoring programmes under the Marine Strategy Framework Directive (MSFD) is an important stepping stone between the assessment and objective setting (article 8, 9 and 10) and the preparation of measures (article 13). Member States do not have to start from scratch because the existing monitoring programmes under EU legislation (e.g. Water Framework Directive, Habitats Directive or Data Collection Framework) and the Regional Sea Conventions as well as other existing monitoring can and should be used. However, the MSFD does require going beyond “business as usual” and introduces new challenges for those who have to design and implement these monitoring programmes. This document lays down seven general recommendations which, if applied, should ensure an effective and efficient implementation of the Directive. Thereby this should help Member States in the achievement of the Directive’s objectives in such a way that they can allocate the increasingly sparse resources in public administrations in the best possible way. The European Commission, the EU Member States and the international organisations, stakeholders and NGOs which have been involved in the preparation of this document are confident that through following these recommendations, we have made another important step towards achieving clean, healthy and productive seas and a sustainable use of the marine waters of the EU.

13 Annex 1 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.

14 Annex 2

Reporting on monitoring programmes under MSFD Article 11 Introduction Following the finalisation of the first stage of MSFD implementation, i.e. delivery of initial assessments, GES determination, targets and indicators by Member States under Articles 8, 9 and 10, the focus of work under the MSFD Common Implementation Strategy is now shifting towards the preparation of monitoring programmes, as required by MSFD Article 11. Learning from the 2012 reporting process, the Marine Strategy Coordination Group (MSCG) agreed to follow a slightly different approach to addressing reporting of monitoring programmes. through a close collaboration between the Working Group on Good Environmental Status (WG GES) and WG DIKE to ensure better synergy between development of principles and concepts of monitoring and the preparation of reporting requirements. Complementary to the concept paper, the present paper presents the approach to reporting (general considerations and process for reporting under Article 11) and lists (see annex 4) a list of questions arising directly from the requirements of the Directive and which form the basis for the reporting by Member States to the Commission together with the identification of the relevant criteria for the Commission’s Article 12 assessment of the Member State reports on monitoring programmes. Approach Following the experience during the first round of MSFD reporting in 2012, DG Environment proposes to change the approach in developing the reporting sheets as regards both timelines and process. The Marine Directors supported the idea that, as much as possible, the content of the reporting format should be largely finalised by May 2013 so that the detailed technical work, including development of schemas and database tools, can take place after that with enough time for completion well before the reporting deadline in October 2014. In this context, it is important to recognise the different steps in the development of reporting requirements and their timelines (Table 1). Table 1: Timelines for development of reporting on monitoring programmes for MSFD Drafting group to refine Reporting Format and 4 June 2013] testing arrangements. Schema development, tools development Written procedure on content of Reporting Format – By end July need DIKE to agree RS before Schema development Preparation of user-friendly database module and By end September 2013 xml schemas Testing of database module and xml schemas By end October 2013 Finalisation of database module and xml schemas By end December 2013

Another important change is that the process has started with a discussion of the assessment purpose and questions to be answered in order to fulfil the Article 12 assessment of Member States notifications on monitoring programmes. The questions, related to the provisions of the Directive, are an essential starting point for developing reporting requirements for Article 11 (see Annex 3). In summary, when setting up Article 11 monitoring programmes, it is most important that the Member States consult the public and demonstrate to the Commission the extent to which they have set up their

15 MSFD monitoring programmes in a way which is "complete, adequate, consistent, coherent and coordinated". These are the headline criteria which need to be assessed and the results presented as a key part of the Commission's Article 12 report. In order to undertake the Article 12 assessment, these headline criteria need to be reflected into a set of questions which can be structured in a meaningful way in topics, such as: a. General aspects, including public consultation and additional information; b. Links to Article 8, 9, 10 and 13 (including relevant annexes); c. Links and streamlining with monitoring programmes from existing EU directives (e.g. Water Framework, Birds and Habitats Directives) and conventions; d. Programme scope and methodology.

