Consultation outcome

Summary of responses and government response

Updated 14 December 2023

Introduction 

This document summarises the responses received to the public consultation on the Channel demersal non-quota species (NQS) 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.    

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 Channel demersal NQS 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) and the requirement for strategic environmental assessment under the Environmental Assessment of Plans and Programmes Regulations 2004.

Background to the consultation 

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

The consultation was conducted using Citizen Space (an 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, we received 78 direct responses to the consultation:

• 33 were submitted through the Citizen Space online survey
• 45 were submitted by email

The breakdown of responses consisted of: 

• 23 (30%) from the catching and producing sector 
• 12 (15%) from other sectors  
• 5 (7%) from interest groups  
• 17 (22%) from individuals 
• 1 (1%) from the processing sector 
• 1 (1%) from science and research sector 
• 1 (1%) from the supplier and retail sector 
• 3 (4%) from the recreational sea fishing sector 
• 15 (19%) sector not stated 

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 Channel demersal NQS 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.  

These engagement events were used as an additional way 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 respondents 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 

We are very grateful for the time that stakeholders have taken to provide constructive input to help us improve and finalise the FMPs. A wide range of diverse and informative views were presented for which we have provided detailed summaries in the sections below.   

Overall, there was broad support for this FMP as an approach to improve the sustainability of demersal NQS stocks in the English Channel. Stakeholders supported continued engagement and establishment of a Channel management group to build on partnership working across a diverse range of fishing interests and the 19 species in this FMP. 

There was broad support for the proposed minimum conservation reference sizes (MCRS) for lemon sole, turbot and brill. There was support for taking forward the 100mm mesh size, and 221kw limitation in the 0 to 12 nautical mile (nm) zone, for flyseiners to help manage effort on demersal NQS in the Channel. We will take forward the MCRS for these three species and supported flyseining proposals during 2024. We will give further consideration to the mixed responses on other potential flyseining measures consulted on.

The proposals for monitoring octopus catches and evidence gathering of the potential impacts of towed gears were also supported and will be explored further during 2024.  

However, many significant concerns were raised about the proposal to introduce a MCRS of 23cm for cuttlefish. Stakeholders were clear there would be significant economic impacts on the trawler fleet with little or no positive effect on stock health. Those concerns ranged from a belief there was a lack of evidence that the stock was at risk, that the measure wouldn’t work given the low survivability of the species and the impact on other species preyed on by cuttlefish, to the economic impact it would have on fishers, businesses and communities from the significant loss of revenue and jobs. We have, therefore, removed the cuttlefish MCRS proposal from the FMP. 

It was clear from the responses that concerns remain about the overexploitation of cuttlefish, and of declining pot and trap catches in the southeast Channel. We therefore propose to bring stakeholders together within the first 6 months of 2024 to develop an action plan to support sustainable management of the cuttlefish fishery. 

While voluntary measures for recreational fishers, such as guidance on safe handling techniques or MCRS, to help support sustainable practices had some support. There were also concerns voluntary approaches were not as effective as enforced legislation and would not provide the required level of protection for wildlife and would be hard to police. We will support the recreational sector to develop codes of practice and evaluate their effectiveness before considering if additional steps are required.

Summary of responses to FMP questions  

As part of the consultation, stakeholders were asked 10 questions via Citizen Space which allowed them to express their views on the content of the proposed Channel demersal NQS FMP. Summaries of the responses to these 10 questions are detailed below. Email responses and views from coastal meetings have also been summarised in this section.

Question 1: Do you have any comments on the process for developing the Channel demersal NQS FMP?

The majority of stakeholders felt the FMP development process was positive with good engagement across a range of stakeholders. Some expressed the importance of considering industry needs, such as the type or time of engagement, and the port visits and in-person events were generally said to be a positive experience, but more could be done to improve engagement.  

Several catching sector stakeholders suggested greater discussion was needed around the proposed measures prior to consultation, such as on the cuttlefish MCRS or the inclusion of a standardised 100mm mesh for bottom trawls.  

Some stakeholders felt engagement could have been more inclusive. Some eNGOs and members of the catching sector were disappointed not to be included in the working group and unable to input into the development of the FMP until the formal consultation stage. Some within inshore catching and recreational sectors felt that the FMP would benefit from more balanced representation.  

Concerns were raised that the sectors included in the FMP working group were able to exert more influence into the plan. Some felt there were biases towards an environmental agenda, others thought that industry views might be taken into account more than that of biologists and conservationists. Some felt that data had been excluded from the FMP, for example on commercial fishing or socio-economic impact. 

Some concerns from the catching sector were expressed around the transparency of the process, feeling that some proposals were included without discussion with industry, for example the cuttlefish MCRS. There was a concern that data gaps would deliver a reactive management response. 

Some stakeholders said the draft FMPs followed expected government processes and guidelines, though some recreational sector responses felt this failed to consider recreational angling interests. Inconsistencies across documents and FMPs, such as in language and terminology was highlighted making the drafts hard to follow. There was support for a standardised approach across the UK, and for joint EU and UK approaches. 

On reviewing the plans on a 6-year cycle, there were concerns from IFCA respondents this would result in insufficient measures within the timeframe. While some wanted to see a more precautionary approach taken and a greater environmental focus.

Question 2: What are your views on the evidence presented on the current state of Channel demersal NQS stocks (and other related stocks) in English waters and can you provide any additional evidence that supports or differs from ours?

A number of stakeholders across all sectors agreed with the evidence provided, felt it was comprehensive and reflected the information available. Some stated it was good to have this in one place. Some noted that there is insufficient data available and the evidence gaps outlined are significant. Some stakeholders felt the evidence was not presented clearly enough. Others felt that there was insufficient time available to comprehensively review the evidence in the time provided.  

