Consultation outcome

Summary of responses and government response

Updated 14 December 2023

Introduction 

This document summarises the responses received to the public consultation to the joint England and Wales sea bass (Dicentrarchus labrax, hereafter ‘bass’) fisheries management plan (FMP), held between 17 July and 1 October 2023, and sets out the government’s response.  

Consultations took place at the same time on 5 other FMPs. A number of broad, cross-cutting themes from the consultation responses, which are relevant to all FMPs, are also addressed in this document. 

This document has three main parts: 

• Introduction – context and a high-level overview of the consultation 
• Summary of responses – summaries of themes and comments received as part of the consultation 
• Government response – sets out the government’s response and intentions 

The summary of responses and government response are divided into separate sections covering the FMP and associated environmental report. 

As noted in the consultation, the UK has some of the best wild seafood resources in the world. Our fish stocks are a public asset that generate food and recreational enjoyment and create jobs in a sector with a strong sense of identity and pride in its communities. These stocks form a vital part of our marine ecosystems and natural capital.  

Many of our fish stocks are under pressure from fishing and climate change. Fishing can also have a negative impact on the marine ecosystem, for example through accidental bycatch or the effects of fishing gear on the seabed. It is therefore important to consider all the effects of fishing as part of our overall management of the marine environment. 

FMPs are a requirement of the Fisheries Act 2020 (‘the Act’). The Environmental Improvement Plan (EIP) for England 2023 also sets out the important role of FMPs in the sustainable management of our fish and shellfish stocks. Welsh Government published the Environment (Wales) Act 2016 which provides an iterative framework to ensure managing our natural resources sustainably is a core consideration in decision-making. Central to the Environment (Wales) Act is the need to adopt a new, more integrated approach to manging Wales’s natural resources to achieve long-term sustainability.

FMPs assess the status of stocks and set out policies and actions to restore stocks to, or maintain them at, sustainable levels. As set out in the Joint Fisheries Statement (JFS), where appropriate, these plans will contribute towards wider objectives under the Act. 

The bass FMP has been prepared and published to comply with the requirements in the JFS and in section 6 of the Act. The preparation process had regard for:  

• the prevailing Marine Plans (as required by section 58(3) of the Marine and Coastal Access Act 2009) 
• the Environmental Principles (as required by sections 17(5)(a-e) and 19(1) of the Environment Act 2021) 
• the requirement for strategic environmental assessment under the Environmental Assessment of Plans and Programmes Regulations 2004 

The plan is joint with Welsh Government; therefore, it has also been prepared and published to comply with:  

• the Environment (Wales) Act 2016 (section 6(1))  
• the Well-being of Future Generations (Wales) Act 2015 (sections 3-5) 
• the Environmental Assessment of Plans and Programmes (Wales) Regulations 2004

Background to the consultation 

The consultation on the bass FMP and environmental report ran for 11 weeks from 17 July until 1 October 2023. 

The consultation was conducted using Citizen Space (a UK government online consultation tool), by email and through a series of online and in-person engagement events. The analysis given in this summary is based on the responses to the consultation provided through all of these channels.

Overview of responses 

In total, 255 direct responses to the consultation were received, 188 were submitted via the Citizen Space online survey and 67 via email. 

The breakdown of responses consisted of: 

• 137 (54%) from the recreational sea fishing sector 
• 44 (17%) representatives from the catching and producing sector 
• 28 (11%) from individuals 

• 29 (11%) from other sectors 

• 8 (3%) from interest groups 
• 2 (1%) from the science and research sector 
• 1 (1%) from the marine industry sector 
• 6 (2%) sector not stated 

Out of 255 responses, 108 formed a part of two separate coordinated responses. While individual responses have been logged, we have removed duplicates from the overall analysis.  

Stakeholders that selected ‘Other sectors’ included Inshore Fisheries and Conservation Authorities (IFCAs), public bodies, other governments, and environmental non-government organisations (eNGOs). However, there was some crossover with the ‘interest group’ category, with some of the same stakeholder groups selecting this option instead. A list of organisations who responded to the consultation is set out in Annex 1. 

We also engaged with over 300 people at 23 in-person meetings where stakeholders were given the opportunity to discuss the draft bass FMP. A list of meeting locations is included in Annex 2. 

Online meetings were also used to gather views from a wide range of sectors and stakeholders including the catching sector, the wider supply chain, eNGOs, scientists, academia, EU attachés to the UK, and others interested in fisheries management.   

The Welsh Government hosted two online events for stakeholders in Wales. 

These engagement events were used as an additional method by which to seek and record views on the FMP. This input was particularly important considering the time of year (summer fishing season) and volume of domestic fisheries consultations held. Views and comments from these meetings were treated as part of the consultation and are summarised below.

Methodology 

Due to the broad scope of the FMP and the qualitative nature of responses, an analysis based on the themes of responses was conducted. Using an iterative approach, each response was analysed twice to identify the topics raised by stakeholders and policy recommendations put forward. We have summarised each response, which has been used to produce the overall summary of responses outlined below. 

Comments and views were noted at in-person and online meetings. These notes were cross checked and then analysed using the same iterative process. Views from these engagement events have been included in the summary below and have been considered equally alongside the email and online responses.

Headline messages 

The high number of responses to the bass FMP consultation demonstrates the importance of this species to a wide variety of stakeholders across England and Wales, and echoes the high levels of engagement with the Department of Education’s multi-disciplinary Policy Lab’s bass FMP stakeholder phase in the development process. The consultation responses reflect the diversity of views and sometimes conflicting priorities of those with an interest in bass fishing.  

