Proposed North Sea and West of Scotland Megrim Fisheries Management Plan

Environmental considerations

Conservation Advice

In addition to the requirements of the 2020 Act, FMPs are subject to legal duties and requirements relating to the protection of the natural environment arising from legislation such as the Habitats Regulations, the UK Marine Strategy Regulations 2010^[15], and the UK Marine Policy Statement^[16], the Environment Act 2021, Marine and Coastal Access Act 2009, and The Marine (Scotland) Act 2010.

Alongside these requirements, FMPs seek to support a range of other existing environmental policies that focus on, enhancing the health of our seas for future generations, restoring marine biodiversity, and tackling the causes and impacts of climate change.

To support the development of policies aimed at protecting the natural environment, Statutory Nature Conservation Bodies (SNCBs) provided conservation advice for the Scottish-led demersal FMPs. This advice was developed to cover all demersal FMPs. This approach was deemed appropriate given the similarities between the impacts associated with demersal gears used in these fisheries, but FMP specific issues are also considered in the advice. SNCBs have also provided separate conservation advice for individual demersal FMPs that cover English waters.

Conservation advice considered risks relating to Marine Protected Areas (MPAs), Priority Marine Features (PMFs) (Scottish waters only) and UK Marine Strategy descriptors of Good Environmental Status (GES). The advice provides a pragmatic steer on where the greatest concerns lie for interactions between the relevant fishing gear types and the designated features of MPAs, PMFs, and UK Marine Strategy descriptors.

The demersal FMP advice identified otter trawls, pair trawls, beam trawls, and demersal seines - collectively referred to as demersal trawls and seines - as well as static nets targeting monk/anglerfish and longlines targeting hake, as the most primary gear types for consideration. For the Northern Shelf megrim FMP demersal trawls and seines are the most relevant gear types.

The SNCBs developed a ‘risk rating’ which is intended to help identify where the greatest impacts of fishing are likely to occur. A three-point scale has been used in the conservation advice: low, moderate and high risk. Activities with a moderate risk indicate that fisheries management authorities may need to take additional action to reduce the impact of fishing or, in some cases, improve the evidence base in order to more accurately assess risk in the future. For activities with a high rating it is generally suggested that action will be needed. The advice noted that more detailed information on gear types, location and fishing effort would improve the ability to assess environmental risks associated with each FMP and could alter some of the risk ratings presented.

The evidence and advice that has been provided by SNCBs underpins the proposed actions in the ‘policies’ section of this FMP, in particular Policy 4: Deliver wider sustainable management by taking steps to minimise the impact of the Northern Shelf megrim fishery on the marine ecosystem. Policies 1 and 2 also directly support the delivery of improvements to the UK Marine Strategy descriptors relating to stock health. It is important to note that many of the actions that sit under these policies support work already underway.

It should also be recognised that the act of fishing in general, by its very nature, impacts on marine species and the marine environment in which fishing boats operate. However, understanding and, where possible, mitigating these risks and impacts, is an important part of effective fisheries management. In particular, the need to balance environmental action with consideration of the socio-economic benefits that fishing brings, is an important component of fisheries management.

MPAs and Priority Marine Features (PMFs) (Scottish waters only)

The conservation advice identified that demersal fisheries, including fisheries for megrim, have the potential to impact the designated features of MPAs and PMFs (in Scottish waters) in three ways:

• Through bycatch and entanglement of species that are designated features of MPA and PMFs (Scottish waters);
• Through removal of key prey species on which designated species depend;
• Through physical impacts on the seafloor resulting in habitat impacts.

The advice recognised that measures have already been introduced, or are in the process of being introduced, which seek to mitigate the impact of demersal fishing in MPA areas, in Scottish, Northern Irish and English waters, covering the above three impacts. These are not specific to megrim, but are covered by actions relating to demersal fishing activity in general. However, potential risks remain to designated mobile species when they move outside of the protection of the MPA.

For MPAs, risk relating to bycatch of mobile species (e.g. marine mammals and seabirds) in demersal trawls and seines is deemed to be moderate, with some species such as the basking shark and flapper skate as well as several deep-water fish species, including elasmobranchs, potentially at a greater risk. Gathering additional evidence on bycatch will help improve the evidence base and support improved management and actions relating to this are set out under the actions section.

The risk rating for bycatch in static nets and longlines is high. Static nets are not generally used in megrim fishing. Actions relation to this are contained within the actions section.