Some catching sector stakeholders felt the evidence provided was not in line with fishers’ observations. Some stated an absence of information on recreational value and importance, while some in the commercial sector believed the evidence presented derived from anecdotal statements and was not backed by scientific analysis. 

Commercial sector stakeholders recognised there were large evidence gaps for data poor species. They proposed including further evidence on the economic impact of the proposed measures, more catch composition data for all vessels, and more research into all forms of fishing and impact on species. Some commercial and processing sector stakeholders felt observer data would help, others pointed out that the science needs to be more real-time, and that there would need to be funding to fill those evidence gaps.  

Some stakeholders felt the FMP didn’t sufficiently refer to regional IFCA measures. Some stakeholders wanted to see management in conjunction with other FMPs, citing a link between the bass and smoothhound fisheries. 

Inshore fishers, eNGOs, IFCAs and some interest groups believed the status of NQS and high levels of exploitation to be a concern. Commenting that the data supports claims that NQS stocks are declining across the whole area, agreeing that there was an absence of evidence on the current state of stocks generally, and citing International Council for the Exploration of the Sea (ICES) and IFCA reports to indicate overfishing of cuttlefish and greater need for offshore management. Some suggested a standalone evidence plan was required for cuttlefish. 

Some inshore and processing sector stakeholders felt there was sufficient evidence to act, while some stated that if the science was not clear, or if indications that fishing was unsustainable, then the management approach should be precautionary, for example closing a fishery.  

Some stakeholders within the commercial sector stated that management measures should be supported by a strong evidence base. That further evidence would be needed on the state of the stocks and economic impact of measures, before making management decisions and that over precautious management could be damaging to the fishery.  

Some stakeholders from the catching sector felt the proposals in the FMP had been driven by political or policy considerations or based on anecdotal evidence, focusing on flyseining and not considering the level of risk to NQS from other gears, and highlighting that the majority of landings were not made by this gear type. Others within the catching sector felt flyseining was having a greater impact than was being acknowledged and more restrictions were required.  

Some commercial sector stakeholders highlighted the need to consider the impact of climate change, and changing environmental conditions, adding that fish will adapt. The need to consider impacts on local communities was noted, for example if fishing becomes depleted there would be a knock-on effect.

Question 3: What are your views on the evidence gaps identified within the FMP?  

Many stakeholders across the responding sectors agreed there were big gaps in evidence on most NQS and fishing activities. Some felt that the evidence gaps identified were appropriate and extensive. A number of responses across the responding sectors stated it was a big task to populate the evidence base and would require substantial investment, cost benefit analyses and collaboration to close the gaps. Some suggested there is existing evidence that could help close gaps, such as a comparative assessment of gear types used. While some wanted the FMP to prioritise filling in the gaps for cuttlefish, squid, elasmobranchs and flyseining.  

There were concerns expressed that priority would be given to data collection rather than management. Some responses from the catching sector felt that there is sufficient evidence to support a need for greater management. 

Several stakeholders from the catching sector felt that there needs to be more evidence and understanding of the impact of measures before additional management is introduced, or that more evidence was needed to create a baseline by which to monitor FMP objectives against. A small number felt market economics had not been captured or accounted for in the evidence while others felt it was not clear how different fishing practices and levels of impact will be assessed and managed.  

Several stakeholders across the responding sectors stated that FMPs need to work closely with remote electronic monitoring (REM) tools to help fill data gaps.  

Some stakeholders wanted to gather further evidence on recreational socio-economic and cultural importance of species. Stakeholders stated there was a need to explore further how FMPs and marine plans fit together, or that the national benefit objective in the Fisheries Act 2020 should be included to guide FMP development.  

Some stakeholders suggested the evidence presented was too high level and simplistic, that they were not presented in way to support FMP objectives.

Question 4: Do you agree with the actions to address the evidence gaps identified?  

Many stakeholders across the responding sectors queried how the evidence gaps would be closed, noting the research plan needs to be more specific and funding put in place. Some recognised this could not be funded by Defra alone and could be a significant drain on government resources. Responses from the catching sector and interest group noted this work would require collaboration with industry, academia, and fisheries managers with specific actions. Some stakeholders welcomed a collaborative approach and said data collection models should be based as far as practically possible on the principles of co-design and collaboration with industry and other partners, highlighting some specific examples here and overseas to consider further. 

Several stakeholders from the catching sector believed it was important to establish close links with fishers who can best supply information or data, such as first-hand experience or observations, and that a long-term strategy should set fishers at the heart of fisheries science. Some stated that gathering evidence from on board the vessels to better understand the composition of catches taken is the only way to significantly improve the quality and quantity of data generated. Some responses from IFCAs and eNGOs stated that REM on all vessels would help fill data gaps.  

A number of stakeholders believed greater prioritisation should be given to addressing the evidence gaps to progress towards species specific stock assessments, highlighting investigating seasonality data against other influencing factors for example, trawling activity. Other stakeholders felt that proxies should be developed where maximum sustainable yield (MSY) is not available. A number of stakeholders stated prioritisation should focus on cephalopods (for example, cuttlefish, squid and octopus). 

Stakeholders supported the proposed Channel management group. One highlighted the composition and terms of reference would need to be carefully considered. For example stating that too diverse a composition may risk effectiveness. Having a steering and working group model was an option suggested.  

Some stakeholders from the catching sector raised concerns that the proposed actions were too complicated to deliver in the short and medium term, while a respondent felt the Goal to ‘deliver effective management of demersal NQS in the English Channel’ wasn’t specific enough as the FMP only covers these species in two ICES areas when they are present throughout the UK and stated that the FMP would be unable to deliver sustainable stock management. 

