Consultation outcome

Summary of responses and government response

Updated 16 December 2025

Introduction 

This document summarises the responses received to the public consultation on the Southern North Sea demersal non-quota species (NQS) fisheries management plan (FMP) and the associated environmental report. It also sets out the government’s response.

Consultations took place at the same time on 4 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 3 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 

FMPs are a requirement of the Fisheries Act 2020 (‘the Act’). The Environmental Improvement Plan (EIP) for England 2025, 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.

Background to the consultation 

The consultation on the Southern North Sea demersal NQS FMP was held between 10 October 2024 until 19 January 2025. 

The consultation was conducted: 

• using Citizen Space (an online consultation tool) 

• by email 

• 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 channels.

Overview of responses 

In total, we received 26 direct responses to the consultation: 

• 22 were submitted using the Citizen Space online survey 

• 4 by email

The breakdown of responses consisted of: 

• 7 from the catching sector 

• 3 producer organisations 

• 3 from local government

• 3 from recreational sea fishing sector 

• 5 from environmental organisations 

• 2 from the EU and other coastal states 

• 3 others (groups or individuals not already covered)

All responses were submitted on behalf of organisations with no responses received from individuals. A list of organisations that responded to the consultation is set out in Annex 1. 

We held two meetings (online and in-person) where stakeholders were given the opportunity to discuss the draft FMP.

Online meetings were also used to gather views from a wide range of sectors and stakeholders including: 

• the catching sector 

• the wider supply chain 

• Environmental Non-Governmental Organisations (eNGOs) 

• scientists 

• academia 

• the EU Commission and EU attachés to the UK 

• others interested in fisheries management 

These engagement events were used as an additional method to seek and record views on the FMP. 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 

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 Southern North Sea. There was support for: 

• the goals, actions and management measures

• the commitment to balancing environmental sustainability with economic viability 

• recognising the importance of protecting marine ecosystems alongside fishermen’ livelihoods

There were calls for: 

• broader stakeholder engagement 

• clearer communication 

• greater inclusion of industry in the decision-making process 

 There was however no firm view on setting up a Southern North Sea demersal NQS management group. Stakeholders recognised current limitations regarding data and supported improving stock assessments and fisheries data collection, advocating scientific research and evidence-based decision-making.

Many encouraged the inclusion of species-specific protections, such as minimum conservation reference sizes (MCRS), for species like smoothhound, red mullet, and gurnards, provided they are based on robust evidence.

There was support for increased research and for taking a precautionary approach to managing growing cephalopod fisheries. There was also support for some protection, such as codes of conduct, to help provide opportunities for industry diversification while preserving ecological balance.

There was a mixed response to the proposed flyseining restrictions. Some stakeholders sought immediate action, including prohibiting the practice, to manage effort, while others felt more robust evidence was needed before seeking to implement management measures. 

Some stakeholders criticised the FMP for lacking meaningful change, favouring commercial fishing interests, and excluding scientific and environmental groups from the early FMP formulation stages. Others stressed the importance of integrating animal welfare considerations into fisheries policy alongside support for voluntary measures for recreational fishermen.

Summary of responses to FMP questions 

As part of the consultation, stakeholders were asked seven questions on Citizen Space. This allowed them to express their views on the content of the proposed Southern North Sea demersal NQS FMP. Summaries of the responses to these 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 engagement process for developing this draft FMP? 

The majority of stakeholders expressed support for development of the FMP. However, several stakeholders across sectors expressed frustration with the engagement process. A lack of meaningful change, excessive detailed information, and perceived bias in favour of commercial fishing interests but against flyseining vessels were noted. Some felt there was a lack of collaboration with wider fisheries stakeholder groups, especially scientific, environmental and academic. Catching sector stakeholders amongst others, stressed the need for effective strategies to improve participation. This highlighted industry disenfranchisement evidenced by low attendance at public consultation events. Some catching sector representatives and other non-UK government organisations emphasised the importance of discussing management measures like MCRS and gear specifications. within forums. They highlighted that discussions should take place in forums, such as the Specialised Committee on Fisheries (SCF), when considering fisheries management in shared areas. 

Some stakeholders supported UK-EU collaboration under the Trade and Cooperation Agreement (TCA) for managing the 13 FMP species and wanted closer, earlier SCF involvement. 

