Demersal Fisheries Management Plans proposals: strategic environmental assessment - environmental report

6. Proposed Measures to Reduce Significant Negative Effects

Existing Negative Effects Whitefish/Demersal Fishing

This ER has acknowledged the existing negative environmental effects associated with the fishing activity which will be managed through the FMPs. The actions proposed by the FMPs to reduce negative effects are set out below.

Biodiversity, Flora, Fauna, Geology and Sediments (soil), Water quality

The stocks covered by the Whitefish/Demersal FMPs are shared with Coastal State partners. Fishing opportunities are managed by total allowable catches (TACs). These, and other joint management measures, are set through international negotiations guided by the best available scientific advice, balancing environmental, social, and economic factors. There is sufficient available scientific evidence for the relevant fisheries policy authorities to make annual maximum sustainable yield (MSY) assessments for cod, whiting, haddock, saithe, hake, monk, and megrim in UK waters. The relevant fisheries policy authorities do not have sufficient evidence to estimate MSY reference points for the Northern Shelf ling or Atlantic (Rockall) cod covered by their respective FMPs, although the advice and management approach follows the ICES MSY approach under their framework for Category 3 stocks.

Therefore, these FMPs set out a path to improve the overall management approach by considering how the evidence base can be strengthened, with any subsequent action focussed on restoring (if required) and then maintaining the stock at sustainable levels. The policies and actions listed in the Whitefish/Demersal FMPs will be part of the overall stock management strategy and are expected to contribute to the conservation of stocks and the wider environment.

The draft Whitefish/Demersal FMPs have considered advice from Statutory Nature Conservation Bodies (SNCBs) with respect to the impacts from whitefish/demersal species fishing activity on MPA features, the wider marine environment in relation to UK MS descriptors, as well as PMFs (Scottish waters).

There was no formal conservation advice specifically for Welsh waters at the point of developing this SEA, however the understanding is that, the ER was developed following Natural Resources Wales (NRW) engagement in the scoping exercise and their advice was considered and reflected in this report. NRW were asked by Welsh Government to produce high-level risk based advice on the impacts of fishing activities to support the development of other relevant mixed demersal fisheries FMPs. Welsh Government are satisfied that the advice provided in that assessment has parallels to the 11 UK Whitefish/Demersal FMPs.

The draft Whitefish/Demersal FMPs have set out the following proposed measures to reduce those known negative effects as follows:

Impacts within MPAs

The MPA network (Appendix C) is protected through the existing MPA management process and HRA assessments by managing human activities such as fishing, to avoid likely significant effects on the environment. These activities are mainly controlled through the powers vested in the Marine Directorate, IFCAs, the MMO, the Welsh Government and DAERA.

The Scottish Government, Defra, the MMO, DAERA, and the Welsh Government were involved in the development of the FMPs to ensure measures proposed through the FMPs are compatible with existing MPA management.

Before the Marine Directorate, Defra, DAERA and Welsh Government implement any new management interventions proposed in the draft Whitefish/Demersal FMPs, those interventions will be screened for likely significant effects on any European sites or European offshore marine sites that overlap with the geographical scope of the measure and, where necessary, an appropriate assessment will be completed in accordance with the Conservation (Natural Habitats, &c.) Regulations 1994, the Conservation of Habitats and Species Regulations 2017 or the Conservation of Offshore Habitats and Species Regulations 2017. In accordance with the Marine and Coastal Access Act 2009 (MaCAA), a Marine Conservation Zone Assessment will also be completed before any new management measure is implemented that may significantly hinder the conservation objectives of an MCZ

Additionally, Nature Conservation Marine Protected Areas (NCMPAs) are designated and protected by the Marine (Scotland) Act 2010 and Marine and Coastal Access Act 2009. An MPA assessment will be completed as required, to ensure any actions or measures before being implemented.

The points above will make sure the impacts of whitefish/demersal fishing activity, and the FMPs’ policies and actions, do not prevent our ability to meet the conservation objectives for MPA features. Thereby enabling us to achieve the legally binding target for MPA condition set out in the Environmental Targets (Marine Protected Areas) Regulations 2022.

