German opinion on "marine knowledge 2020"

Herr Generaldirektor,

ich beehre mich, Ihnen hiermit eine Mitteilung der Regierung der Bundesrepublik Deutsch¬land vom 12. Mai 2011 zu der oben bezeichneten Angelegenheit zu übersenden.

Genehmigen Sie, Herr Generaldirektor, den Ausdruck meiner ausgezeichneten Hoch¬achtung.

Schuldt

Im Auftrag

TRANSLATION from Commission's Translation Service (POETRY)

Communication

from the Government of the Federal Republic of Germany

to the European Commission

of 12 May 2011

Subject: Communication from the Commission to the European Parliament and the Council 'Marine Knowledge 2020' COM(2010) 461 final

The Government of the Federal Republic of Germany hereby sends the Commission the following comments:

In its communication 'An Integrated Maritime Policy for the European Union' of October 2007, COM(2007) 575 final, the European Commission had already announced steps to set up a European Marine Observation and Data Network. The German Government shares the view expressed by the Commission in its Sep­tember 2010 communication on this that knowledge of the oceans and seas is the key to sustainable and smart growth and that this knowledge has to be improved so as to become an effective instrument of integrated maritime policy.

We welcome the fact that the European Commission, with its communication 'Marine Knowledge 2020', is proposing measures to improve this knowledge, add to it and make it more easily accessible. The contents of the communication do, however, call for more detailed consideration, and our position is as follows:

1. From the German point of view, it is important that MK 2020 should not become a new initiative for collecting and compiling marine data. Existing projects and systems must be used and extended if necessary. MK 2020 must begin with better coordination of the INSPIRE Directive, Water Framework Directive (WFD), Marine Strategy Framework Directive (MSFD) and the WISE / WLSE-Marine and EMODnet systems, to avoid duplication of effort.
2. Another important point is that data should be collected and made available according to demand. If a demand should arise due to existing legal requirements (e.g. MSFD, Fisheries Data Framework Regulation), the new 'basin checkpoints' to be set up could define on the basis of a Council Decision which data are required in order to close the knowledge gaps for certain sea basins in a targeted manner. Attention should be paid at the same time to compatibility and consistency with other sea basins. It makes no sense, in particular, to collect and supply all available marine data in an untargeted way. Existing data resources should be used for collecting the data required, and assembling new data resources should be avoided if possible.
3. The system should be implemented in the form of a geodata infrastructure with distributed data resources. The data remain with the services responsible for keeping geodata and are maintained and updated there. Current OGC and ISO standards are to be complied with in doing so. Introducing special standards would lead to duplication of and maybe even conflict with standards already applied, and so should be avoided.
4. The German Government considers that for the operation of a European marine data infrastructure a secretariat is usefully employed only if in addition to the traditional tasks of a secretariat it also performs coordinating functions, ensures the operation of the network of distributed systems and cooperates with the group of independent experts as well as the yet to be formed group of experts from the Member States. It must then also carry out the usual secretarial duties of preparing meetings, evaluating results, ensuring deadlines are met and drafting reports. In setting up such a secretariat, the most efficient and economic option of those proposed in the European Commission's impact assessment should be selected. At all events, setting up a completely new structure should be ruled out for reasons of cost.
5. In many Member States a start has been made with building up coastal information systems. Germany, too, has begun construction of its Marine Dateninfrastruktur Deutschland (MDI-DE). The aims and measures of this national project, initially set at three years, largely coincide with those of the MK 2020 initiative.
6. We would point out once again that knowledge of the seas and oceans cannot be achieved only by extending and if necessary optimising the provision of data. This can only be one step in that direction. In order to build up the body of knowledge required, the data have to be analysed and interpreted by competent specialists with sufficient knowledge of the local circumstances to be evaluated.