A minority in the environment sector felt consultations were focused on commercial interests rather than the objectives of the Fisheries Act. They warned of potential industry bias and a lack of best available science in FMP development – citing they were excluded from engagement pre-consultation. The catching sector raised concerns about replicating the Channel demersal NQS FMP, which placed restrictions on flyseine interests and came into force in December 2024. Some respondents felt Defra’s application of the precautionary principle to flyseiners in this FMP was overly precautionary. 

Some gaps were noted on fully integrating the recreational sea fishing sector into the development of fisheries management. Recommendations to improve engagement included: 

• evening meetings 

• diverse communication channels (for example tackle shops, surveys) 

• inclusive language to engage recreational fishermen 

• ensuring consultation processes are representative and effective 

Others noted the potentially high economic value of smoothhound as a recreational target species, and a decline in species like smoothhound and spotted dogfish. This was attributed to their low value use as pot bait in commercial fisheries. 

While some in the catching sector supported the overall aims of the FMP, they highlighted challenges such as stakeholder fatigue, resource constraints, and the cumulative burden of government workstreams. While there was recognition of engagement efforts by the Marine Management Organisation (MMO) the need for broader participation, better resource allocation, and a clear implementation phase to ensure meaningful outcomes were flagged.

Question 3: Do you have any comments on the goals in the draft FMP? 

The majority of stakeholders emphasised that while sustainable stock management is essential, it should take account of the economic challenges faced by fishermen. This includes for example, the rising operational costs and reduced quotas. Some catching sector representatives expressed concern about disproportionate economic burdens stemming from proposed measures, particularly in relation to smaller operators and flyseining vessels. 

There was consensus across all stakeholder groups that data gaps remain a critical issue, hindering accurate stock assessments and effective monitoring. They highlighted the need to include catch data from private and charter vessels to gain a more accurate picture of exploitation. Some advocated for more comprehensive data through the use of systems like remote electronic monitoring (REM), in particular for addressing cetacean and seabird bycatch. Improved data collection is vital to ensure evidence-based decision-making. It is particularly vital for data-poor stocks and growing fisheries like cephalopods sensitive to environmental changes and with short life cycles. Some stakeholders sought adaptable management strategies for these growing fisheries to ensure sustainability. This suggests cephalopods are fished only when profitable and operations cease if their populations decline. 

While the majority of stakeholders supported the FMP goals, they asked for clarity and specificity in their wording. Some wanted clarity on who would be responsible for their implementation and how this would be achieved. 

There were also calls for greater ambition in line with the Fisheries Act 2020 and transparency in restoration targets, performance indicators and timescales. Environmental stakeholders, in particular, sought more measurable targets, clearer definitions and precise implementation strategies, alongside bespoke approaches for both small and larger scale fisheries. Several stakeholders, notably from the recreational sector, want to see socio-economic considerations regarding communities, businesses and individuals given equal weighting to ecological sustainability needs. A need to integrate recreational fisheries data and coastal community impacts into the FMP was highlighted. Others h wanted better development of the knowledge, tools, and collaboration needed to manage fisheries and conservation efforts more effectively. They also wanted better stakeholder engagement in line with recommendations for developing scientifically based measures such as a MCRS. Alignment with broader initiatives like discards reform and strategies for reducing cetacean bycatch to support biodiversity and conservation efforts were also suggested.

Question 4: Do you have any comments on the measures and actions in the draft FMP?

Views on the proposed measures and actions were mixed both between and within sectors. Several stakeholders supported flyseining restrictions (including a full prohibition) to tackle potential overfishing, reduce mortality rates and potentially high discards and bycatch rates. Others were supportive of management measures to protect NQS species from overfishing, such as introducing a MCRS and a stricter application of the precautionary principle. 

Some producer organisations and non-UK government organisations questioned the focus on restricting flyseining, which they view as sustainable and low-impact fishing method regulated under existing measures. They argue that increasing mesh sizes to 100mm and limiting engine power to 221kW is unnecessary and potentially harmful to commercial fishermen without clear evidence of stock health benefits. They sought greater harmonisation of measures across UK and EU waters to ensure fairness and effectiveness. Perceived discrimination against both UK and EU flyseiners and an overly cautious application of the precautionary principle were highlighted by some in the catching sector. It was asserted that flyseining restrictions introduced in the Channel had led to maritime safety issues due to displacement of effort into EU waters and associated risk of overfishing in those waters. A minority also opposed the introduction of a MCRS for any NQS species and any restrictions or measures relating to the cephalopod fishery.