Some IFCAs highlighted that cuttlefish and squid were important fisheries for both inshore and offshore sectors and that identifying benefits for coastal communities will be challenging. Some catching sector stakeholders stated that for cephalopod fisheries collecting catch and effort data would need a significant change in custom and practice for vessels under 10m. While other catching sector stakeholders were concerned that cuttlefish are a threat to other stocks if not regulated through fishing.  

IFCA, eNGO and interest group respondents supported precautionary management. Some stated that the precautionary objective in the Fisheries Act means there should be active steps to manage the fisheries, rather than waiting for the extensive list of data gaps to be closed, indicating there is an urgency to ensure that catch limits are set based on the precautionary principle, and that there are ongoing risks to inshore fisheries. Others felt there should be a short-term action to identify the fish habitats that support the most commercially important fisheries and assess their status and vulnerability. 

Some catching sector respondents suggested government is attracted to precautionary management so it can show a commitment that can be assessed. They raised the need to define how precautionary management is applied, and agreed this should come sooner rather than later. Some from the catching sector stated all commercial catch information should be standardised.  

Others in the catching sector stated further data would be needed before precautionary management, and not to implement blanket precautionary approaches to management based on anecdotal information. Some expressed concerns that new mandatory measures would further limit fishers’ capacity to improve their sustainability, suggesting that if new rules were introduced others must disappear so fishing remains profitable in practice. Some in the catching sector stated that socio-economic data collection should also be a core part of any data collection programme to support the FMP, and that socio-economic impacts should be taken into consideration, for example if new measures are introduced.  

Some from the catching sector felt the proposed introduction of management of flyseining is based on anecdotal concern and not underpinned by evidence. They stated both the Fisheries Act 2020, and general fisheries custom and practice, required fisheries science to underpin management action based on rigorous quantitative methods.  

Some eNGOs and fisheries interest groups felt that closing stock population data evidence gaps by conducting an MSY assessment for all species would be advantageous, by providing data which can be used to set total allowable catches.  

Stakeholders from the recreational sector believed the goals to be vague and difficult to assess whether they are ambitious or decisive enough to make real progress toward the overarching objectives of world-class fisheries that are environmentally, socially and economically sustainable. Some suggested that more work needs to be done on the recreational species of interest, and that ecosystem approaches needed to be considered over MSY. Some recreational responses stated that MSY does not develop brood stocks, allowing commercial fishers to take the maximum potential catch out of a stock, and believed stopping commercial fishing in recovering fisheries would prevent further damage and deliver UK wide brood stock fisheries. 

One respondent from the catching sector stated research is needed into the benefits of increasing the mesh size to 100mm for all vessels, suggesting an increase in minimum mesh size would be more effective than just increasing the MCRS which alone may result in increased discards without reducing mortality. They also suggested a square mesh panel should also be required for all flyseine vessels, and that all gear types should be restricted by power (kilowatt) inside the 0 to 12nm zone.  

However, another respondent from the catching sector expressed concerns that recent trends in landings data would be impacted or distorted by future measures, for example through applying a MCRS or mesh size. They feared a tougher stance and a precautionary approach to be applied due to increased uncertainty in the data, particularly if management moves to output controls.  

One respondent felt it was difficult to follow the research plan logic in its presentation and suggested the Whelk FMP evidence and research plan structure, format and detail should be applied to the Channel demersal NQS FMP.

Question 5: What are the benefits and drawbacks (environmental, economic, social) of introducing the proposed MCRS for Lemon sole, turbot, brill, and cuttlefish in the English Channel within 2 years of publication? Are there any other species that could benefit from the introduction of MCRS? 

The responses to this question focused mainly on the application of a proposed 23cm MCRS for cuttlefish, where most stakeholders were against introducing a cuttlefish MCRS at all.  

For the other three species there were fewer responses but those who did respond were generally supportive of the proposed MCRS and sizes – some noted that MCRS was a useful management tool and would align with measures already in place, for example in the Cornwall IFCA. Some catching sector respondents noted an increased burden sorting catch would place on the fishers, and that correctly applied technical measures would be a better approach.  

Stakeholders from eNGOs, the recreational sector and interest groups felt there would be general benefits to introducing an MCRS alongside technical measures, and that these measures should be extended to other species in the FMP. An MCRS could lead to improvements to stocks and the environment and greater protection for juvenile fish, allowing juveniles a higher chance of surviving to reproduce. Some of these respondents highlighted a medium to long term economic benefit of introducing a MCRS, generating profit from larger fish and potential help towards ecotourism.  

Respondents from the catching sector believed introducing an MCRS would impact commercial fishing and would result in increased discards. Many expressed strong concerns about the potential impacts of a cuttlefish MCRS in particular, citing impacts on business, from a loss of revenue to crew reductions and job losses ending fishing livelihoods in the South West.  

Going further, catching sector stakeholders stated the economic impact would decimate fishing communities, and could lead to a potential increase in fishing effort to compensate for losses placing more pressure on other stocks. A number also felt this proposal had undermined trust in building a co-management process.  

A number of stakeholders cited the low survivability of cuttlefish caught in trawls and that the fish would be dead after long periods of measuring sizes on board, placing additional pressure on crews for a time-consuming process with little benefit. Some stakeholders also highlighted this measure would have an impact on other species who are natural prey to cuttlefish.  

Some stakeholders also felt an MCRS would lead to a lack of incentive to record data and in turn lead to inaccurate stock assessments. The difficulties on compliance and enforcement due to the quantities caught were also highlighted.