Finally, there is also a moderate risk relating to removal of juvenile gadoids which are considered important prey species for designated species. More evidence is needed on impacts and to aid understanding.

For PMFs (Scottish waters), the risk rating for bycatch in mobile demersal gears is considered moderate. However, further evidence collection to better understand the issue could lower this risk in the future. A moderate risk rating also applies for bycatch of PMFs in longlines (this is reduced from the MPA assessment as the PMF list does not include birds). However, monitoring of commercial species bycatch, including sensitive fish and elasmobranch PMF species is currently limited and further research is needed to understand the risk to these species. This issue is considered as part of the actions section, which sets out current and planned additional evidence gathering and bycatch mitigation which includes positive actions already being undertaken by the fishing industry.

The risk rating for physical impacts to benthic and habitat PMFs from mobile demersal gears is considered moderate, due to the fact that these features will be offered some protection through the MPA management process. The advice notes that physical impacts from static demersal gears are likely to represent a lower risk to benthos but there may be areas where high intensity static fishing can have a moderate impact on PMF habitats and benthic features through physical disturbance.

This topic is explored further in Policy 4 ‘Deliver wider sustainable management by taking steps to minimise the impact of megrim fishery on the marine ecosystem’. Some actions to address impacts are already underway such as the introduction of inshore VMS and increasing the frequency of VMS reporting; incentivising the use of selective fishing gear and fishing techniques that have a reduced impact on the environment; and the implementation of fisheries management measures being introduced to existing MPAs and for PMFs (Scottish waters).

UK Marine Strategy Descriptors

The UK Marine Strategy Regulations^[17] require management action to be taken to achieve or maintain GES in the UK marine area. The UK Marine Strategy Part Three: UK Programme of Measures outlines the actions and initiatives that are being taken across the UK to achieve this.

The conservation advice for demersal species focussed on the most relevant descriptors (D1 biodiversity, D3 commercial fish and shellfish, D4 food webs, D6 seafloor integrity and D10 marine litter). The advice also noted that additional consideration of screened-out descriptors may be required in the future and that the status of many of the current indicators are currently ‘uncertain’ or ‘unassessed’ and as the evidence base develops, the advice pertinent to those descriptors will need to be updated.

The conservation advice identified a number of risks from demersal fishing covering activities across the Demersal FMPs (not just those risks specific to fishing for Northern Shelf megrim). This included: a moderate risk from demersal trawls and seines to achieving GES for marine mammals and seabirds through bycatch and prey reduction; a high risk to seafloor integrity due to benthic disturbance caused by mobile demersal fishing activities; and a moderate risk relating to marine litter. There is also a high risk from longlining to achieving GES for seabirds due to bycatch.

This topic is explored further as part of Policy 4 ‘Deliver wider sustainable management by taking steps to minimise the impact of megrim fishery on the marine ecosystem’. Some of the actions to address impacts are already underway such as the work to introduce specific fisheries management measures where these are needed to protect specific marine features, for example, by supporting improved accuracy of fisheries spatial data through the introduction of inshore VMS. Relevant longer term actions include collaborating across the UK to develop policy to reduce/eliminate sensitive marine species bycatch in the UK.

In relation to marine litter specifically, there is ongoing work with regard to the Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) to implement the second Regional Action Plan on Marine Litter. This includes action to tackle marine litter from land and sea-based sources, including fishing.

Climate Change

The fisheries sector is facing several critical climate change issues and there is a need to collectively address these and co-develop solutions. The evidence base has made significant progress in the last decade with much greater focus on climate change impacts, adaptation^[18] and mitigation^[19] both from policy and industry.

The impacts of climate change are already apparent in the marine environment. We are already seeing warm water species increasing in abundance in UK waters while some cold-water species have decreased, with these trends expected to continue in the future. For species such as Northern Shelf megrim, it is likely that habitat suitability for the species will change, resulting in more favourable conditions for the species to live in UK waters in the longer term. The impacts in terms of biomass are not well understood and are also dependent on other broader factors such as fishing pressure, and the trends in prey and predators for a given species.

The potential changes in species distribution will have consequences for commercial fisheries, and are likely to affect fishing behaviours, fishing quotas and will require adaptive management.

Fishing can play a positive role in addressing climate change through providing high-quality protein with a lower carbon footprint. The UK policy authorities have different targets relating to climate change and are developing plans to support the drive towards net zero.