Environmental stakeholders, in particular, advocated for increased research and precautionary measures, to protect the growing cephalopod fisheries and provide opportunities for industry diversification. Some stakeholders across the environmental, catching and recreational sectors supported developing codes of conduct to prevent overfishing and preserve ecological balance, such as safeguarding cuttlefish eggs. Many from the environmental, recreational and producer sectors supported the use of a MCRS for species like smoothhound, red mullet, and gurnards, provided these measures were evidence based and avoid inconsistencies. Environmental, recreational and catching sector stakeholders had similar views, calling for mandatory REM to improve bycatch research and evidence gathering and inform decision-making.

Some catching sector stakeholders highlighted the importance of involving fishermen in the management process, particularly for small-scale fisheries, to ensure that regulations are practical and equitable. Industry dialogue is critical to effective fisheries management with calls for a more balanced, regional approach that considers the diverse needs of different fleets.

Question 5: Are there other measures or variations of the proposed management measures we could consider? 

Several respondents from the recreational and catching sectors supported the FMP as a comprehensive framework for using scientific evidence to assess stock status and ensure sustainable fishing practices. Many stressed the importance of balancing sustainability with economic viability and advocated for active stakeholder participation in decision-making. The catching sector in particular want further assessment of impacts before deciding on specific management measures. Instead of imposing restrictions, they suggested incentivising sustainable fishing practices.

A number of recreational and environmental stakeholders highlighted the ecological damage caused by beam trawling. They called for it to be phased out, as well as prohibiting flyseining, to address high bycatch rates and habitat disturbance, while promoting more selective, low-impact fishing methods. A minimum mesh size of 100mm for commercial vessels was suggested. 

Environmental stakeholders generally supported species-specific measures such as introducing minimum and maximum conservation references sizes, especially for finfish and slower-growing species. They sought conservation measures for vulnerable species and proposed harvest control rules for cuttlefish to avoid overfishing.

Both environmental and recreational stakeholders were keen to prioritise the implementation of REM to help reduce bycatch. Other points raised included the importance of mitigating benthic impacts and risks to seafloor integrity They called for spatial management measures, effort limitations, and improved vessel tracking to ensure compliance with wider fisheries legislation. 

Some in local government suggested aligning NQS approaches across English and Scottish waters, recommending a regional strategy due to geographical differences. 

Further suggestions were to explore alternative harvest strategies. such as Maximum Economic Yield (MEY) and ecosystem-based fisheries management. Suggestions highlighted these strategies should be supported by independent advice from the International Council for the Exploration of the Sea (ICES) on: 

• rebuilding depleted stocks 

• addressing significant data gaps in bycatch and habitat impacts

Question 6: Do you have any additional comments on the draft FMP? 

While appreciative of the summary provided within the consultation documentation, some in local government felt the length and complexity of consultation documents made them inaccessible to some stakeholders. Other sectors echoed this view noting the critical importance of stakeholder engagement, with calls for more concise, accessible communication.

There was some criticism of the FMP drafting process. Some felt that it was not transparent or inclusive, particularly concerning flyseining and lacked evidence, with an over-reliance on the precautionary approach. Some favoured including wider marine sectors in developing the FMP, given the Southern North Sea is a busy region. However, they did not want these sectors to disproportionately influence commercial fishing activities. A perceived lack of evidence regarding proposed management measures in the supporting DMA and environmental report was also mentioned.

The need for a regular review of the FMP, careful implementation and early engagement with fishermen to ensure effective outcomes was also noted. Some catching sector stakeholders reiterated concerns regarding the exclusion of flyseiners from certain zones being a potential breach of the TCA, urging adherence to international obligations. Others opposed the FMP and any proposed flyseining restr ictions.