Question 6: What are the benefits and drawbacks (environmental, economic, social) of introducing the proposed seasonal closures for trawlers to protect cuttlefish pre-spawn aggregations in the English Channel? 

Many stakeholders, including eNGOs, IFCAs, interest groups, recreational sector, the catching and processing sectors, expressed support for a seasonal closure for cuttlefish to help protect pre-spawning aggregations during key reproductive periods, with strong support for introducing as soon as possible. Some stakeholders stated this must be done on a precautionary basis pending further evidence for longer term management approaches. 

Stakeholders across all sectors highlighted seasonal management, introducing spatial measures would provide safe areas for cuttlefish and their movement to breeding grounds. Some proposed reductions in bycatch risks extended to all gears, with management placed over the autumn and winter to protect pre-spawning aggregations from trawlers, and that this would be a more effective measure than an MCRS as manageable and enforceable. Additionally, some proposed introducing protections for egg laying stocks by restricting the trap fishery and protecting spawning locations.  

A number of the catching sector expressed concerns that closing areas for fishing could cause significant economic impacts to the fishery and depending on whether these are placed inshore or offshore would impact the respective sectors. Some noted that a long-term benefit could be found in increasing the spawning stock biomass, but more evidence would be required before closures were brought in.  

Some in the catching and processing sectors stated that summer closures on spawning cuttlefish would have significant economic impacts, leading to job losses and loss of livelihoods with little benefit to the stock, owing to the quantity of offshore catches. Some in the catching sector, eNGOs and interest groups stated that offshore management was needed for the long-term viability of the fishery using high impact fishing methods to target cuttlefish, or the inshore cuttle trap fishery would continue to disappear, and that a seasonal closure would see greater economic and social benefits for inshore potters.  

Some eNGOs and interest group, processing sector, recreational sector, catching sector and IFCA respondents highlighted closures would improve the condition of other stocks and benefit the fishery. They believed the measure would mean a sustainable future fishery and sustainable fisher income and that an initial drop in revenue would be outweighed by long-term benefit. 

Some recreational responses felt a seasonal closure may have the benefit of reducing bass bycatch from trawlers in the South West Channel, and it was stated that banning demersal trawling in shallow nearshore waters of West Sussex had benefitted species.  

A small number of stakeholders said this measure would improve the condition of other commercial fish stocks and progress towards good environmental status (GES). Some stated they would be open to supporting data collection, while some stated there would be a general social benefit from stock improvement. One respondent felt that temporary closed areas do not work as fishers would capitalise on rested stock or areas once opened, leading to greater environmental harm.  

Other catching and processing sector respondents stated that there is no evidence of the stock being at risk. Some felt that high trawl landings do not impact the following years’ stock and there was little merit in restricting the inshore pot fishery due to small catches. Some stakeholders said there should be socio-economic analysis before any seasonal closures, looking at vessels’ reliance, impact on other fisheries and onshore jobs.  

Some catching sector responses suggested there was the need to understand how trawl fisheries vary within inshore and offshore to not disadvantage one sector over the other. While some suggested landings from trawl fleets comprised substantial volumes of immature stock, which may be impacting stock development and potential yield, and therefore supported seasonal closures.  

A number of stakeholders highlighted that there was little evidence on cuttlefish distribution, breeding sites or stock levels, but seasonal closures may be appropriate if scientific evidence supports this. A further observation was that with two spawning seasons (or continuous spawning throughout the year) and three cuttlefish species, defining a closed season would be difficult. Others stated more research, or modelling of landings and displacement, was needed before an appropriate closed season can be considered. Some stakeholders in the catching sector felt that a closed season in a mixed fishery would be challenging and would mean unavoidable bycatch and increased discards. Adaptive catch and bycatch limits would need to be set during the season. Alternatively, some in the catching sector felt technical measures would be more beneficial, for example mesh sizes or square mesh panels, rather than spatial measures as these species are difficult to avoid in a mixed fishery.  

Some from the catching sector proposed dynamic real time closures, such as for aggregations of juvenile cuttlefish, or a flexible seasonal opening and closure alongside a bycatch allowance as a management avenue to explore. 

A number of stakeholders from the eNGO, interest group, recreational sector and catching sectors highlighted an increased displacement risk, which would increase the pressure on other fisheries, and would need to be effectively monitored and managed. A small number of stakeholders expressed concerns that displacement pushes fishers further offshore, increasing the risk to safety.  

Some stakeholders welcomed proportionate, phased use of REM for vessels with highest catching capacity or monitoring fishing activity around spawning periods with significant penalties or licences revoked for boats turning off VMS. 

A small number of catching sector stakeholders proposed a joint UK and EU approach to cuttlefish to balance the sustainability of the stock and economic viability of active fleets, and that alternative uniform measures that do not lead to a closure of the area may be more efficient.

Question 7: Would the proposed voluntary measures for recreational fishers support sustainable practices across the recreation fishing sector? How can recreational fishers input further evidence and data to improve understanding of NQS catches? 

Many stakeholders from across responding sectors supported promoting greater recreational engagement and were in favour of codes of practice or guidance such as on safe handling techniques or MCRS, to help support sustainable practices and sustainability of the recreational sector. Some stated improving how fish are handled and released is important to the recreational sector, but also noted many recreational fishers already practice voluntary approaches. Some stating that any improved engagement and data provided from the recreational sector would be beneficial but has to be effectively monitored with control measures in place. 

A small number of the catching sector and IFCAs highlighted the Southern IFCA impact of good practices from codes of conduct, such as that for cuttlefish traps, and urged that it be adopted more widely.  