The bass FMP seeks to balance these concerns and priorities by outlining a plan to develop an improved management approach that delivers for stakeholders while ensuring stock sustainability. Although the bass stock has increased in recent years and is currently fished within sustainable limits, we recognise it remains a vulnerable stock, with recruitment still low and reduced International Council for the Exploration of the Sea (ICES) advice for 2024. The bass FMP commits to ensuring fishing pressure remains within sustainable limits aligned with ICES scientific advice (within 95% confidence intervals). 

The bass FMP places increased stakeholder engagement at the heart of our approach to future stock management with the establishment of a bass management group (or groups), so that stakeholders can continue to participate as the FMP enters the implementation phase. We will seek to ensure those with an interest in the bass fishery are adequately represented in the management group, and we welcome the willingness of many consultation respondents to engage with the process. However, it will also be important to keep the group (or groups) to a manageable size, to support effective collaborative working.  

Many of the views expressed by stakeholders to this consultation will be captured within the various reviews of management measures in the bass FMP. This will include reviews of:  

• the most appropriate size limits – such as a minimum conservation reference size (MCRS) or slot sizes 

• closed seasons for the stock 

• inshore and shore-based netting regulation 
• the current authorisation system 

For example, the review of the authorisation system will consider who should be able to land bass, which gear types should be used, and whether improvements are needed to the way that the authorisation process works and is enforced. 

In recognition of the importance of this issue to many stakeholders, the netting review will be brought forward to become a short-term priority. It will seek to ensure adequate protections are in place to minimise the bycatch of sensitive species and migratory fish associated with netting, while reducing the bycatch and discarding of dead bass.   

We will also bring forward actions on developing gear modifications for nets and trawls to reduce bycatch and discards, which could include consideration of appropriate mesh sizes as well as the use of other appropriate technologies to reduce bycatch. While many stakeholders called for the introduction of a minimum mesh size to improve gear selectivity, we note that a 100mm minimum mesh size is already in place for fishers who land bass bycatch. We will update appropriate guidance to better reflect this.  

Further, we will bring forward actions on the production of fish-handling guidance and on ensuring better consistency and clarity of approach between regulators to improve compliance with bass regulations. 

We note calls from the recreational sector for an alternative harvest strategy for bass to replace maximum sustainable yield (MSY). Reviewing alternative strategies remains a medium- to long-term goal in the FMP. More evidence is required to determine how alternative harvest strategies would work for the bass stock in practice, and how any potential changes would impact fishers. Further, the ongoing ICES bass benchmarking exercise will update the models underlying bass stock assessments and may change how scientific advice is produced. As a shared stock, ongoing international collaboration on harvest strategies would also be required to achieve the full benefits. 

Many recreational anglers called for the introduction of real-time closures as a short-term priority to protect the bass stock. However, there wasn’t a clear explanation how this might work in practice, nor any evidence for what the impacts would be on different fishers. Introducing real-time closures would require this evidence base in order to amend the enforcement framework, so is more appropriate for consideration in the medium to long term. 

The initial Evidence Statement (Annex 1) published with the consultation draft FMP will be updated and re-published in early 2024. It will include the evidence gap highlighted in the consultation on understanding the age or size profile of the bass stock. We acknowledge further work is required to understand the importance and contributions of bass nursery areas to the adult population, which would help inform decisions on future management measures.

Summary of responses to FMP questions 

As part of the consultation, stakeholders were asked seven questions via Citizen Space which allowed them to express their views on the content of the proposed bass FMP. Summaries of the responses to these seven questions are shown below. Email responses and views from coastal meetings have also informed this section.

Question 1: Do you have any comments on the process for developing the bass FMP?  

Stakeholders welcomed the bass FMP development process, including the novel approach used by Policy Lab and the in-person and online engagement events. However, concerns were raised about the length, volume and complexity of the material that was consulted on, as well as some of the locations chosen for engagement events.  

There was considerable support from recreational angling stakeholders for the initial stages of the stakeholder engagement process, but many felt the outputs from this phase were not reflected in the final FMP, which they believed was too focussed on the commercial sector. Others suggested a more local and regional approach to evidence gathering and engagement would have been beneficial. 

Many stakeholders used this question to present their views on potential future management approaches. While some supported the current management of bass, other suggestions put forward included, for example, movement away from the use of MSY to maximum economic yield (MEY), an increase in the MCRS, the introduction of slot sizes, changes to the entitlement system, and introduction of a quota system (see question 4 and 5 for further discussion on management measures). There were also calls for strengthened enforcement to tackle illegal, unreported and unregulated (IUU) fishing.

Question 2: What are your views on the evidence presented on the current state of bass stocks in English and Welsh waters, and can you provide any additional evidence that supports or differs from ours?  

A small number of stakeholders stated the evidence-based approach was well presented and rightly highlighted the extent of evidence gaps in terms of making an accurate assessment of the current state of bass stocks in English and Welsh waters.  

There were mixed views from the stakeholders across all sectors, who expressed their personal experience and observations on the state of bass stock, suggesting both increased and decreased stock abundance. Some stakeholders from the commercial sector suggested there was now more bass further north, which was an evidence gap that needed addressing, and that further review of bass management was required for this area. It was also suggested that recreational fishing should be better monitored to improve understanding of their removals from the stock overall. 

Many recreational angling stakeholders strongly felt the FMP did not correctly represent the 2024 evidence from ICES that the spawning stock biomass is low, fragile and below safe limits. These stakeholders also noted ICES advises that removals in 2024 should be reduced, due to persistent low recruitment of juveniles into the adult stock in any given year. They also stated the 42cm MCRS is set too low to allow sufficient fish to spawn before removal. Additionally, they stated that the FMP does not reflect the significant body of economic evidence for managing a fishery for recreational objectives.

Question 3: Do you agree that the goals are appropriate for domestic management priorities within the bass FMP? 