Greater use of the SCF to discuss shared NQS fisheries, and potential negative economic impacts were also highlighted. These impacts included, for example, displacement of fishing effort into EU waters, or reduced UK quotas if NQS became TAC species. A number of stakeholders across sectors challenged Defra’s stance on voluntary measures being less enforceable than compulsory measures.

A variety of recommendations were made by recreational, catching and other sectors. They ranged from further species protection and sustainable stock exploitation for marine habitats to the diversification of commercial inshore fisheries (particularly for growing cephalopod fisheries). This emphasised the sustainability of seasonal fishing practices.

 The economic and ecological importance of species like squid (target species and bycatch) was noted, with calls for consideration of impacts on related nephrops and pot fisheries. The designation of smoothhound as a recreational-only species was suggested, in recognition of its limited commercial value but significant socio-economic importance to recreational fishermen. A ban on industrial-scale trawling within UK territorial waters, greater awareness of fish welfare and integration into wider policy objectives were also raised.

Question 7: Do you have any comments on the assessment of the environmental effects of the FMP, as set out in the environmental report? 

Stakeholder concerns focused on the FMP needing to ensure it achieves a balance between environmental sustainability and economic interests. They noted that the proposed measures might disproportionately impact fishing livelihoods in the short term. Stronger enforcement and clearer explanations were proposed to avoid conflicting regulations.

Stakeholders from the catching and producer sectors acknowledged that the environmental report highlights seabed disturbances caused by demersal towed fishing gear and other marine activities. This hinders progress toward achieving Good Environmental Status. However, they also stressed the importance of considering natural sediment movements in the assessment. Other concerns were raised over potentially biased mortality estimates for harbour porpoises in the Greater North Sea and the use of data that could lead to unrepresentative bycatch limits.

Further concerns were raised by producer sector stakeholders over inconsistencies in FMP measure. In particular gear mesh sizes were criticised for being precautionary yet are unsupported by evidence. Some stakeholders suggested the environmental report is too broad, does not focus on localised issues and focuses primarily on Marine Plans, overlooking connections to other FMPs. Others felt the environmental report lacked contextual evidence. Recommendations from various stakeholders included:

• undertake further studies on fishing gear effects on benthic resources and sediment types 

• give greater consideration to the adverse impacts on fishing communities when managing fishing in marine protected areas

Government response: FMP 

Views were diverse with a range of opinions within and between stakeholder groups. We have considered all views provided by those who responded to the consultation. This section explains the change we have made to the FMP in response to these views and why we have taken particular decisions.

Overview 

The FMP sets out how we plan to manage fishing activity for demersal NQS stocks in the Southern North Sea. The aim is towards more sustainable fisheries, and for the benefit of marine users and local coastal communities.

Following a public consultation, there was broad support for the proposed goals and actions in the FMP. There was some opposition from some producer organisations and non-UK government representatives to our proposed flyseining restrictions. However, this was counter-balanced with support across sectors for restricting flyseining activity, with some calling for a total ban for this gear type. 

To achieve the ambitions of the FMP, we will improve our scientific and evidence bases to better understand the fisheries that are included in the FMP. We will continue collaborating with stakeholders to identify how we can close the main evidence gaps affecting how we manage these fisheries.

We will conduct research into growing cephalopod fisheries and consider MCRS for certain NQS species in the medium term. We’ll also look at increasing education into species, identification, handling and welfare across the recreational and commercial fishing sectors. 

All the measures in the FMP are focused on achieving our ambitions for sustainable demersal fisheries in the Southern North Sea for current and future generations. The measures in the FMP will take time to implement. However, we will continue to collaborate with individuals and representatives across all the fishing sectors, regulators and wider interest groups on the sustainable management of the Southern North Sea NQS fishery.

Changes to the FMP following consultation

Recognising concerns about clarity and accessibility, we have amended the language in the final FMP to remove ambiguity and ensure the rationale for measures is clear. 

We acknowledge the strength of opinion from a small number of stakeholders regarding best available evidence, application of the precautionary approach and the rationale underpinning measure for managing flyseining effort in ICES Areas 4b and 4c. We reaffirm that the best available evidence including socio-economic data has been used to develop the FMP. We note that little alternative, verifiable evidence was provided in the consultation responses. Also, we recognise remaining concerns that data-poor NQS stocks are at risk of exploitation with little or no sustainability assessments. However, we will consider the implementation of these measures further and have updated the language in the FMP to reflect this.