IFCAs stated information on voluntary measures needs to be accessible across numerous mediums, such as notice boards, engagement with clubs, marine officers, social media and websites, to include all fishers. They added voluntary measures must be seen as fair and proportionate for stakeholders to buy into them. 

A number of stakeholders from the commercial, recreational and processing sectors were against voluntary approaches, saying they were not as effective as enforced legislation, would not provide the required level of protection for wildlife, would be hard to police and regulation should be applied equally. A number of these stakeholders felt guidelines should be legal and enforceable, for example through byelaws, closed seasons, bag limits or compulsory MCRS.  

Other stakeholders believed recreational fishing to have a relatively small impact on the environment compared to commercial fisheries, but as this was dispersed would be almost impossible to monitor compliance or enforce regulations. A concern was raised about sustainability if the recreational sector moved into fish sales, saying that anglers should not sell or profit from their catch. 

eNGO respondents felt that monitoring and recording recreational fishing removals, was crucial for accurate and reliable stock assessments, citing ICES which recognised that inclusion of recreational take in stock assessments is difficult to do and may impact stock sustainability. There were suggestions from the catching sector that data could be collected – to be subsequently verified – through a CatchApp, local angling groups or citizen science programmes.

Question 8: Are there other measures or variations of the proposed management measures we could consider to help manage demersal NQS stocks and the ecosystem/environment in the English Channel? Do you have any evidence to support some of these areas for future consideration? 

A number of stakeholders from eNGOs, interest groups, IFCAs and the catching sector suggested measures to help manage cuttlefish, from using dynamic real time or adaptive area closures, or seasonal closures set on a precautionary basis to protect breeding grounds, to prohibiting fishing in areas when there are a certain proportion of small cuttlefish. A small number stakeholders from the catching and produce sector suggested the proposed MCRS for cuttlefish should be set to 10cm or less. 

Some stakeholders from the catching sector, eNGOs and interest groups proposed bringing forward an MCRS for other species, such as those targeted by flyseiners, or lesser spotted dogfish and smoothhound due to variations in life histories and vulnerability to fishing pressure and slow development. Some suggested an MCRS should be considered for all fisheries with high survival rates, and quotas with bycatch provision for fisheries with low survival rates. 

A small number from the catching sector and eNGOs proposed pot or effort limits (such as trawling two months a year), or a licensing scheme to limit the number of vessels or aligning with and drawing experience from EU and French cuttlefish management. A small number of other stakeholders from the catching sector supported joint UK-EU approaches to management of Channel demersal NQS. 

Some eNGOs stated the need for additional cuttlefish evidence requirements, such as using pre-season and mid-season surveys to track the stock and enable adjusting removal levels, or more evidence gathering on the vulnerability of cuttlefish eggs to disturbance. Recommendations from eNGOs and IFCAs to apply the IFCA codes of practice for cuttlefish trap handling and washing practices across the Channel was suggested. 

Some stakeholders suggested the proposed MCRS for cuttlefish should be set to 10cm or less, while others proposed bringing forward an MCRS for other species, such as those targeted by flyseiners, or lesser spotted dogfish and smoothhound, due to variations in life histories and vulnerability to fishing pressure and slow development. Also suggested was an MCRS for all fisheries with high survival rates, and quotas with bycatch provision for fisheries with low survival rates. 

Many stakeholders from all sectors called for immediate and more robust measures to manage flyseiners in the Channel. Suggestions ranged from banning all flyseiners, prohibiting flyseining inside the 0 to 12nm zone or limiting the total number of permitted vessels. A number of responses included recommendations as a priority, such as gross tonnage limits, short-term seasonal closures, a 100mm mesh size, and increased monitoring in situ (through onboard observers or REM) supported by better enforcement. A further suggestion was that all fish caught must be landed, with any in excess being sold not for profit. It was suggested that engine power restrictions would not be enough of a restriction as they would be difficult to monitor and enforce, while rope length should be a short-term priority to limit effort while other measures are developed.  

Conversely, some in the catching sector opposed the proposed management on flyseiners citing an unfair bias against flyseine vessels because the proposed measures disproportionately targeted these vessels. Some felt that banning gear types for efficiency would be a backwards step as it focuses on flyseining rather than the wellbeing of the stock. Stakeholders indicated an 80mm mesh size was necessary for economic stability and compatible with minimum landing size for the target species. Additionally, it was stated that the other proposals would increase operational costs, compromise safety and increase crew working hours.  

Several respondents from eNGOs, IFCAs and the catching sector suggested that the proposed minimum 100mm mesh for flyseiners should be extended to trawlers across the Channel to improve NQS selectivity. Some eNGO and IFCA stakeholders proposed an increase in mesh sizes for towed gears in combination with spatial and temporal closures to promote ecosystem health. Other catching sector stakeholders believed targeted fisheries, such as squid and cuttlefish, should operate with a mesh size relative to the catchability of the species, which would remove unintended bycatch.  

There was a concern expressed by some that current management of the towed gear offshore sector falls short of meeting FMP objectives. Several eNGO, catching sector and IFCA stakeholders proposed measures on towed gears, for example limiting engine capacity inside the 0 to 6nm zone, or the 0 to 12nm zone, restricting trawl vessels from working up to the shore or introducing input or output controls to limit trawl effort.  

Some from the catching sector, IFCA and eNGOs suggested looking at technical measures as a way of managing the fishery, such as by using square mesh panels to help reduce discards or gear modifications alongside spatial-temporal closures in high bycatch fisheries.  

Some from eNGOs felt the proposed approach to octopus lacks ambition and didn’t align with precautionary requirement set out by the Fisheries Act. Suggestions for further action from eNGOs and the catching sector included introducing a MCRS, annual management plans, closed seasons during spawning periods, a maximum daily catch, limits on the number of traps per working hour at sea and minimum mesh sizes suitable for regulating fishing on cephalopod species. Using REM to monitor fishing activity was also proposed. 