These topics are used to structure the questions in Annex 3. Amongst the "compliance indicators" (which are formulated as assessment questions in the Annex 4), the most relevant one is:  Will the monitoring programmes provide adequate data and information to enable the "ongoing assessment of environmental status" and assessment of progress against the related Article 10 environmental targets? (see Recommendation 1 in the concept paper). Other important assessment questions are:  Are the monitoring programmes coherent, coordinated, compatible, consistent and comparable? (see Recommendation 2);  How have existing monitoring programmes which address aspects of status of the marine environment, in particular for EU legislation (e.g. WFD, Habitats and Birds Directives) and international agreements (including Regional Sea Convention programmes) been integrated with MSFD requirements? (see Recommendation 3). Finally, all these assessment questions can be complemented with a fall-back situation: "if not, what is the Member State doing to implement this and by when?" All this is elaborated in more detail in Annex 4, which also gives reference to the criteria (completeness, adequacy, consistency and coherence) relevant for use in the Commission’s Article 12 assessment. However, this assessment needs to be developed further and should be agreed as part of the reporting guidance. Links to other elements in the MSFD marine strategies The fulfilment of monitoring programmes under Article 11 needs to be seen as part of the overall process of the marine strategies required by the Directive, with consequent linkages, in particular, to Articles 8, 9, 10 and 13. In terms of reporting, this indicates that linkages should be made to relevant elements of the reports for Articles 8, 9 and 10 and, in future cycles, also to reports on measures for Article 13. As reporting has been undertaken by Member States for their respective parts of each (sub-)region, this structure will be maintained for Article 11; for those Member States with several (sub-)regions, a way should be found to enable reporting information to be readily repeated in several (sub-)regions if needed. A second key link is to the provisions of Article 19(3) which requires inter alia that data and information from the monitoring programmes is made available to the Commission and European Environment Agency (EEA). In this context it is important to distinguish between the information that should be reported under Article 11 (about the programmes) and that which is more appropriately associated to Article 19(3) (about the data and information emanating from the programmes, including metadata on the surveys, methods and resultant data). The relationship can be represented as shown in Figure 1. Note that data collected during monitoring programmes are often processed into 'data products' for use in (indicator) assessments. For Article 19(3) it may be more appropriate to provide access to such 'products' rather than the unprocessed data, but this need to be determined via the process for implementation of Article 19(3).

16 Figure 1: Indicative relationship between reporting on monitoring programmes under Article 11 and giving access to the data and information emanating from the monitoring programmes according to Article 19(3). Note that data are often processed into 'data products' for use in (indicator) assessments. It may be more appropriate to provide access to such 'products' rather than the unprocessed data, but this needs to be determined via the process for implementation of Article 19(3).

Reporting for Art. 11 MSFD Monitoring Programme

Monitoring / Implementation of monitoring programme

Data

Data products / Implementation of Art. 19.3 information - access for EC and EEA - INSPIRE compliance

Links to monitoring for other Directives and the Regional Sea Conventions Monitoring undertaken in relation to the Water Framework, Habitats, Birds and other EU Directives for example the Data Collection Framework, is often of direct relevance to programmes needed for MSFD, i.e. these programmes may be considered by the Member State to directly contribute to MSFD monitoring

17 needs. In such cases, there needs to be an explicit cross reference from the MSFD programme to the programmes under other Directives within the reporting under MSFD, whilst ensuring that reporting is complimentary rather than duplication. Additionally, there may be monitoring programmes established under the auspices of Regional Sea Conventions or in other international frameworks that the Member State considers contribute to MSFD needs. These should be explicitly reported under Article 11, where relevant. Decentralisation and coordination of reporting information The reporting process for the monitoring programmes should be used to introduce the possibility (at this stage as an option) for Member States to publicly present information on their monitoring programmes in such a way that can also be directly used for reporting at EU level. Such pre-defined information (e.g. presented as ‘fact sheets’) would need to be prepared in a structure that follows the reporting approach (based on what is outlined in this document) and answers the assessment questions (such as those listed in Annex 1). Also some of the information should be available in an interoperable format (e.g. xml file) so that it can be downloaded and used for analysis purposes by the Commission (alongside equivalent reports from Member States who continue to report into ReportNet). Ideally, such 'fact sheets' would be designed in such a way that they also fulfil other purposes, e.g. for the work of the RSCs, for national implementation and for the public consultation process. Table 2 outlines a possible way in which the information needed at national, regional and EU level could be developed in an integrated manner. Member States are required under the Directive to coordinate their monitoring programmes to ensure they are coherent, consistent and comparable/compatible within each (sub-)region. Whilst the reporting of these programmes remains a Member State responsibility, it is possible to prepare the required reporting information jointly (such as within the Regional Sea Convention framework). This would have the advantage of clearly demonstrating to the Commission the level of coordination achieved (as the MS reports would hold the same information), and could potentially reduce effort as only one report per programme need be prepared for the sub(region) for all relevant Member States. Table 2: Outline of how requirements of reporting to the Commission (Art. 11 and 12) could be integrated with requirements of Member States (e.g. national implementation, Art. 19(2) public consultation) to ensure synergy and minimise reporting efforts. Commission use of Directive MS response: information MS response: information for Reporting question information: Art. 12 requirement for national purposes reporting to Commission assessment Simplified and categorised Text-based (or other response/values etc. for Criteria used for Art. format) used for national Reporting Sheet 12 assessment: Question: e.g. Which purposes and for Art 19.2 completeness, e.g. Art. 11.1, e.g. Yes/No/Partly/Unknown target does the consultation adequacy, e.g. Annex V.3 programme address? Could follow a consistent Information needed by consistency, format (e.g. Fact Sheet Commission to assess coherence, approach) consistency and coherence of coordinated MS reports Information held by MS and Reporting sheet information in updated as need, but See annex 3 for xml format. File could be held accessible by Commission proposed questions. To by MS and accessed by Comments for Art. 12 assessment. be finalised as basis for Commission OR reported into Equates to information that Reporting Sheet ReportNet (as per existing MS use for notification system) under Art. 11(3). Possibility for MS to jointly prepare reporting information Regional where monitoring programmes have been developed jointly consistency for a (sub-) region, e.g. within an RSC or other international framework.