An error in the de minimis assessment has been corrected. In paragraph 4 in the problem under consideration section, 2021 landings in ICES areas 4b and 4c were given as 11,000 tonnes valued at £21.6 million. However, the correct landings totalled 2,200 tonnes, valued at £5.9 million. We have also added a reference to the Animal Welfare (Sentience) Act 2022 in the FMP that formally recognises cephalopods as sentient beings.

You can read he final version of the Southern North Sea demersal non-quota species fisheries management plan.

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

In this section, we summarise the various cross-cutting FMP themes that emerged through the consultation responses. We explain why we have taken particular decisions. Given the volume, breadth and detail or the responses, we are not able to provide detailed explanations on all points raised.

Engagement and collaborative working

We are grateful for the support of the fishing sector and wider stakeholders for engaging with our process to develop the FMPs.

While stakeholder views on the engagement process for developing the FMPs varied, many recognised the significant efforts that went into engaging stakeholders, However, it was generally felt that it could have been better. Notably, the UK General Election in 2024 necessitated a hiatus in development and engagement. 

The collaborative approach taken was valued by the majority of respondents. However, there was some criticism that the process prioritised the fishing sector in some instances, leading to inherent bias in the FMPs.

There was little common ground between or within interests or sectors on the preferred engagement method. Some favoured tailored engagement, while others sought a fully collaborative approach. While we aim to find a balance across sectors with frequently variable views, we recognise there is scope to bring some sectors into the process at an earlier stage. This would ensure genuine collaboration.

A clear message from many respondents was recognising the importance of enabling those with a stake in fisheries, to participate in the management of those fisheries. We are committed to working with the fishing sector and wider interests to co-design FMP policies and measures. We acknowledge that a greater role in decision making carries shared responsibility to ensure we are abiding by our legal and international commitments. It also helps ensure we are balancing environmental, social and economic sustainability along with the other objectives.

As part of ongoing work to explore how we continue to develop and implement a collaborative approach to FMPs and fisheries management more widely, we held an engagement pilot. It took place in Cornwall in October 2024 and bought together commercial fishermen, regulators and government to discuss key fisheries issues, including FMPs. Future opportunities engaging a broader range of stakeholders and different areas of the country are being considered. 

Some stakeholders cited ‘FMP fatigue’ as an issue and sought more streamlined communication across plans. We welcome continued engagement with the FMP development process by all interested stakeholders. It is impractical for government and regulators to engage individually with all those with an interest, in the same way it is impractical for all individuals to engage with us. In recognition of the resource constraints highlighted by most respondents, we encourage sectors to consider how to organise themselves into representative groups to feed views into the wider FMP programme. This will reduce the associated burden of engagement.

We continue to review our engagement. Building on work initiated last year, we have improved communication across the FMP programme. We launched an FMP blog in May 2024, that brings the latest FMP developments and engagement information together on a single, accessible platform with regular updates. 

Many respondents called for continued participation through to the implementation phase of the FMPs. Stakeholder involvement and ongoing collaboration underpins successful delivery of the FMPs and will continue into the implementation phase.

Consultation process and documentation 

Many respondents criticised the large number of FMP consultations. Combined with other policies relevant to the fisheries sector, they create an overwhelming engagement burden, leading to calls for a coordinated approach across government. While we recognise the resource impacts for industry and wider stakeholders, the formal consultation process gives all interested parties the opportunity to give their views and help shape the developing FMPs. This is in line with the co-design principle supported by the majority of stakeholders. It also recognises the guidelines for public consultations and our statutory requirements.

As mentioned, efforts to find common ground and form representative organisations within or across sectors is encouraged, to help minimise the resource burden. Moreover, we would be interested to understand from stakeholders their views on streamlining engagement on fisheries management issues more generally.

Some respondents felt the consultations lacked sufficient scientific evidence to support the main consultation documents. Our consultation approach is designed to be transparent and provide evidence and supporting material to help stakeholders provide informed responses. It follows extensive engagement and informal consultation prior to the draft FMPs being developed. 