To support delivery of the climate change objective in the 2020 Act, the fisheries policy authorities will continue to take management decisions and negotiating positions that are evidence-based, setting fishing limits that are informed by the best available scientific advice, to support the ongoing resilience of fish stocks and the fishing fleets which rely on them.

FMPs set out our approach to increasing or maintaining sustainability of fish stocks and as additional evidence is developed, this will help fisheries managers to respond to changes in the status of stocks.

As found throughout the current literature^[20] the recorded changes in climate are already shifting species distribution, altering major life events such as spawning and hatching, and changing the productivity levels of marine organisms. As the distributions of commercial species shift geographically, fishing grounds increase or decrease in importance, while extreme weather events become more frequent, impact on the fishing industry is inevitable. The three UK administrations will work with the fishing industry to help them adapt to the impacts that climate change will have on commercially important species and will contribute to the collective efforts to mitigate the impacts fishing has on climate change.

Several studies have modelled large-scale and long-term future changes in fish abundance and distribution in response to climate change. However, a level of uncertainty remains, and it is currently proving difficult to produce robust forecasts. Commercial fish stocks are generally managed on a stock-by-stock basis through the yearly assessment of their exploitation and ecological status compared to reference points, such as the level of fishing pressure that corresponds to MSY. However, MSY and its associated fishing mortality rate FMSY are sensitive to both stock characteristics and climatic conditions.^[21] ICES makes the assumption that climate change is implicitly incorporated into the catch advice as the stock assessments and short-term forecasts are done using the most up-to-date data in order to estimate sustainable catch levels. Therefore, the data used encompasses changes in stock abundance and/or size at age, whether or not these are climate-driven, and it is assumed that climate change impacts do not need to be explicitly accounted for.

In addition, every five years (or so) ICES provide ecosystem overviews which are aimed at fisheries managers and include a climate change section which summarises the main climate change impacts to consider, although these are currently only at a high level.

The current ICES benchmarking^[22] and catch advice accounts for climate change to a limited degree, however, in the longer term the single-stock advice currently used in mixed fisheries may not be sufficient to enable managers to anticipate and respond to climate change impacts adequately. At ICES level, mixed fisheries scenarios are available, which explore fish stocks interactions and are a first step towards an ecosystem approach to fisheries.

Fisheries policy authorities are keen to understand this further as new information becomes available.

In addition to the impacts of climate change on fisheries, and the need to adapt to these changes, it is also important to consider climate change mitigation (and net zero targets) in relation to fishing. The fishing sector contributes to carbon emissions through vessel emissions and transport of exports. In addition, fishing practices that disturb the seabed (e.g., trawling) may impact on carbon stored in marine habitats (i.e., ‘blue carbon’).

The JFS highlights the need to protect and restore blue carbon habitats to support resilience to climate change. Marine sediments are an important blue carbon store and seabed disturbance could lead to release of carbon dioxide (CO2) back into the atmosphere. Research is currently underway to better understand the fate of carbon disturbed through bottom contact fishing and quantify the scale of any atmospheric emissions. This work is beginning to highlight those areas of the seabed which support the highest densities of organic carbon and where the stores are most vulnerable to remineralisation and losses from disturbance. This evolving evidence could support future consideration of measures to reduce impacts of demersal fishing on blue carbon (e.g. through spatial or technical fisheries management measures).

The total emissions of the UK fishing fleet were estimated as 802 kt CO2e in 2019 which is equivalent to 0.18% of UK total territorial emissions, or 0.66% of UK domestic transport emissions.^[23] The fleet segments with the highest emissions are the Pelagic trawlers over 40m, North Sea Nephrops over 300kW, and within English waters, the South West beamers (over 250 kW). The carbon footprint (kg CO2e / kg fish) is highest in North Sea beam trawls over 300kW, with approximately 15kg CO2e per kg of fish landed.^[24]

Addressing many of these challenges are beyond the scope of this FMP. Under the climate change objective in the 2020 Act and JFS, as well as national strategies such as Scotland’s Fisheries Management Strategy, the fisheries policy authorities will work in partnership with stakeholders to support fisheries in the drive to net zero and consider where and how we need to adapt our approaches to take account of the impacts of climate change.

The delivery of mitigation strategies for climate change is not within scope of this first iteration of this FMP. The FMP does, however, contain an objective to explore options for adapting fishery management to challenges presented by the changing climatic conditions. This FMP will be reviewed and adapted as research into climate change develops and new methods to address challenges from climate change are available.