While some stakeholders agreed with the goals proposed without further comment, many stakeholders suggested alternatives or modifications. There were some suggestions that the FMP goals should be more ambitious and use more specific language, particularly Goal 4 on compliance.  

Some stakeholders suggested Goal 1 (Inclusive stakeholder engagement structures to inform management of the bass fishery) was important and needed to be inclusive of all those with an interest in bass, and if balanced and effective would be the way forward. Others, particularly from the recreational sector, suggested sustainability should be the focus of the FMP and our goals and that stronger action on bycatch was required to increase selectivity and minimise unwanted catch. A suggestion was made for more explanation of the data and how it is used to inform policy, such as providing a rationale for the most appropriate size limits, closed seasons and gear selectivity measures.  

Most recreational angling stakeholders noted there was no separate goal to support the development of a ‘world class’ recreational bass fishery and to restore the stock to support this, nor any reference to this in Goal 2 which refers to equitable access. These stakeholders also stated that the FMP didn’t include information from previous surveys in support of MEY, and that alternative harvest strategies need to be prioritised. The same stakeholders felt the FMP undermined the goals on sustainable harvesting by ignoring ICES advice for 2024. They also thought it undermined the goals on protecting juvenile and spawning bass, by allowing commercial fishers to target spawning aggregations and by not adopting temporary closures and minimum mesh sizes.  

Again, many stakeholders also used this question to present their views on potential future management approaches, such as netting restrictions, MCRS increase, seasonal closure changes to protect pre-spawning aggregations, and mandatory use of remote electronic monitoring (REM) (see questions 4 and 5 for further responses on actions). Concerns were expressed from the catching sector about the viability of fishing businesses if more restrictions were introduced.

Question 4: Do you agree that the actions are appropriate short-term priorities for the bass FMP? 

Many stakeholders were generally supportive of the proposed short-term actions to achieve the bass FMP goals. In particular, there was support for the bass management group (BMG), although several stakeholders noted the challenge of ensuring adequate representation of interests and called for greater clarity on how the group (or groups) would function. A few stakeholders noted the BMG should include environmental representatives, such as eNGOs, as well as those from industry, and regulators and scientists. Several stakeholders from the catching sector suggested those whose livelihoods depended on fishing for bass should be given precedence in the management group, while others highlighted the importance of getting representation right both within and between sectors. 

There was general support for proposals to improve the evidence base, review the most appropriate closed seasons, and develop adaptive management approaches in the short-term. However, one respondent suggested the collection of evidence should be de-prioritised with the short-term focus instead on immediate action, and that moving catch limits to license conditions should be de-prioritised. Another noted that the recreational sector required an equivalent legislative mechanism to enable recreational bag limits to be adjusted flexibly in line with commercial limits. 

There was support for investigating how bass bycatch and discards can be reduced, as a short-term priority. Several stakeholders from the catching sector, in particular those using smaller vessels, raised the need to reconsider the 5% per trip limit for trawlers. The same stakeholders stressed a need to develop closer links with the Channel demersal non-quota species (NQS) FMP, where it was suggested fishers landed a greater number of low-value non-quota species to remain within the 5% bass limit. There were also suggestions of mandating use of the Record Your Catch app to record discard data, and to extend its use to recreational as well as commercial fishers. Some respondents suggested exploring gear developments for netting and trawling to improve selectivity, including increases to mesh sizes, should be prioritised in the short term. 

Several stakeholders provided views on who should be authorised to fish commercially for bass, and there was support for reviewing this in the short term. Suggestions included allowing all inshore vessels to land a small amount of bass to reduce discarding and prioritising more sustainable fishing methods. Some stakeholders from the recreational sector suggested commercial fishing activity should be prohibited or limited until bass stocks had substantially increased, and suggested the FMP and short-term actions were too focused on commercial interests. Other stakeholders from the catching sector believed the FMP and short-term actions had unfairly prioritised recreational interests, and instead the FMP should facilitate regulatory changes to support inshore vessels and ensure their economic viability. 

There were calls from the recreational sector to bring forward the review of appropriate size limits to the short term, in order to facilitate increasing the MCRS or introducing slot sizes. There were also calls from the same stakeholders to bring forward the production of handling guidance for fishers and the use of real-time closures to protect the stock. A few stakeholders, for example eNGOs, urged the commitments on REM should be brought forward and firmed up to reduce the risk of sensitive species bycatch. Several stakeholders also felt a more concrete and timebound commitment to shifting towards more sustainable fishing methods (such as hook and line) was required. These reflected general calls from various sectors to increase the timeline of delivery of the FMP and to firm up commitments wherever possible. 

A number of concerns were raised around the regulation of netting for bass. These concerns were from, on the one hand, those within the catching sector who thought netting was already over-regulated and bass bycatch limits for netters should be increased, and on the other hand from those in the recreational sector who thought salmonids and sea trout required additional protections, and felt that netting enforcement loopholes should be closed. Many in this second group of stakeholders also mentioned bass nursery areas (BNAs). Suggestions included banning netting within these areas and improving research into where bass were spawning, as well as considering amendments to existing BNAs to better protect juveniles.

Question 5: Do you agree that the actions are suitable medium-long-term priorities for the bass FMP? 

While some respondents agreed with the actions as proposed without further comment, many more stakeholders suggested modifications to the actions or believed these actions should be short-term actions. Concerns were expressed about the language used such as ‘consider’ and ‘possible’, and it was suggested these needed to be strengthened and made clearer, otherwise they may not be completed.  