Some eNGO stakeholders proposed catch limits for all NQS, using the ICES precautionary approach to data limited species, and considering welfare and sentience in harvest rules. Alternatively, some stated they wanted a greater emphasis on early technical measures following the precautionary principle, focusing on specific gears.  

Some recreational, eNGO and interest group stakeholders stated they wanted more management for smoothhound, gurnards and red mullet that prioritises the recreational sector and coastal communities. Another proposal from the catching sector was to better use retired fishers for engagement and decision making.  

Some stakeholders from the catching sector felt that it was not possible or was too premature to introduce multi-species approaches to NQS. 

Some stakeholders from the catching sector wanted to see foreign vessels banned from the 0 to 12nm zone, and foreign vessels operating in UK waters to land in UK ports. Others within the catching sector wanted to see harmonised measures across UK boundaries. 

A number of stakeholders across sectors highlighted the need for robust and reliable data and effective monitoring of all removals to inform management and compliance. Several stakeholders from IFCAs, eNGOs and the catching sector strongly supported the use of innovative technologies and REM as a cost-effective tool for data collection- some pushed for more urgent introduction of these technologies. Most of this focus centred on flyseining, but also extended to other fisheries. One IFCA suggestion was the application of REM to help evidence catches with an immediate emphasis on vessels over 15m. 

Stakeholders stated several cuttlefish evidence requirements, such as using pre-season and mid-season surveys to track stock and enable adjusting removal levels, or more on the vulnerability of cuttlefish eggs to disturbance.

Question 9: How would you like to be involved in the delivery of the plan and the future management of Channel demersal NQS? 

Almost all the stakeholders stated they wanted to be involved in the future, either supporting data collection and closing evidence gaps, providing expertise, helping design measures or having an input in decision making. There were offers to facilitate government and industry interaction and use existing membership or representation mechanisms.  

A number of stakeholders from the catching sector suggested that government needs to do more to facilitate involvement, such as providing financial support or delegating decision making and responsibilities to adopt true co-management. Some others felt co-management and decision making should be restricted to those who are most invested in the fishery but providing other fora for others to voice opinion. While others wanted to be engaged through existing UK-EU channels, some from eNGOs and interest groups cited the greater need for involvement of these bodies in Channel demersal NQS management.

Question 10: Are there any important connections with or links to other fisheries that we should consider when finalising this FMP or during its implementation process?  

Respondents from the catching sector, eNGO and interest groups highlighted the opportunity to connect with and draw from international examples, such as in Maine, USA with an established FMP for a similar fishery, rather than reinventing the wheel on fisheries management. There were some calls from eNGOs for government to follow the United Nations Food and Agriculture Organization (UN FAO) Fisheries Management guidelines in future FMP development, and to work with the EU to ensure plans are meaningful and effective. More specifically, a formal mechanism with France was proposed to regulate the offshore cuttlefish fishery to help sustain the inshore fishery, in addition to recommendations on Channel wide data gathering and management with the EU. 

Many stakeholders across the catching sector, recreational sector, IFCAs, eNGOs and interest groups felt that due to the nature of mixed fisheries there needs to be better connectivity and understanding of differences in fisheries and fishers. Some requested greater support and recognition for inshore fishers, others saw an opportunity for regulatory alignment as well as harmonisation and diversification of opportunities within the fishery. Others observed interactions between FMPs would create a complex regulatory framework which would be difficult to follow and enforce. Comprehensive education, training and guidance would be needed to ensure compliance.  

Several catching sector stakeholders believed the impact and displacement of the cuttlefish fishery under this FMP, such as the proposal for an MCRS, would increase pressure on other species and mean a loss of economic viability. Some stressed that without controlling the population of cuttlefish, they would impact on the viability of other stocks.  

Some eNGO stakeholders highlighted the need for precautionary measures for bib and pouting as a bycatch to gadoid fisheries. Some catching sector and interest group stakeholders highlighted connections with the scallop fishery and impacts associated with bycatch, displaced effort and for some a need for restrictions to dredgers. 

Several respondents from IFCAs, eNGOs, interest groups and the recreational sector suggested the FMP seeks closer ties with the bass FMP to manage bycatch of smoothhound and lesser spotted dogfish, some suggested introducing precautionary management directly.  

Some catching sector observations noted displaced flyseine effort could move to the Celtic Sea, impacting habitats and hake stocks.  

There were recreational sector requests to consider an FMP for some additional species, such as grey mullet, flounder, wrasse and gilthead bream.  

There was an interest group request for a more holistic view and an ecosystem approach.  

Some stakeholders from eNGOs and interest groups suggested REM was a must for managing and evidencing fisheries interactions, but some catching sector responses noted that the FMP and REM plans timescales were not consistent.

Summary of responses to the 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 Channel demersal NQS 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 suggested that it would be beneficial to gather additional data, including landings data, and that further stock-specific evidence should be collected. It was suggested that evidence should consider how fisheries are changing and the impact climate change could have on stocks in the future.  

Several stakeholders highlighted historical data that has been gathered and suggested this could be used to inform our understanding of the current marine landscape. Stakeholders also felt that it would be beneficial to gather further data to better understand the extent of interactions between cultural heritage and the impacts of each fishery. 

It was suggested that we draw on Seasearch data to better understand the importance of benthic habitats for commercial and prey species and that information from Fisheries and Aquaculture and Seafish publications could be used to help understand different fishing methods and gear types.  