Environmental effects associated with designated features of MPAs

The marine environment outside of MPAs but within the spatial boundaries of the FMPs may potentially be negatively impacted by fishing activities. SNCB advice commissioned by the Scottish Government’s Marine Directorate covering Scottish waters highlighted that while the risk to the conservation status of mobile species that are designated features of MPAs (e.g. birds and mammals) through bycatch from mobile demersal gear is generally considered low, given the scale of these fisheries and significant gaps in the available evidence, the risk rating for bycatch in mobile demersal gears is considered moderate. In addition, the risk rating for bycatch in static nets and longlines is considered high, with more data collection required to understand the scale of the problem and improve the ability to assess risk. Recognising a potential impact pathway but lacking sufficient evidence to provide a confident conclusion, the risk of prey depletion to designated features of MPAs from demersal fisheries is considered moderate. Static nets are used in the hake and monk/angler fisheries, with hake fishing also utilising longlines, thereby these aspects of bycatch only cover certain features of demersal fishing. There is insufficient evidence for some fisheries regarding the extent of bycatch, highlighting the need to both enhance our understanding and take appropriate action.

SNCB advice covering English waters also identified moderate risk to the conservation status of designated mobile species from demersal trawls owing to significant evidence gaps. In addition. a high risk to conservation status of designated mobile species (birds and mammals) from static nets and a high risk to the conservation status of seabirds from longlines was identified. These risks arising from static nets and longlines are specific to the monk/angler (static nets) and hake (static nets and longlines) fisheries. A moderate risk to designated mobile species (harbour porpoise) from reductions in the availability of juvenile cod and whiting as prey was identified.

The advice acknowledged the lack of high-quality bycatch data. This severely restricts both the ability to draw firm conclusions on mobile bycatch risks on MPA features beyond site boundaries, and the ability to identify specific mitigation. Policy 3 of the draft Whitefish/Demersal FMPs addresses the risk of bycatch by minimising the impact of the fisheries “on the marine ecosystem by taking appropriate measures to: 1) reduce benthic impact and 2) reduce incidents of bycatch of sensitive marine species.” The actions set out as part of this policy aim to build our understanding whilst also taking appropriate action. Short-term actions focus on improving fisheries data accuracy, incentivising low-impact fishing, and supporting management measures for Marine Protected Areas and Priority Marine Features (Scottish waters). Long-term actions involve evaluating the effectiveness of these measures, exploring alternative fishing gear to reduce benthic impacts, and supporting ongoing research and innovation to minimise environmental impact and bycatch of sensitive species. The FMPs link specific data collection initiatives to wider bycatch monitoring and mitigation programmes such as the UK Bycatch Mitigation Initiative and the creation of a cross-UK benthic impacts working group.

UK MS descriptor impacts

The draft Whitefish/Demersal FMPs focus on sustainable harvesting of a number of stocks. This will support the achievement of GES for UK MS Descriptor 3 – Commercial fish and shellfish stocks. This will also benefit the wider marine environment and support improvements in the status of fish biodiversity (Descriptor 1) and marine food webs (Descriptor 4).

The risks identified in the SNCB advice largely mirror the risks associated with designated features of MPAs. For Scottish waters, this includes a moderate risk to achieving GES for the biological biodiversity of seals, due to impacts from demersal fishing activities (specifically static nets). Although bycatch in static nets is a significant source of mortality for seals, and demersal fisheries may reduce the availability of prey, at their current scales these pressures are not thought to be among the primary drivers for change with respect to achieving GES for seals. A high risk to achieving GES for the biological biodiversity of cetaceans and birds, due to impacts from demersal fishing activities, is identified. This rating is primarily driven by risk of bycatch in static net and longline fisheries for cetaceans and birds, respectively.

For English waters, a high risk to achieving GES for cetaceans and seabirds (D1 & D4) due to bycatch in static nets and longlines respectively is identified. A moderate risk to achieving GES for seals and seabirds (D1 & D4) due to bycatch in static nets is identified. While the risk from demersal trawls and seines to achieving GES for marine mammals and seabirds (D1 & D4) is generally considered low, there are still significant gaps in the available evidence. As a result, the FMP risk rating has been upgraded to moderate, taking a precautionary approach into account. Furthermore, there is a moderate risk to cetaceans (harbour porpoise, D1 & D4) through reduction in the availability of juvenile cod and whiting as prey.

