Strategic Environmental Assessment (SEA) for Pelagic Fisheries Management Plans

7. Reasonable Alternatives

Regulation 12(2)(b) of the SEA Regulations 2004 requires the fisheries policy authorities to consider reasonable alternatives to the draft Pelagic FMPs. A reasonable alternative has been defined as ‘an activity that could feasibly attain or approximate the FMP’s actions 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. Annex A of the JFS lists the planned FMPs, including the draft Pelagic FMPs. Section 6 of the Fisheries Act 2020 requires the fisheries policy authorities to prepare and publish listed FMPs, including the eight specified Pelagic FMPs.

The draft Pelagic FMPs, alongside the other 35 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 draft Pelagic FMPs, was part of the public consultation on the draft Joint Fisheries Statement in early 2022.

Fishing for mackerel, herring and blue whiting is an ongoing activity and management already exists which is considered broadly appropriate. The draft Pelagic FMPs cover Pelagic 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 MSY assessments for most pelagic stocks covered by these FMPs in UK waters. The relevant fisheries policy authorities do not have sufficient evidence to estimate MSY reference points for the West Coast of Scotland and Clyde herring fisheries covered by the West Coast of Scotland and Clyde Herring FMP, but advice and management follows the ICES MSY approach under their framework for Category 3 stocks.

The Fisheries Policy Authorities manage these Pelagic fisheries on an overarching basis, and actions to ensure overall sustainable management across the FMP regions are in place. This is generally achieved through the setting of a TAC alongside appropriate technical management measures. These FMPs therefore describe a vision with policies and actions which set out how management can continue to support an MSY approach^[25] for the mackerel, herring and blue fisheries, and highlights areas that could lead to refinements to management approaches in the future. Areas for action include those which support the wider delivery of policies within the JFS, and which contribute to the delivery of the fisheries objectives in the 2020 Act.

A range of environmental issues (e.g., through SNCB advice, evidence relating to climate change impacts, etc.) 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 5 (Annex 1).

On this 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 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 Pelagic FMPs will develop through future iterations as the evidence base improves. Policies and actions will be adapted to ensure the most appropriate and effective management interventions are used to address contemporary issues. Where appropriate, additional actions will be developed as options for more targeted management become available to tackle a wider range of fisheries management issues over the longer-term.

The public will be consulted on the draft Pelagic 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.