Stakeholders encouraged us to explore data from vessels that use different mesh sizes, particularly the impact an 80mm mesh size and a 100mm mesh size can have on catch composition. 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 inshore fisheries management, gear trials and interspecies impacts.

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

The importance of considering data when assessing the impact of the FMP was raised by several stakeholders. Some stakeholders felt that there is insufficient evidence to assess the environmental impact associated with the policies in the FMP.  

A range of different views were provided regarding the environmental effects associated with the policies in the Channel demersal NQS FMP. Some stakeholders highlighted concerns about the proposed actions in the FMP. For example, concerns were raised about the impact predatory species such as cuttlefish could have on fisheries, and it was suggested that fisheries management should account further for the impact of predatory species.  

Stakeholders also raised concerns about potential negative environmental impact if the FMP relies solely on MCRS for the protection of juvenile fish. In addition, stakeholders stated that there is a lack of data to suggest that the MCRS lengths proposed within the FMP will help achieve the aims of the FMP.

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?   

Multiple stakeholders suggested that there should be more actions to mitigate the environmental impact of the FMP and that action should be taken on a precautionary basis where data is insufficient. Some stakeholders felt the introduction of the new management measures proposed through the FMP should be accelerated. In particular, some stakeholders felt the management of mobile demersal gear should be introduced urgently due to its impact on non-target species and the benthic environment. Some stakeholders felt that the introduction of REM should be prioritised as current reporting requirements do not show all catches. Some stakeholders felt that management should remain flexible so the UK can respond quickly to environmental changes. 

Additional suggestions included more focus on developing multi-species broodstock fisheries as there were concerns that MSY would not protect this type of fishery. It was also suggested that trialling gear modifications would be beneficial to reduce benthic impact, bycatch, and juvenile fish mortality. Although in the meantime, spatial closures and other similar measures should be introduced. 

Multiple concerns were raised about the content of the FMP and the impact its proposals could have on stocks. Several stakeholders suggested that the proposed MCRS for cuttlefish would have negative economic and environmental impacts and should be removed from the FMP. Alternative management measures such as seasonal closures were suggested to manage cuttlefish. 

Some stakeholders requested further detail on the introduction of the actions proposed in the ER, including timelines and division of responsibility for different actions. Stakeholders encouraged measures to focus on spatial management, carbon emissions from fishing, as well as applying a wider approach to mixed fishery management.

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?   

A small number of stakeholders stated that repetition and language divergence across the FMP hindered their ability to fully consider the ER. 

Other suggestions provided by stakeholders included promoting the cultural heritage of fishing, building artificial reefs, banks and wrecks to improve youth recruitment as well as protecting the marine environment and considering the needs of the inshore industry. 

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 affects are significant or require mitigation or policy changes 
• include clearer links between 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 Channel demersal NQS ER should have stronger links to other reports and regulations including: 

• river basin management plans  
• UK Marine Strategy (UKMS) part 3 to revised and adopted part 3  
• OSPAR quality status report  
• biodiversity duty  
• newly designated highly protected marine areas (HPMAs)  

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.

Government response: FMP

Overview 

The FMP will manage how we fish our demersal non-quota species stocks in the Channel, so that the full benefits of the fisheries will be available to fishers and their local communities.     

We will improve our science and evidence to better understand these fisheries. We will continue working collaboratively with stakeholders to identify how we can close the main gaps affecting how we manage these fisheries. We will focus on developing having better stock assessments, including reference points to set sustainable harvest limits. 

In the short term, we intend to introduce the following measures:    

• a minimum conservation reference size for lemon sole (25cm), turbot (30cm), brill (30cm)   
• an engine restriction of 221kW for flyseining vessels in the English 0 to 12nm zone in ICES areas 7d and 7e 
• a minimum mesh size (100mm) for flyseiners in ICES areas 7d and 7e  
• we will introduce voluntary measures including guidelines to promote sustainable fishing for recreational anglers 

We will establish a Channel management group and also bring stakeholders together within 6 months of publication of the FMP to develop an action plan for the cuttlefish fishery. 

Over the longer-term (5 years or more), we will be considering measures to protect cuttlefish stocks to promote recruitment, monitor octopus catches and start a research plan for gathering data and managing the fishery,  placing further restrictions on flyseiners including potential seasonal closures, a ‘days at sea’ regime, rope and length diameter restrictions, a permit scheme, and extending MCRS to species caught by the flyseining fleet. 

All these measures are focussed on achieving our ambitions for sustainable demersal fisheries in the Channel for future generations.

Introduction 

This section sets out the government’s response to the Channel demersal NQS 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 that 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 options 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 this FMP. It sets out the first steps and longer-term vision necessary for sustainable management of this fishery. The plan will take time to develop and implement. It is 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, ecosystems or the marine 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.   

We recognise the concerns raised about the use of the term ‘track record’ creating a ‘race to fish’ and the risks this poses to future fishing opportunities if stocks are overfished. Should a track record be considered, there would be further consultation with potentially affected parties to directly consider such issues.  

We also recognise the concerns raised about consolidation of permits, permits gaining value and markets for permits being created. Learning the lessons from the fishing vessels licensing regime, any potential flyseining permit created would remain in the ownership and control of government or the regulators and would not be tradeable.  

We will also learn lessons from how we currently manage quota stocks before introducing any catch limits for non-quota stocks. For example, we would carefully consider whether property rights should accrue to individuals or whether fishing opportunities should remain in public ownership and control.

Changes to the FMP following consultation 

In response to many concerns about the significant economic impacts of a proposed MCRS of 23cm for cuttlefish on the trawler fleet with little or no positive effect on stock health, we are removing this proposal.  