Both the advice covering Scottish waters and English waters identify a high risk to seafloor integrity (D1 & D6) due to benthic disturbance caused by mobile demersal fishing activities and a moderate risk of impacts from marine litter (D10). There was no formal conservation advice specifically for Welsh waters at the point of developing this SEA, however the understanding is that, the ER was developed following Natural Resources Wales (NRW) engagement in the scoping exercise and their advice was considered and reflected in this report. NRW were asked by Welsh Government to produce high-level risk based advice on the impacts of fishing activities to support the development of other relevant mixed demersal fisheries FMPs. Welsh Government are satisfied that the advice provided in that assessment has parallels to the 11 UK Whitefish/Demersal FMPs.

The Whitefish/Demersal FMPs includes an action to support the creation of a “cross-UK benthic impacts working group”. In the update to UK Marine Strategy Part 1 (2019) Defra made a commitment to assess the feasibility of setting up a partnership working group, referred to here as the Benthic Impact Working Group. The UK Administrations and Government agencies are in the process of developing this Group which will be tasked with providing evidence-based advice to reduce the impacts of fishing activity on benthic habitats to achieve Good Environmental Status. Once convened, this group should provide strategic oversight and direction for delivering future advice. This includes identifying, developing, and trialling possible mitigation or management options, in partnership.

As detailed under "Environmental Effects Associated with Designated Features of MPAs," policy 4 of the draft Whitefish/Demersal FMPs outlines 11 actions aimed at reducing benthic impact and bycatch of sensitive marine species. These actions are divided into short-term measures, which focus on enhancing data collection, improving our understanding of impacts, supporting fisheries management as part of ongoing programs, and strengthening cross-UK collaboration. The long-term actions prioritise evaluating the effectiveness of existing measures, exploring alternative gear options, and fostering research and innovation.

Priority Marine features (PMFs) impacts (Scottish waters)

The risk rating for PMFs’ bycatch in mobile demersal gears and longlines is considered moderate. The risk rating for bycatch of PMFs in static nets is considered high. Owing to a potential impact pathway but lacking sufficient evidence to provide a confident conclusion, the risk of prey depletion to PMFs from demersal fisheries is considered moderate. As the benthic species and habitat PMFs are also represented across the Scottish MPA network, it is assumed that these features will be offered some protection through the MPA management process. Therefore, some of these impacts on national status of PMFs will be mitigated, and the risk rating for physical impacts to benthic and habitat PMFs from mobile demersal gears is considered moderate.

The draft Whitefish/Demersal FMPs as part of goal 3 for minimising impact of the fisheries on the marine ecosystem, proposes actions in support of introducing fisheries management measures to existing Marine Protected Areas (MPAs), where these are not already in place, as well as the most vulnerable Priority Marine Features (PMFs) in Scottish inshore waters (0-12 nautical miles). As mentioned in the SNCB advice, benthic species and habitat PMFs are also represented across the Scottish MPA network and will be offered some protection through the MPA management process. The draft Whitefish/Demersal FMPs also contain actions on “site specific fishing restrictions […] to ensure conservation objectives can be achieved”. Birds are not included in the PMF list, therefore the risk from longlines to PMFs was downgraded to moderate. The actions outlined in the draft Whitefish/Demersal FMPs, aimed at improving data collection and understanding of bycatch, are expected to support management measures that will reduce the impact of fisheries on Priority Marine Features (PMFs).

Climate Change

Vessel Emissions

The draft Whitefish/Demersal FMPs acknowledge that more work is needed to fully understand how carbon emissions can be reduced in a sustainable way. The FMPs propose three actions as part of policy 6 aimed at collaboration for reducing environmental impacts of the fisheries (including CO₂ emissions) and improving the evidence base. This will be done by collaborating across Government, with industry and academic organisations to understand the current evidence gaps and latest innovations, to support the development of pathways towards Net Zero for the UK fishing fleet.

Blue Carbon

The draft Whitefish/Demersal FMPs acknowledge that the UK continues to build the evidence base on blue carbon habitats, including marine sediments. 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 Blue Carbon Evidence Partnership is looking to progress the evidence base to address some of the uncertainties in this area.