We learned valuable lessons from the consultation process on the first set of FMPs in 2023. In response to stakeholder feedback, we adopted a different approach. We aimed to strike a better balance between the volume of consultation documentation and also ensuring stakeholders have sufficient information to engage meaningfully with the consultation process. We reduced the overall volume of material, the number of consultation questions and incorporated evidence directly supporting the proposed goals or measures into each plan. We published the more detailed evidence statement during the consultation period so those who want further background information can read it. We acknowledge doing this in parallel with launching the consultation would have been more beneficial for some respondents and will make this happen in future consultations. 

Inconsistent language across FMP documentation was raised as an issue by some stakeholders, making it difficult to understand the rationale for proposed or timescales for delivery. We acknowledge that FMP terminology has been variable and are working to simplify it where possible. We are also working to ensure greater consistency across the FMPs and all future plans.

Consultation is an on-going process. Our aim is to strike a balance between formal and informal consultation activity that allows those impacted by the policies to meaningfully engage in the process. We will continue to consider different approaches in future as well as how much information is published at various stages.

Implementation and pace of change

In December 2024 following public consultation, we took the decision to amend the timescales for FMP production and publication contained in Annex A of the JFS. The decision was made after changes to scientific advice and a pause in work resulting from the 2024 UK General Election. 

Some respondents expressed a strong desire for clearer commitments and more specific and faster timescales for delivery of actions. This issue was raised in earlier FMP consultations and changes made accordingly to deliver some key changes more quickly. However, it has led to fresh concerns about the impacts of delivering change too quickly on the fishing industry. It includes a need for continued stakeholder involvement in designing FMP measures. We have therefore balanced views against resources and a recognition that too much change would not be deliverable or could create unreasonable burdens on the fishing sector. 

Many of the actions in the FMPs are to gather more data and consider options. This is because most of the plans cover non-quota stocks which have little management and are data poor. This requires new evidence to ensure appropriate measures, based on the best available scientific advice, are introduced. We are learning continuously and through implementation of the FMP actions, changes will be made to the fisheries management. The FMPs will be reviewed at least every six years.

We are working collaboratively with sector representatives to define how best to deliver the goals of published FMPs. This approach will continue during the implementation phase of these plans.

Some stakeholders raised the issue of REM and were keen for it to be mandatory to facilitate monitoring and compliance of FMPs. We are considering collaborative and innovative ways of gathering and using data, including technologies such as REM.

Cumulative impacts 

Questions were raised about the cumulative impacts of FMP measures, both within and across the plans. as well as overlap with other policies and activities in the marine environment that contribute to spatial pressures on the fishing sector.

FMPs are designed to appropriately balance impacts. This includes being mindful of maintaining economic viability without jeopardising the sustainable long-term recovery of stocks or delivery of a healthy marine environment for all sectors. Impacts are considered as plans are developed, ensuring they are deliverable. As those plans are implemented, further consideration of the cumulative impacts of measures will be made. Our collaborative approach to delivering FMPs, will enable the fishing sector to contribute its information on activities and impacts to help co-design management actions.

We have heard very clearly, the concerns about increasing spatial pressures and continue to talk to the fishing industry and wider government about these issues. The cross-government Marine Spatial Prioritisation programme continues to engage with various sectors to discuss potential barriers and solutions to co-location.

Our FMPs recognise that displacement of fishing effort can result from the introduction of spatial, and other restrictions. To address this, actions to monitor and where applicable mitigate displacement and its social, economic and environmental impacts have been included.

FMPs allow for adaptive management and so can take changes in evidence or wider use of the seas into account in their implementation.

Application of the precautionary approach

Respondent views on the application of the precautionary approach varied between and within sectors. Some called for management measures of data poor stocks to be prioritised. Others were concerned about the risk of potential social and economic impacts in its application. Questions were raised about the process for developing precautionary management measures, particularly within mixed fisheries, and how stakeholders would be involved. 

In line with the Fisheries Act, FMPs set out goals and measures to manage stocks sustainably based on the best available scientific advice and using a precautionary approach where there is insufficient data. Lack of data is not a reason to not act or postpone the implementation of effective management measures that will conserve a stock or its environment. Decisions on precautionary management measures must be balanced and proportionate alongside the other fisheries objectives. This approach will also take account of wider responsibilities including international agreements.