Many recreational angling stakeholders suggested the following should all be short-term proposals:  

• slot sizes 
• a prohibition of fixed nets in BNAs (under the guise of mullet fishing) 
• reviewing the MCRS 
• gear developments 
• shore netting 

• alternative harvest strategies 

• percentage (%) catch composition limit 
• fish care and handling guidance 

Concerns were expressed about the lack of focus on preventing localised stock depletion, controlling offshore catches, and of not ring-fencing sufficient tonnage (including fish of larger sizes) for recreational sea anglers. 

However, concerns were also expressed about the potential impact of some suggested actions on the viability of the commercial fishing sector, such as an increase in the MCRS, the introduction of slot sizes and % catch composition limits, which were not supported. 

Some other points made were:  

• the current closed season does not adequately protect spawning and pre-spawning bass, and the closure of the bass fishery should be extended from 1 November to 31 March inclusive 
• IFCAs should be better funded to increase enforcement patrols across England, and they should have an equal number of non-commercial stakeholder representatives, rather than the current commercially dominated structure 
• further research should be undertaken in the short term to increase knowledge of sea trout migrations and movement at sea, including areas where they congregate and feed, and the number of sea trout and salmon caught as bycatch by the commercial bass fishery. Decisive action should be taken to protect these species 
• participation in REM early-adopter programmes should be encouraged where appropriate to improve data collection on discards 
• more authorisations should be made available to support the diversification of inshore fisheries in areas where bass have not been traditionally found, if stock levels change and could be well-managed

Question 6: How would you like to be involved in the delivery of the plan and the future management of the English and Welsh bass fishery? 

Broadly, the responses to this question across all sectors were positive. Most stakeholders expressed a willingness to engage further in the delivery of the plan and the future management of the bass fishery. 

Many stakeholders wanted to see recreational anglers represented in future stakeholder engagement, either as individuals or through representative bodies and organisations. Some recreational stakeholders felt there was disengagement and apathy among the sector and were looking for reassurance that recreational concerns would be reflected in the FMP. However, a number of these stakeholders were keen to engage and provide support through stock surveys, data gathering, workshops and online discussions.

Similarly, stakeholders from the catching sector were keen to engage through data and evidence gathering, sharing lived experience and to participate either as individuals or through representative organisations. 

Other stakeholders wanted reassurance of environmental and conservation body involvement, equality of representation and inclusivity and an open and transparent collaborative approach to the delivery of the FMP and management of the fishery. 

Across the sectors there was support for collaborative engagement through the proposed BMG. Welsh stakeholders referred to a strategic Ministerial Advisory Group for Welsh Fisheries, and species-specific advisory groups which sit beneath, and suggested these groups remain the appropriate structures to develop and deliver the bass FMP goals in Wales in collaboration with the proposed bass management group(s).

Question 7: Are there any important connections with or links to other fisheries that we should consider when finalising this FMP or during its implementation process? 

Several stakeholders who identified as recreational anglers did not respond to this question. Of those who did respond many expressed a need to protect other stocks and species, including salmonids, bait species, sea mammals, cetaceans and sea birds. There was a general desire for the FMP to look to other coastal state fisheries for examples of best practice and the achievement of a world class fishery. 

The responses from the catching sector were more varied. Some stakeholders suggested the bluefin tuna fishery and its effect on the bass fishery should be considered, while others suggested equivalencies with the EU and access to the shared stock by the EU and foreign vessels should also be considered. However, most stakeholders referred to actions already proposed in the draft FMP, such as closed seasons and nursery and juvenile stock protection rather than connections with or links to other fisheries. 

Other stakeholders suggested referring to other FMPs, such as the Channel demersal NQS FMP, and other initiatives, including the English Seabird Conservation and Recovery Plan, the Bycatch Monitoring Programme and the ICES working group for North Atlantic salmon.

Summary of responses to environmental report questions  

Stakeholders were asked four questions which allowed them to express their views about the content of the environmental report (ER) on the bass FMP. Summaries of the responses to these four questions are detailed below. 

Question 1: Is there any additional evidence we could consider, to inform our environmental baseline?  

Several stakeholders commented on the data gaps within the evidence base for the bass fishery, such as within spawning data, historic data on bass stock levels, and the impacts of fishing gear such as gillnets on fish stocks and the wider environment. 

While some stakeholders suggested further research should be undertaken, others recommended making use of local knowledge and anecdotal data from fishers to fill these data gaps. Some suggested avenues of further research, this included the:  

• impact of seals on the environmental baseline 
• impact of bycatch on cetaceans  
• reintroduction of bass surveys as conducted by Cefas  
• documentation of caught and released bass by recreational fishers  
• impacts of other species on the fixed gear fishery 
• impacts of the fixed gear fishery on the wider environment 

Some stakeholders noted they felt ICES advice had not been fully incorporated or regarded by the draft FMP, while others said they found the inclusion of recreational fishery data lacking. 

Several stakeholders noted the impact of climate change on the fishery. Comments were made on the impact of tuna stocks moving into bass waters due to rising sea temperatures, the change in distribution of bass stocks as northern waters become warmer, the impact of warming sea temperatures on bass spawning activity, as well as broader points around the carbon emissions of EU vessels and how this contributes to further changes within the fishery. 

The regeneration of American bass stocks was pointed out by several stakeholders as an example of a well-managed recreational fishery, with suggestions to take USA guidance into consideration when designing UK management measures. 

Concerns were raised by some stakeholders on wider environmental issues, such as the decline of salmon and trout stocks as a result of bycatch from the bass fishery, the impact of unauthorised sewage releases on fish stock health, the impacts of gillnets on bycatch species within inshore waters, and the impact of wind farms on the displacement of both bass stocks and fishers. 