18 Annex 3

Analysis of needs from reporting on MSFD monitoring programmes The following tables provide an analysis of the relevant articles and annexes of the MSFD that relate to monitoring programmes. This has been used to develop a proposed set of questions that the Member State reporting should address, addressing in particular the text of the Directive highlighted in yellow. The questions are organised into a logical sequence, starting with some broad generalised questions relating to the monitoring programmes as a whole and then a set relevant to each programme (i.e. likely to differ per programme). The final column in the tables indicates how the questions could relate to the criteria used in the Commission's Article 12 assessment, thus providing a direct link to how the information reported by Member States could be used by the Commission. The details of the assessment methodology for answering the question and the related data needs will need to be developed as a next step. Headline questions: Will the programme enable the ongoing assessment of environmental status, including distance from and progress towards GES and whether environmental status is improving, stable or deteriorating, and at least, differentiated per descriptor (Art. 8 with regard to Art. 9)? Will the programme provide suitable and sufficient data/information to enable assessment of progress with the environmental targets (using specified indicators with reference points) established under Art. 10 and enable their regular updating, at least, differentiated per target and indicator? General questions:

19 20 Directive Directive text Questions for reporting Art. 12 criterion

1. On the basis of the initial assessment made pursuant to Article 8(1), Member States shall Question 1 establish and implement coordinated monitoring programmes for the ongoing assessment of Do the monitoring programmes as a whole the environmental status of their marine waters on the basis of the indicative lists of constitute an appropriate framework to meet elements set out in Annex III and the list set out in Annex V, and by reference to the the requirements of MSFD? Article 11.1 environmental targets established pursuant to Article 10. If not, what further development is needed: Monitoring programmes shall be compatible within marine regions or subregions and shall t build upon, and be compatible with, relevant provisions for assessment and monitoring laid  What are the significant monitoring Completeness n e down by Community legislation, including the Habitats and Birds Directives, or under gaps in Annex III coverage? What plans Adequacy m international agreements. s are there to fill the gaps and by when? s

e Consistency s  What are the significant monitoring s On the basis of all the notifications made pursuant to Articles 9(2), 10(2) and 11(3) in respect A gaps in GES Descriptor and criteria Coherence of each marine region or subregion, the Commission shall assess whether, in the case of each coverage? What plans are there to fill Member State, the elements notified constitute an appropriate framework to meet the the gaps and by when? Article 12 requirements of this Directive and may ask the Member State concerned to provide any additional information that is available and necessary.  Which targets (from MS art 10) are not In drawing up those assessments, the Commission shall consider the coherence of addressed by the monitoring frameworks within the different marine regions or subregions and across the Community. programmes? What plans are there to fill these gaps and by when? n o i t a t

