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

7. Reasonable Alternatives

Regulation 12(2)(b) of the SEA Regulations 2004 requires the fisheries policy authorities to consider reasonable alternatives to the draft Whitefish/Demersal FMPs. A reasonable alternative has been defined as ‘an activity that could feasibly attain or approximate the FMP’s policies at a lower environmental cost or decreased level of environmental degradation’^[24].

Section 2 of the Fisheries Act 2020 requires the fisheries policy authorities to publish a JFS setting out how they will use FMPs to achieve, or contribute to achieving, the fisheries objectives. The JFS lists the planned FMPs, including the draft Whitefish/Demersal FMPs. This listing creates a legal requirement to prepare and publish the draft Whitefish/Demersal FMPs.

The draft Whitefish/Demersal FMPs, alongside the other 32 FMPs, were agreed by the fisheries policy authorities through the JFS publication. Engagement across administrations took place via the processes outlined in the Fisheries Framework. Regular scrutiny of the emerging list of FMPs was built into every step of the JFS policy formation, and through this process credible alternatives to managing stocks without an FMP were considered. The draft list of proposed FMPs, that included the Whitefish/Demersal FMPs, was part of the public consultation on the draft Joint Fisheries Statement in early 2022. Following consultation, an updated version of Annex A of the JFS was published in December 2024, introducing changes to the publication dates and technical details of several FMPs.

The fisheries covered under the Demersal FMPs are an ongoing activity and management already exists which is considered broadly appropriate. The Whitefish/Demersal FMPs cover the cod, whiting, haddock, saithe, hake, monk, megrim and ling stocks which 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 the cod, whiting, haddock, saithe, hake, monk and megrim stocks covered by these FMP in UK waters. The cod, whiting, haddock, saithe, hake, monk and megrim stocks relevant to these FMPs are currently being fished within an MSY approach. Therefore, these FMPs describe a vision with policies and proposed actions which set out how management can continue to maintain an MSY approach for the fisheries, and highlight research areas that could lead to refinements to management approaches in the future.

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 sets 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 draft Whitefish/Demersal FMPs’ aim is that fisheries covered in the FMPs in UK waters will continue to be managed sustainably, or in the case of Northern Shelf Ling and Atlantic (Rockall) cod, that they have sufficient evidence in place to help ensure that stocks are maintained above levels capable of producing Maximum Sustainable Yield (MSY). Additionally, the FMPs aim to further develop fisheries management in a more coherent and coordinated way, taking into account broader environmental issues. On that basis, the FMPs will likely deliver greater environmental gain and will have a more significant positive impact on improving the current environmental baseline, compared to a ‘business as usual’ approach that only continues with existing fisheries management.

The policies and actions set out in the FMPs suggest how this could be achieved in a way that is consistent with, and supportive of, the wider achievement of the fisheries objectives set out in the 2020 Act and the policies contained within the JFS.

A range of environmental issues (e.g., through SNCB advice, evidence relating to climatic change impacts) have been considered during the development of the current proposed policies and actions to ensure they have minimal negative environmental effects and where applicable maximum positive environmental gain. Stakeholder input, including that from the environmental sector has been considered during the development of policies and actions. These processes have been employed to ensure the most appropriate actions have been proposed for this stage in the life cycle of the FMPs. An assessment of the potential alternatives is provided in Table 6 (Annex 1).

The proposed policies and actions set out in the FMPs are therefore considered to be the most appropriate for this stage in the FMPs’ development.

The draft Whitefish/Demersal FMPs will develop through future iterations as the evidence base improves. The policies and actions will be adapted to ensure the most appropriate and effective management interventions are used to address contemporary issues. Where appropriate, additional measures will be developed as more targeted management options become available, addressing a broader range of fisheries management issues in the long term.

The public will be consulted on the draft Whitefish/Demersal FMPs, alongside the consultation of this ER. These consultations will provide stakeholders with the opportunity to review proposed policies and actions and present alternatives if available.