There was also concern around the spawning stock biomass being below safe limits, with the respondent feeling further management should account for this within the FMP, such as through greater protections for spawning stocks and bigger fish to regenerate the stock. The current MCRS was felt by some to be too low to allow fish to spawn before being removed from the stock. MSY was also felt to be an inadequate model for fisheries management that considers all environmental concerns. 

The protection of juvenile bass stocks was raised, such as through controls on near shore fishing effort, or through minimum mesh sizes. Similarly, the use of larger vessels in inshore waters was considered to negatively impact stock health by the users of smaller inshore vessels. 

There was a suggestion that Appendix B of the ER should include the assessment of Environmental Improvement Plan (EIP) indicator E9 (Percentage of our seafood coming from healthy ecosystems produced sustainably). 

Several stakeholders submitted additional evidence for consideration on low impact fisheries, marine strandings, impact of bass fishing on migratory salmonids and seabirds, water quality in estuaries and seabass biology and ecology.

Question 2: Are there any other positive or negative environmental effects associated with the policies and actions of the draft Seabass FMP that we could consider?  

Some positive environmental effects were noted by stakeholders, such as the mental health benefits of a recreational bass fishery and the impacts of stricter rules for non-compliance. 

Many stakeholders found the proposed management approach too weak, and noted potential negative impacts caused by the commercial bass fishery, such as the risks of bycatch to fish and cetacean stocks due to fixed gear, and the reliance on MSY preventing quick stock recovery. 

Conversely, some stakeholders noted that lower limits on allowable bycatch for the bass fishery could lead to the targeting and overfishing of other stocks, particularly within the commercial fleet. The wider ecosystem implications could further reduce the bass stock. Some felt that netting restrictions would lead to an increase in the use of dredging or trawling gear, which have a larger negative impact on the marine environment. These gear types may also have higher rates of bycatch. 

While not resulting from bass management measures included within the FMP, some stakeholders commented on how unauthorised sewage release may impact fish stock health and important benthic habitats.

Question 3: Do you have any comments on the proposed actions set out in the Environmental Report to monitor and/or mitigate any likely significant (negative) effects on the environment of the FMPs?  

Some stakeholders felt more robust evidence should be gathered to measure the effects of proposed management measures appropriately, aided by monitoring technology such as REM. This monitoring should be effectively resourced, and the results should be made available to the public. Along similar lines, some stakeholders stated that evidence used to inform the FMP should be more specific, such as evidence around the potential effects of climate change on bass stock health and distribution. 

Stakeholders suggested the impact of the recreational fishing sector should be monitored, alongside the commercial sector to determine its impact on the fish stock and the wider environment.  

Conversely, stakeholders stated netting has no effect on benthic habitats while another noted that restricting inshore boats from using static gear such as nets to catch bass could lead to the use of towed fishing gear, which could have a greater negative environmental impact. 

Stakeholders stated that the current management measures within the FMP act to increase fish discards, while another found the funding and enforcement of the measures to manage impacts to be unclear. 

Other stakeholders felt the bass stock should be protected. If commercial fishing effort is not reduced, bass stocks could be further reduced. 

There was concern over whether increased catch limits could lead to further environmental damage, whether further Marine Protected Areas (MPAs) should be introduced to reduce fishing activity, and how water quality could be improved to improve bass stock health. 

Stakeholders suggested the extent, scale and environmental impact of gill netting in some parts of England, notably in the Southwest of England, should be fully assessed and evaluated. More generally there was a view the FMP does not propose any firm remedial actions or management to address the negative effects of fishing.

Question 4: Do you have any additional comments in relation to the Environmental Report which you have not been able to provide in response to the previous questions?  

Some responses considered the data gaps within the draft FMP and ER. One respondent noted that juvenile bass are not well monitored within English waters, and this would impact the effectiveness of proposed management measures.  

However, other stakeholders felt that bass stock health should be prioritised over the economic viability of the commercial catching sector, and that the lower range of MSY should be used when provided with sustainable removals options by ICES. 

More generally, some stakeholders felt that the wider ecosystem needs to be carefully managed to sustain bass stocks. 

A number of stakeholders, while being supportive of the process for the SEA, had comments on the level of the assessment and suggested a more detailed Habitat Regulations Assessment on bass management measures be performed.  

Stakeholders identified the following ways the ER could be improved:  

• indicate the SEA issues and receptors that may be affected by the policies of the FMP  
• indicate how SEA issues and receptors may be positively or negatively affected 
• indicate whether these effects are significant or require mitigation or policy changes 
• include clearer links between the issues raised by the assessment and the actions being taken to mitigate them in the FMP 
• recommend the FMP considers setting out how the objectives of the FMP will contribute to achieving good environmental status (GES) for the relevant UK Marine Strategy indicators 

Stakeholders felt the bass ER should have stronger links to other reports and regulations including:  

• river basin management plans  
• UK Marine Strategy Part 3 to revised and adopted Part 3 
• OSPAR Quality Status Report 
• biodiversity duty 
• newly designated HPMAs 
• Natural Environment and Rural Communities Act 2006 – Atlantic salmon, sea trout and allis shad are recognised as species of high conservation interest and value, reflecting their inclusion within Section 41 
• Habitats Regulations (2017 as amended) – Atlantic salmon and allis shad are listed under Annex 11 and Annex V 

Finally, it was suggested that the limited data regarding interactions between cultural heritage and the impacts of fisheries within English waters should be defined as a data gap. The proposition to consider the bass fishery as an early adopter for the REM programme, to both better understand and manage the risk posed by this fishery to sensitive species, was welcomed.

Government response: FMP 

Overview 

The FMP will manage how we fish our bass stocks in English and Welsh waters so that the full benefits of bass fishing will be available to local coastal communities.  