l 2. Member States shall publish, and make available to the public for comment, summaries of Question 2 u s the following elements of their marine strategies, or the related updates, as follows: n Article 19.2 Completeness o When (dates) and how (web link) has a public C c i (c) the monitoring programmes established pursuant to Article 11(1); consultation been undertaken? l b u P 1. In order to achieve the coordination referred to in Article 5(2), Member States shall, where practical and appropriate, use existing regional institutional cooperation structures, including those under Regional Sea Conventions, covering that marine region or subregion. 2. For the purpose of establishing and implementing marine strategies, Member States shall, within each marine region or subregion, make every effort, using relevant international forums, including mechanisms and structures of Regional Sea Conventions, to coordinate their actions with third countries having sovereignty or jurisdiction over waters in the same Question 3 marine region or subregion. Article 6 Where can additional information be found (e.g. In that context, Member States shall, as far as possible, build upon relevant existing via a web link) on the following: programmes and activities developed in the framework of structures stemming from international agreements such as Regional Sea Conventions.  Regional cooperation on monitoring programmes (if information is Coordination and cooperation shall be extended, where appropriate, to all Member States in additional to that already provided the catchment area of a marine region or subregion, including land-locked countries, in order under article 6, 7, 8, 9 and 10) to allow Member States within that marine region or subregion to meet their obligations n under this Directive, using established cooperation structures prescribed in this Directive or in  Consideration of transboundary o i t Directive 2000/60/EC. impacts and features in monitoring a programmes (Article 11.2b) m r Article o f (b) relevant transboundary impacts and transboundary features are taken into account.  The ability of the monitoring Adequacy

n 11.2b i

programmes to identify major changes l Coherence 21 a in the environment (Annex V.11) n (11) Need to include, as part of the initial assessment provided for in Article 8, an assessment o i

t Annex V.11 of major changes in the environmental conditions as well as, where necessary, new and i  The ability of the monitoring d emerging issues. programmes to identify new and d

A emerging issues (Annex (5) Need to provide information on chemical contaminants in species for human consumption Annex V.5 V.11)Information on chemical from commercial fishing areas. Programme-level questions: Question 7 (3) Need to ensure the generation of information allowing the assessment of the impact Annex V.3 of the measures referred to in Article 13. Will the programme monitor:  relevant activities and/or their 3 1

pressures (spatial distribution, .

t (4) Need to include activities to identify the cause of the change and hence the possible r intensity and frequency), which are A

Annex V.4 corrective measures that would need to be taken to restore the good environmental causing environmental changes, to Adequacy o

t status, when deviations from the desired status range have been identified. enable the identification of possible s

k measures, if needed? n i L  relevant measures to determine their (6) Need to include activities to confirm that the corrective measures deliver the desired Annex V.6 effectiveness (impact) in relation to changes and not any unwanted side effects. delivering desired changes in environmental status? 1. 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

g reference to the environmental targets established pursuant to Article 10.

n Article 11.1

i Question 8 r

o Monitoring programmes shall be compatible within marine regions or subregions and t

i With which monitoring programmes under

n shall build upon, and be compatible with, relevant provisions for assessment and Adequacy

o Community legislation or international monitoring laid down by Community legislation, including the Habitats and Birds

m agreements is the programme compatible? Directives, or under international agreements. g n i How has this been implemented? t

s (10) Need to ensure, as far as possible, compatibility with existing programmes i

x developed at regional and international level with a view to fostering consistency e

o Annex V.10 between these programmes and avoiding duplication of effort, making use of those t

s monitoring guidelines that are the most relevant for the marine region or subregion k

n concerned. i L

22 Methodology Article Article 11.2a Annex V.9 Annex V.8 Annex V.7 Community levelCommunity (9) technical Need specifications to develop and standardised methods monitoring for between regions subregions.marine and/or (8) Need to 4.withaccordance Article (7) Need to facilitate of comparabilitymonitoring results (a) coordination, endeavour to ensure that: programmes paragraphin with accordance 1 and in shall,the and of interest coherence 2.Statessharing marine subregionMember shalla region draw or up monitoring monitoringmethods consistent aretheregion across or marine to subregion so as aggregate onthethe aggregate information of regions basis marine or subregions ensure comparability of ensure comparability assessment approaches within and methods and , toso as, allow comparability of informationallow of comparability ; . in at at nationalscale),give reasons? If datacannot(beyondaggregated the be the environmental assessments? At databe which scale theforaggregatedcan Question 10 In particular: consistency and comparability? How monitoringprogrammedoes the ensure Question 9           Other EU Region Subregion being used? andproceduresQAQCWhatare is Whattheof sampling?frequency this area? is Whattheof withinsamplingdensity (sub-) region)? (withinprogrammeMS the waters of is Whattheof coverage thespatial measured andmonitored are which parameters components, pressures) Which elements (e.g. ecosystem monitoring (data collection)? is Whatusedthe method for ? are are Coherence Adequacy 23