In response to feedback, we have strengthened the language in the FMPs, making clearer the factors used to determine precautionary measures. Our aim is to work with the fishing sector and wider stakeholders to develop and agree the right precautionary measures to proportionately manage the risks and ensure fish stocks are sustainable into the future.

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

A number of EU respondents raised the importance of ensuring sufficient engagement opportunities in the FMP development process, and at an early stage. While membership of working groups established to develop the draft FMPs appropriately consisted of UK stakeholders, plans are required to go through a public consultation giving all interested parties the opportunity to provide their views.

The importance and value of close working with other coastal States on fisheries management, particularly for shared stocks, continues. We are working with the EU to pilot new ways of working on FMPs at earlier stages of development and on implementation of published plans. This will strengthen cooperation and our collaborative relationship.

EU stakeholders were keen for measures to be developed through the SCF, to harmonise fisheries management and make implementation more effective. Recognising the transboundary nature of fisheries and working collaboratively with coastal States were also encouraged by some of our domestic stakeholders. While it is not a requirement to discuss FMPs at the SCF (or for the EU to discuss their policies), co-operation with the EU on the management of shared stocks will continue. For example, the UK and EU will discuss a multi-year strategy for king scallops, and we will continue to engage with the EU during the development and implementation of FMPs which will affect EU vessels. 

EU stakeholders were also concerned that proposed measures might affect access arrangements agreed under the TCA. They strongly emphasised the principles of cooperation, proportionality, non-discrimination and using best available scientific evidence to manage stocks sustainably. The TCA preserves the regulatory autonomy of the UK to manage its fisheries while ensuring that the interests of the EU and vessels of member states are properly considered. FMPs have been developed to ensure the UK complies with its obligations under the TCA including during the implementation phase when proposed measures may be taken forward.

A few respondents disputed our application of the precautionary principle, and the interpretation of best available scientific advice under the TCA. It is right to pursue policies and consider the introduction of measures in order to protect stocks. The FMPs have been designed to balance the requirements of the Fisheries Act, along with the UK’s international obligations. including those in the TCA. This includes basing measures on the best available scientific advice and adopting the precautionary approach where appropriate. Additionally, FMPs allow us to introduce bespoke, evidence based and adaptive management.

FMP evidence and data

Most respondents were positive about the approach to developing an evidence pathway that promotes collaboration between industry, academia and fisheries managers to address evidence gaps. We will continue with this approach.

We acknowledge the substantial amount of evidence that needs to be collected to fill existing gaps. We also acknowledge the questions raised about the government’s ability to address: 

• evidence gaps 

• timelines for delivery 

• making FMP evidence more accessible to the fishing industry 

We are starting to address some of the highest priority gaps through Defra funded research projects including improving data collection and stock assessment methods, exploring sustainable fishing practises and management tools and improving the social and economic evidence base of FMPs 

FMPs are a priority for fisheries funding. The Fisheries and Seafood Scheme (FaSS), provides financial assistance for projects that support the development of the catching, processing and aquaculture sectors, and for projects that enhance the marine environment. The latest round of funding announced on 9 June will support projects in the 2025 to 2026 financial year covering science fisheries partnerships. Projects will be required to collect data to address evidence gaps identified in FMPs.

However, it will not be possible or appropriate for the government to fund all the evidence gaps identified across the FMP programme. Prioritisation of FMP evidence gaps continues alongside looking at innovative ways to fill those gaps, including for example remote electronic monitoring. Where evidence gaps identified in these FMPs are prioritised, timeframes may be bought forwards.

We continue working with the fishing sector and wider stakeholders to support the delivery of evidence requirements. An event held in March, explored the future direction of collaborative science for FMPs. It included a call subsequently issued to industry and wider stakeholders seeking their help to provide the evidence required to support the phased approach of FMP delivery and implementation. 

Some stakeholders were keen for the scientific advice used to inform the development of management measures, to be more clearly evidenced in the FMPs. Others emphasised the importance of adhering to the TCA principle of using the best available scientific advice and collaboration with EU scientific bodies. 