We will improve our science and evidence to better understand our fisheries. We will continue working collaboratively with stakeholders to identify how we can close the main gaps affecting how we manage the bass fishery. For example, we need data on discarding and recreational removals alongside a better way to measure the social, cultural and economic benefits of bass fishing to local coastal communities. 

Over the next 1 to 2 years, we will establish a new bass management group with commercial fishermen, recreational anglers, eNGOs, regulators and scientists to help us implement the FMP. We will also begin reviewing the most appropriate closed seasons for the stock, the current authorisation system and the regulation of shallow inshore and shore-based netting. We will ensure there is consistency and clarity of approach between regulators to improve enforcement and will seek to develop more adaptive management systems.  

Within 3 to 5 years, we will review appropriate size limits and harvest strategies for the stock, encourage participation in REM early-adopter programmes, investigate the feasibility of implementing a catch composition definition of bass bycatch for netters, and review the possibility of a model whereby all bass is landed to reduce discarding.

Introduction 

This section sets out the government’s response to the bass FMP consultation. It first explains our decisions for this FMP and any changes we plan to make to the plan, followed by a more general response about cross-cutting FMP issues. 

We are very grateful for the time all stakeholders have taken to provide constructive input to help us improve and finalise this FMP. The views provided were diverse, with a wide range of opinions within and between interest groups. All have been considered and have helped us develop our understanding of the views of stakeholders and the issues of importance. Some have resulted in changes to the FMPs. Others have not because they were more appropriate to be reflected in the implementation stages, or in a minority of cases because they were unreasonable or unworkable. In this section we explain why we have taken particular decisions. Given the volume, breadth and detail of the responses, we are not able to provide detailed explanations on all points raised.  

This is the first version of the bass FMP. It sets out the first steps and longer-term vision necessary for sustainable management of this fishery. These plans will take time to develop and implement. They are intended to allow an adaptive approach and will be reviewed and improved over time as we collaborate with the fishing sector and wider interests on the sustainable management of these fisheries. 

While FMPs set out specific policies, measures and actions that will contribute to more sustainable management of the relevant fisheries or of the marine ecosystem and environment, there is a wider body of work being undertaken by government that will also contribute to this. For example, the creation of Highly Protected Marine Areas (HPMAs), improving the management of Marine Protected Areas (MPAs), work to introduce greater use of REM, reform of discards policy, and ongoing work to reduce bycatch.

Changes to the bass FMP following consultation 

Recognising the importance of this issue to stakeholders, we will bring forward the review of inshore and shore-based netting regulation to become a short-term priority. It will seek to ensure adequate protections are in place to minimise the bycatch of sensitive species and migratory fish associated with netting, while reducing the bycatch and discarding of dead bass.  

We will bring forward actions to support developing gear modifications for nets and trawls to reduce bycatch and discards, which could include consideration of mesh sizes as well as the use of other appropriate technologies. While many stakeholders called for the introduction of a minimum mesh size to improve gear selectivity, we note that a 100mm minimum mesh size is already in place for fishers who land bass bycatch. We will update appropriate guidance to better reflect this.  

We will also bring forward actions on the production of fish handling guidance and on better ensuring consistency and clarity of approach between regulators to improve compliance with bass regulations. 

We have strengthened the link between the FMP objectives and goals and the relevant UK Marine Strategy descriptor GES targets they will contribute to achieving.

We have now published the final version of the bass fisheries management plan.

Overview of cross-cutting or common responses and questions across FMPs in the consultation

Engagement and collaborative working 

The majority of respondents across all of the consultations were positive about the collaborative approach adopted to develop the FMPs and the efforts made by Defra and its delivery partners to engage people in the process.   

Many want this approach to continue through the implementation stages to ensure that stakeholder expertise can be taken into account. A number of stakeholders noted the need to adopt a coordinated approach to the implementation of FMPs and to help improve the ability of fishing businesses to plan ahead. We will continue to work collaboratively with stakeholders during the implementation phase of the FMPs. 

However, despite the extensive engagement and opportunities for input prior to the drafting of the FMPs, and during the formal consultation process, we recognise some stakeholders did not feel as included as others in the preparations of the FMPs. There were also a few comments about us discriminating against particular sectors, which we refute.  

We continue to review our engagement. In many areas there was little common ground between or within interests or sectors. This made developing solutions acceptable to all exceedingly challenging. What we have therefore tried to do is chart a reasonable course in terms of reacting to the constructive responses received (unfortunately a handful were not) and ensuring we are abiding by our legal and international commitments and are balancing environmental, social and economic sustainability.   

In early 2024 we intend to initiate more work, across the programme and in relation to particular FMPs, to explore how government, regulators, scientists, industry, recreational fishers and other stakeholders can work together better in a respectful and constructive way. This will be considered both in terms of the development of further FMPs and their implementation. It will include developing a common language about the approaches taken, considering and articulating roles and responsibilities and ways of working better and earlier in processes, and improving communication. We are also keen to work more closely with initiatives like Fishing Into the Future to improve understanding.

Volumes of material and timing of consultation 

Many stakeholders raised the issue of the volume of material that we consulted on and the timing of the consultation.  

We took the view that we wanted to be transparent and provide evidence and supporting material to help stakeholders provide informed responses. There had also been extensive engagement and informal consultation prior to the drafts being developed, which included familiarisation with FMPs. We tried to ensure more accessible summaries were prepared, and we held 23 in-person engagement events and a series of online meetings where views were noted and fed into the analysis process. These events covered the wide range of interested sectors and stakeholders including a diverse catching sector, the wider supply chain, eNGOs, scientists, academia, EU Commission and Member States, and others interested in fisheries management.  

We will consider different approaches in future (while also recognising the guidelines for public consultations and our statutory requirements), as well as how much information is published at various stages.