Concerns ranged from a belief there was lack of evidence that the stock was at risk, that the measure wouldn’t work given the low survivability of the species and the impact on other species preyed on by cuttlefish, to the economic impact it would have on fishers, businesses and communities from the significant loss of revenue and jobs.  

However, it was clear from the responses that concerns remain about the overexploitation of cuttlefish, and of declining pot and trap catches in the South East Channel.  

We therefore propose to bring stakeholders together within the first 6 months of 2024 to develop an action plan to manage the cuttlefish fishery. 

Voluntary measures for recreational fishers, such as guidance on safe handling techniques or MCRS, were questioned as being less effective than enforced legislation, would not provide the required level of protection for wildlife and would be hard to police. We will support the recreational sector to develop codes of practice and evaluate its effectiveness before considering if additional steps are required.

We have now published the final version of the Channel demersal NQS FMP.

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

Engagement and collaborative working 

The majority of stakeholders 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 that extensive engagement and opportunities for input prior to the drafting of the FMPs, and during the formal consultation process, we recognise that some 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, other stakeholders, and recreational fishers can work together better in a respectful and constructive way. Both in terms of development of further FMPs and in relation to the implementation of them. This will include developing 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 that more accessible summaries were prepared and 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 (whilst 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 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.

The devolved administrations 

There were questions raised about how the measures will work across borders with the devolved administrations. 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)  

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 the 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. 

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

Government response: environmental report 

Introduction 

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

An SEA is a formal process to assess the effect of a plan or programme on the environment. It 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 Channel demersal NQS FMP. The environmental report (ER) sets out the findings of the SEA process. 

Undertaking a Strategic Environmental Assessment of the draft Channel demersal NQS 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 Channel demersal NQS 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 Channel demersal NQS FMP and sets out recommendations on how the FMP could reduce the environmental impact of channel non-quota 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 Channel NQS 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 Channel demersal NQS FMP seeks to address. 

Stakeholders recognised the need for better data and evidence to fully assess the impact of the Channel NQS 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 response to the views provided on these topics are set out below. 

Stakeholder responses have been considered and the Channel demersal NQS FMP ER has been updated with additional recommendations. The full report will be published in 2024. The revised Channel demersal NQS FMP has considered these recommendations and adjustments have been made where appropriate.

Question 1. Evidence 

Stakeholders suggested considering a range of additional evidence to inform the environmental baseline, including species abundance data, Seasearch reports and historical data on the state of the marine environment.  

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 

Stakeholders raised several points to consider including the ecosystem effects of species removal, the limitations of using MCRS as the principal stock management measure and the survival rates of bycatch species post catch and release. There was also concern that proposed actions to collect further evidence would not prevent overfishing taking place.  

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, and where appropriate precautionary actions to address bycatch and seabed impacts related to channel non-quota species fishing. We recognise the concerns raised by stakeholders and the ER has recommended that the FMP considers more immediate actions. Specifically, that there should be clear actions to reduce or remove the impacts on the most sensitive species and in the most sensitive areas.  

Alongside introducing more immediate actions stakeholders supported the need to monitor impacts by providing more detail on timings and ownership of activities. The ER has recommended that the FMP sets out further details on how impacts will be monitored. 

Question 4. Additional comments 

We welcomed the suggestions 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 UK MS 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 UK Marine Strategy descriptors.

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

• river basin management plans    
• UKMS Part 3 to revised and adopted Part 3    
• OSPAR Quality Status Report   
• biodiversity duty   
• newly designated HPMAs  

We have amended the ER to make these links.

Annex 1: List of organisations which did not request confidentiality   

• Association of Inshore Fisheries and Conservation Authorities 
• Amethyst Fishing Company Limited 
• Angling Trust 
• Anglo Scottish Fish Producer Organisation Limited 
• Bass Angling Conservation Limited 

• Blue Marine Foundation 

• Brixham Trawler Agents Limited 
• Chapman’s of Rye/Rye Fish Market 
• Coombe Fisheries 
• Cornish Fish Producers Organisation 
• Cornwall Inshore Fisheries and Conservation Authority 
• Credit sea fishing 
• Cuttlefish Conservation Initiative 
• Devon and Severn Inshore Fisheries Conservation Authority 
• Emilia Jayne Limited/Emily Rose Fishing Limited/Mollie Jayne Fishing Limited 
• European Commission 
• Fife Producers Organisation 
• Hastings Fishermen’s Protection Society 
• Historic England 
• Humberside Fish Producers Organisation Limited 
• International Transport Workers Federation (ITF) 
• Kent and Essex Inshore Fisheries and Conservation Authority 
• Leach Fishing 
• Marine Stewardship Council 
• Mike Montgomerie Limited  

• Ministry of Agriculture, Nature & Food Quality, The Netherlands 

• Mudeford and District Fishermen’s Association 
• National Federation of Fishermen’s Organisations 
• New Under Ten Fishermen’s Association Limited 
• North Atlantic Holdings Limited 
• North Sea Fishermen’s Organisation 
• New Under Ten Fishermen’s Association Ltd  
• Office for Environmental Protection 
• Plymouth Fishing and Seafood Association 
• Rederscentrale 
• Scottish Fishermen’s Federation 
• Shark Trust 
• Sole of Discretion Community Interest Company  
• South Coast Angling Club 
• South Coast Fishermen’s Council 
• South Devon and Channel Shell fishermen 
• South Western Fish Producers Organisation 
• Southern Inshore Fisheries and Conservation Authority 
• Sussex Inshore Fisheries and Conservation Authority 
• University of Southampton 
• Waterdance 
• Wembury Marine Conservation Area Advisory Group and Cuttlefish Conservation Initiative 
• Western Producers Organisation 
• WWF-UK

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)