There were also a few comments about FMPs not contributing to the ICES scientific advice benchmarking process, which appear to have been misunderstood. UK scientists make a significant contribution at all levels of its advisory process, including on the Science and Advisory Committees and through participation in expert groups. We continue to determine FMP policies and management measures informed by the best available scientific advice, including that from ICES. 

A number of respondents felt the FMPs could be strengthened by the addition of harvest control rules (HCRs) or harvest strategies based on alternative biomass reference points. In line with the Fisheries Act, the overarching harvest strategy for all FMPs is for fisheries to be managed sustainably. FMP harvest strategies can include appropriate HCRs which will require a sufficient level of data and understanding of a stock to be developed and implemented.

Government response: environmental report 

This section sets out the government’s response to the Southern North Sea demersal NQS FMP Strategic Environmental Assessment (SEA), environmental report consultation. 

Stakeholder responses have been considered and the Southern North Sea demersal NQS FMP environmental report has been updated with additional recommendations. These updates have been considered in the revised FMP. The full environmental report has been published alongside the FMP.

Changes to the environmental report following consultation 

Some stakeholders noted the reports highlights the widespread disturbance of seabed habitats by demersal towed fishing gear and marine activities, preventing good environmental status. While other stakeholders emphasised the importance of accounting for natural sediment movements when considering seabed disturbance. It is our view that the statutory nature conservation bodies (SNCB) advice for the FMP provides sufficient evidence at this stage to determine the potential effects of fishing on the benthic environment. We acknowledge that further studies would be useful but would be directed by the Benthic Impact Working Group, as set out in the report.

We note concerns about the evidence used within the environmental report related to harbour porpoise bycatch. We acknowledge that there may be discrepancies in the data used by the underlying studies referenced. In response, we have proposed to gather more data on bycatch to better our understanding. 

To address concerns that the report focused largely on marine plans, raising questions on relevance for in-combination effects of the FMP, we have added additional detail for clarity. Marine plans are helpful tools that: 

• set out priorities and directions for future development within the plan area 

• inform sustainable use of marine resources and help marine users understand the best locations for their activities

Marine plans also consider all marine activities, resources and ecosystems. This means assessing FMP policies against marine plan policies is the most efficient way of determining how FMP policies will broadly interact with other marine activities. It also ensures compliance with section 58 of the Marine and Coastal Access Act 2009.

Another concern was that the FMP does not address where different gear types are allowed to use different mesh sizes such as 80mm mesh for otter trawl vessels and 40mm gear for other demersal NQS fisheries. In comparison, flyseiners would have to use 100mm mesh sizes.

Having different mesh size requirements for different gears can already be found in fisheries management for different reasons, such as improving juvenile survivability. While there were some concerns about the impact of other bottom-towed gear types and other methods of fishing, flyseining was identified as a priority for introducing stock protection measures. Introducing effort management for vulnerable and data-poor NQS in a new fishery with large capacity vessels, is based on the best available scientific evidence. It is also supported by the precautionary objective in the Fisheries Act. However, we will consider implementation further and have updated the language in the environmental report to be consistent with the updated wording in the FMP.

Annex 1: List of organisations that did not request confidentiality 

• Angling Trust 

• Bass Angling Conservation 

• Blue Marine Foundation 

• Comité National des Pêches Maritimes et des Elevages Marins 

• Comité régionale de la pêche maritime et des élevages marins Hauts-de-France 

• Cuttlefish Conservation Initiative 

• East Anglian Charters

• Eastern England Fish Producers Organisation 

• Eastern Inshore Fisheries and Conservation Authority

• European Association of fish Producers Organisations 

• Fishing Forward UK 

• French authorities 

• Historic England 

• Humberside Fish Producers Organisation Ltd 

• Joint Nature Conservation Committee 

• Kent & Essex Inshore Fisheries and Conservation Authority 

• National Federation of Fishermen’s Organisations

• Natural England

• Nederlandse Vissersbond 

• North Sea Advisory Council 

• North Sea Fishermen’s Organisation 

• Northumberland Inshore Fisheries and Conservation Authority 

• Office for Environmental Protection

• The Open Seas Trust 

• Permanent Representation of Belgium to the EU 

• Scottish Fishermen’s Federation 

• Scottish White Fish Producers Association 

• Shark Trust 

• Whale and Dolphin Conservation 

• Wild Animal Welfare Committee