Pace of implementation and change 

There is a strong desire for much faster delivery and for there to be a clearer commitment to doing so. We have made some adjustments to the FMPs to deliver some changes faster. We have had to balance this against resources and a recognition that too much change would not be deliverable or could create unreasonable burdens on the fishing industry.

Application of the precautionary approach 

Stakeholders from within and outside the fishing sector raised the importance of the precautionary approach in fisheries management, although concerns were also raised about the risk of potential social and economic impacts in its application. The Fisheries Act recognises both the need for fisheries to be managed so as to achieve economic, social and employment benefits, and the precautionary approach as objectives.

Fisheries regulators will need to take a balanced and proportionate approach to a range of considerations to ensure we achieve our ambitions set out in the Joint Fisheries Statement for sustainable stocks, underpinned by a healthy marine environment, supporting a profitable fishing sector and thriving coastal communities. We will continue to be mindful of this balance during the implementation of FMPs, particularly how we build a better understanding of the risk to stocks from overfishing in data poor fisheries and how we work with the fishing sector and wider stakeholders to help inform management of those fisheries.

Management borders 

There were questions raised about how the measures will work across borders of the UK fisheries policy authorities. More detail will be set out as we implement the FMPs – for example, on the areas where the measures will apply and the vessels that will be affected.  

Most fisheries management measures are devolved. It is therefore possible and probable that different management measures and approaches will apply in different fisheries administrations. Indeed, this is one of the benefits of FMPs – bespoke management can be brought in which takes account of the different fisheries, conditions, industries, priorities or pressures. However, where deemed appropriate or desirable, the UK administrations may decide to collaborate and harmonise measures.

Collaboration with the EU and compliance with the UK and EU Trade and Cooperation Agreement (TCA)   

A number of stakeholders raised the importance of collaboration between coastal states on fisheries management and the need for subsequent FMP management measures to be compliant with the TCA.  

As an independent coastal state, we recognise and value the importance of close working with other coastal states on fisheries management. We continue to look forward to deepening the excellent collaborative relationships the UK enjoys with our neighbouring coastal states and will ensure that our measures are fully compliant with the TCA.  

The TCA preserves the regulatory autonomy of UK to manage our fisheries (and the EU to manage theirs). Alongside this, the UK will continue to cooperate with the EU on the management of shared stocks, where appropriate. This would be achieved through the development of a multi-year strategy and would require a commitment from both the UK and the EU.

FMP evidence and data  

We acknowledge and plan to thoroughly review the substantial amount of evidence provided during the consultation, along with any additional evidence provided through continual engagement with FMP stakeholders. FMP evidence statements and evidence requirements will be updated to ensure evidence delivery priorities are reassessed to meet delivery and implementation ambitions of each plan. These will be published in 2024.  

A large proportion of stakeholders expressed concern about government’s ability to address the evidence gaps identified in the FMPs. Stakeholders also highlighted the importance of adopting a collaborative approach to the development of evidence – working with the fishing sector and wider stakeholders to support the delivery of evidence requirements.  

It will not be possible or reasonable for government to fund all the evidence gaps identified across the FMP programme. Prioritisation will be needed. As well as looking at innovative ways to fill those gaps, to support the phased approach of FMP delivery and implementation and progress towards meeting the Fisheries Act objectives, in 2024 Defra will launch and publish an evidence approach that promotes collaboration across stakeholders to address identified evidence gaps for FMPs. 

A number of stakeholders called for there to be more coordination across fisheries authorities regarding data collection requirements on industry.  

We will take data requirements into account when developing new measures and will consider this as part of separate but linked work already under way to develop a more coordinated approach to data collection, management and use between fisheries authorities. 

Latent capacity 

The issue of latent capacity was raised frequently through this engagement. Some stakeholders were keen for latent licences to be removed to help prevent an increase in effort on stocks. Others raised concerns that removing latent licenses would be unfair and restrict those fishers who rely on being able to diversify and adapt to circumstances. We will consider latent capacity as part of the overall development of effort management measures.

Government response: environmental report 

Introduction 

This section sets out the government’s response to the bass FMP strategic environmental assessment (SEA) environmental report (ER) consultation. 

A SEA is a formal process to assess the effect of a plan or programme on the environment. SEA aims to: 

• provide a high level of protection to the environment  
• promote sustainable development 
• integrate environmental considerations into the preparation and adoption of a plan or programme 

The SEA must be completed before the plan or programme is adopted to avoid unnecessary environmental harm arising from its proposed actions or outcomes. The SEA concentrated on the proposed objectives and actions of the draft bass FMP. The ER sets out the findings of the SEA process. 

Undertaking a SEA of the draft bass FMP allowed us to identify the existing impacts of the fishery, better understand the environmental effects of the policies and actions contained in the plan, while ensuring we meet the requirements under the SEA Regulations 2004. 

The SEA process introduced environmental considerations into the preparation phase of the draft bass FMP, ensuring we continue to make progress on our commitment to deliver environmentally sustainable fisheries. The ER helped inform and influence the development of the proposals set out in the draft bass FMP and sets out recommendations on how the FMP could reduce the environmental impact of bass fishing into the future. 

We are grateful to all stakeholders for sharing their views. The responses to the consultation confirm that the environmental sustainability of the bass fishery is important and an essential component of managing harvesting to create a sustainable fishery. The responses have contributed to our understanding of the environmental risks that the bass FMP seeks to address. 

Stakeholders recognised the need for better data and evidence to fully assess the impact of the bass fishery to introduce targeted management to reduce or remove negative effects. Nevertheless, we acknowledge such data gathering must run in parallel with clear actions to manage current impacts. 