The German Government comments as follows on the other measures in the Commission's communication to the European Parliament and the Council:

1. • We welcome the fact that data from EU‑supported regional development programmes and marine research programmes will be made more readily available.
   • We are glad that thought is being given to measures to promote coastal data systems. Targeted funding should be used to try to harmonise the data resources, improve interoperability and secure a better data base which will meet the legal requirements and cover further requirements agreed by the competent EU decision-making body.
   • We see involving WISE-marine and EMODnet as problematical. With the WISE‑marine system the 'electronic reporting' required by the MSFD will be implemented. This work is being coordinated inter alia by the European Environment Agency (EEA). EMOD­net was designed as a data management system geared to INSPIRE and making possible efficient data access. The question as to whether linking these systems makes sense technically and is economically feasible with a view to the overarching objectives defined by INSPIRE should be resolved with the assistance of the EEA's Eionet.
   • We welcome the fact that the EU's Agencies will regularly release data from the marine research projects in the EU framework programme – even from outside the EU bodies.
   • The steps planned by the Commission to coordinate the various initiatives are an essential prerequisite for the successful construction of a European marine data system:
     • common standards must be assured;
     • the aim must be to provide free access and unrestricted use of the data;
     • it must be ensured that data assembled in initiatives such as EMODnet can be used for the MSFD;
     • the in-situ data gathered in EMODnet must be used for validating GMES data and for covering waters not dealt with by GMES;
     • thought must be given to cooperation beyond the borders of Europe and with partner countries and international organisations, in order to develop an interoperable global marine knowledge system.
   • The two statements that data should be maintained as close to the sources as possible and that they should be stored in accredited data centres contradict each other. As already mentioned, due to its federal structure Germany supports decentralised data storage.
   • We welcome the setting up of consortia for assembling data into thematic assembly groups. It should be ensured that this work is done in close cooperation with the expert groups for the relevant themes of INSPIRE in order to avoid duplication of effort in building up harmonised data resources.
   • We think an integrated viewpoint at sea‑basin level and cooperation with existing regional organisations are necessary in order to address the regional needs of the respective sea basins. Conventions such as OSPAR and HELCOM, as well as EuroGOOS and other initiatives should be taken into account.
   • The German Government sees it as critical and unnecessary for some marine data – even limited to a small number of cases – to be analysed and possibly re‑evaluated by the EU. The task of data analysis is carried out at national level e.g. by the drafting of reports in the framework of the MSFD.
   • MK 2020 talks about the need for a decision-making process but does not suggest a measure for implementing it. As described above, a coordinating body should prepare such tasks together with the group of independent experts and a group of experts from the Member States. The decision-making process must be at a level that has the competence to decide on the necessary financial framework.
   • It would be desirable for the industry to be involved in gathering marine data and for it to publish its data as well.
   • We welcome the setting up of a communication platform by the Commission for the exchange of information between the Member States. Such a platform should in turn be organised and made available by the above-mentioned 'basin checkpoint'.
   • We think it necessary for so-called 'basin checkpoints' to be set up. A useful way to gain a better idea of the demands of these facilities will be to set up pilot stations. We are assuming that pilot stations will be set up for the North Sea and the Baltic Sea taking account of existing networks and structures.
   • We think it necessary to set up a group of experts from the Member States. This is important for the cooperation with the basin checkpoints, work on the communication platform, etc.
   • he term 'basin' is unclear. It is used to mean 'sea basin' or 'sea area'. As integrated coastal zone management is also referred to, it should be clearly defined what these terms mean. The terms 'basin checkpoints' and 'secretariat' should also be more clearly defined as regards tasks and competences.

The measures mentioned in the MK 2020 document are to be carried out between 2011 and 2013. If this is to be achieved it is absolutely essential to draw up a roadmap of the work packages showing the resources and milestones allotted to them.

The content of MK 2020 is as at 2010. The information available from various meetings of working groups concerned, e.g. the Member State Expert Group on Integrated Maritime Policy, already goes beyond that given in MK 2020. Planning for the MK 2020 initiative is already further advanced, so document MK 2020 is in need of an update.