Climate change impacts on stocks and fisheries

The draft Whitefish/Demersal FMPs acknowledge there are already changes to the distribution and size composition of demersal stocks as a result of climate change, but the overall impacts are not yet fully understood. Policy 6 specifically looks at how the fishing industry can be supported to adapt to the impact of climate change. This includes actions on wider research to identify impacts of climate change on fisheries, including their links within the wider ecosystem, as well as identifying the impacts of the fisheries on the marine environment. Further research will be required to predict the scale of impacts on the environment and over what timeframe this will be applicable to the Whitefish/Demersal FMPs. Climate mitigation and adaptation measures can then be proposed and developed. Direction on climate research and adaptation may be set at a national level, should this occur, the relevant chapter in the FMPs will be reviewed and amended.

Cultural Heritage

The draft Whitefish/Pelagic FMPs do not explicitly consider the potential impacts of fishing activity on marine cultural heritage.

Historic England have developed a range of options designed to manage negative interactions between commercial fishing and the historic marine environment. Marine Directorate, Defra, DAERA and Welsh Government should work with agencies such as Historic Environment Scotland, Historic England, DfC Historic Environment Division and Cadw to consider how measures that could protect the marine historic environment could be incorporated into fisheries management for future iterations. Considering appropriate measures to reduce negative interactions with marine heritage assets could strengthen the positive interactions between FMPs and cultural heritage and has the potential for the FMPs to contribute to having a positive effect on the current baseline. In addition, by working with Historic Environment Scotland, Historic England, DfC Historic Environment Division and Cadw to better understand the extent of prehistoric deposits like moorlog and how they are changing, efforts to conserve them from the impacts of fishing them might contribute to climate change mitigation and adaptation.

Landscapes and Seascapes

The draft Whitefish/Demersal FMPs do not explicitly consider the potential impacts of fishing activity on submerged prehistoric landscapes or seascapes.

The FMPs will investigate the impact of fishing activity has on the wider environment. Any future management intervention could indirectly help to conserve submerged prehistoric landscapes or seascapes.

Marine Directorate, Defra, DAERA and Welsh Government should work with agencies such as Historic Environment Scotland, Historic England, DfC Historic Environment Division, Cadw, JNCC, NatureScot and DAERA to consider how measures that could protect the marine historic environment could be incorporated into fisheries management for future iterations. Considering appropriate measures to reduce negative interactions with submerged prehistoric landscapes or seascapes could strengthen the positive interactions between the FMP and the wider marine environment that fishing for demersal species operates in. This has the potential for the FMPs to contribute to having a positive effect on the current baseline.

Effects identified by this assessment

The assessment of the likely negative effects of the individual policies and actions in section 5 identified a low risk of significant adverse effects on the environment from implementing individual policies and actions. Therefore, no changes to the proposed policies and actions are needed ahead of publishing the FMPs. Where appropriate, the policies and actions will be developed and implemented to mitigate any potential negative effects identified by the current assessment.

The likely negative effects will also be considered when developing monitoring activities as part of the implementation process (see section 8), to ensure that any negative effects of the FMPs’ policies and actions individually or combined can be further reduced. Given the uncertainty as to the negative effects of implementing the individual policies and actions, monitoring changes to fishing activity resulting from the implementation of the FMPs will help identify any unintended consequences on the environment that could lead to significant negative environmental effects. Where likely unintended environmental consequences are identified, appropriate changes to management or mitigation can be implemented to reduce to any negative environmental effects developing.

General

The UK is committed to using marine resources sustainably and reducing the impacts of fishing on the marine environment to comply with its international and domestic obligations. The draft Whitefish/Demersal FMPs seek to support these commitments by providing the tools (FMP policies and actions) to deliver the sustainable harvesting of stocks.

The range of environmental issues identified through this assessment have been considered by the draft Whitefish/Demersal FMPs. The FMPs acknowledge that the evidence base is not sufficiently comprehensive at present to fully address all of the issues and therefore propose a two-pronged approach for reporting on the effectiveness of the FMPs, set out by the policies and actions aimed at delivering long-term sustainability and improving the evidence base. The FMPs should remain flexible to adapt their policies as new evidence on potential impacts of whitefish/demersal fishing emerges, particular in relation to climate change.

This ER considers that the Whitefish/Demersal FMPs have proposed all possible actions to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plans. The ER considers that the FMPs have appropriately considered how they will address potential issues arising from the implementation of the FMPs’ policies and actions. This ER has therefore not proposed any mitigations in addition to those already set out in the FMPs