The consultation sought views on evidence and the environmental effects of FMP policies and proposed mitigating actions. Stakeholders were also able to provide comments on other matters. Our responses to the views provided on these topics are set out below. 

Stakeholder responses have been considered and the bass FMP ER has been updated with additional recommendations. The full report will be published in 2024.  

The revised bass FMP has considered these recommendations and adjustments have been made where appropriate.

Question 1. Evidence 

Stakeholders submitted a range of additional evidence to be considered to inform the environmental baseline, including marine animal strandings data, impacts on seabirds and effects of water quality on bass habitats. There was support for including more evidence of specific impacts from bass fishing that have influenced the current environmental baseline.  

The evidence provided through the consultation has been collated and will be considered as part of FMP implementation and any future assessments. 

Question 2. Environmental effects of FMP policies 

Some stakeholders submitted views stating how changes to bass fishing practices could impact on other species through increased bycatch, increased fishing pressure from displacement into other fisheries, and increased bait collection for rod and line fishing.  

The additional effects provided through the consultation have been considered and included in Section 5. Assessment of Environmental Effects, as appropriate.

Question 3. Actions to mitigate environmental effects 

Stakeholders wanted to see more immediate measures introduced to address bycatch issues related to bass fishing, particularly from the use of gillnets, suggesting the improved application of an ecosystem-based approach to fisheries management. We recognise the concerns raised by stakeholders and therefore the ER has recommended that the FMP considers more immediate actions. Specifically, in relation to mitigating the impacts of netting on sensitive species.

Question 4. Additional comments 

We welcomed the suggestions on where the ER could be improved, particularly around linking the assessment of the FMP’s policies and actions back to the SEA issues and receptors and associated UKMS descriptors. The revised ER has recommended the FMP considers setting out how the objectives of the FMP will contribute to achieving GES for the relevant UKMS descriptors. 

Stakeholders felt the ER should have stronger links to other reports and regulations including:   

• river basin management plans  
• UK Marine Strategy Part 3 to revised and adopted Part 3 
• OSPAR Quality Status Report 
• biodiversity duty 
• newly designated HPMAs 
• Natural Environment and Rural Communities Act 2006 
• Habitats Regulations (2017 as amended) 

We have amended the ER to make these links.  

Several stakeholders suggested the ER should provide clearer recommendations to address existing environmental impacts caused by the bass fishery. We agree the ER should provide clarity in its recommendations. However, we note its purpose is to provide recommendations on the strategic issues arising from the objectives and proposed actions of the FMP as currently drafted. The ER can highlight other broad environmental issues that the FMP could address (such as impact on sensitive species) but cannot propose specific measures (such as prohibit netting within 3 nautical miles of the coast). It is for the FMP process to consider the issues and decide what actions it should take to address them.

Annex 1 - List of organisations that did not request confidentiality 

• Amethyst Fishing Company Limited 
• Angling Cymru Sea Anglers 
• Angling Trades Association 
• Angling Trust 
• Bass Anglers Sportfishing Society 
• Bass Angling Conservation  
• Blue Marine Foundation 
• Brighton Inshore Fishing 
• Cornish Fish Producer Organisation 
• Cornish Federation of Sea Anglers 
• Cornwall Bass Investigations Group 
• Cornwall Inshore Fisheries and Conservation Authority 
• Cornwall Wildlife Trust 
• CSM Sport & Entertainment 
• Devon and Severn Inshore Fisheries and Conservation Authority 
• Eastland Compounding 
• European Commission 

• Frontier Construction 

• Historic England 
• International Transport Workers Federation 
• JMR Fishing Ltd 
• Joint Nature Conservation Committee 
• Kent and Essex Inshore Fisheries and Conservation Authority 
• Launceston Anglers Association 
• Lyme Bay Fishermen’s Community Interest Company 
• Marine Conservation Society 
• Ministry of Agriculture, Nature & Food Quality - Netherlands 
• Mudeford and District Fishermen’s Association 
• Natural England 
• Natural Resources Wales 
• National Federation of Fishermen’s Organisations 
• New Under Ten Fishermen’s Association Limited 
• North Eastern Inshore Fisheries and Conservation Authority 
• North West Fisherman’s Association 
• North Western Inshore Fisheries and Conservation Authority 
• Northumberland Inshore Fisheries and Conservation Authority 
• Plymouth Fishing and Seafood Association 
• Poole and District Sea Angling Association 
• River Otter Fisheries Association 
• Royal Society for the Protection of Birds  
• Sea Angler magazine 
• Shark Trust 
• Shoeburyness Waterman’s Association 
• South Coast Fishermen’s Council 
• South Devon and Channel Shell fishermen 
• Southern Inshore Fisheries and Conservation Authority 
• South West Rivers Association 
• Southwold Commercial Fishing Group 
• Southwold Fishermens group 
• Sussex Inshore Fisheries and Conservation Authority 
• Sportfishing Club of the British Isles 
• Tamar and tributaries Fisheries Association 
• University of Exeter 
• University of Southampton 
• Welsh Fisherman’s Association - Cymdeithas Pysgotwyr Cymru 
• Wembury Marine Conservation Area Advisory Group 
• Whale and Dolphin Conservation
• Wildfish

Annex 2 – List of FMP consultation engagement meetings 

• Amble   
• Bridlington   
• Brixham   
• Brussels (hybrid in person and online) 
• Cromer   
• Folkestone   
• Gosport  
• Hull   
• Ilfracombe   
• Lowestoft   
• Newlyn   
• North Shields   
• Padstow   
• Peterhead   
• Plymouth   
• Poole  
• Rye   
• Scarborough   
• Shoreham  
• Stokenham   
• West Mersea   
• Weymouth   
• Whitby   
• Whitehaven   
• Whitstable (online)