West Coast of Scotland and Clyde Herring Fisheries Management Plan

FMP policies

In developing the policies and actions for this FMP, the fisheries policy authorities have considered the current policy landscape including applicable international agreements and declarations, conservation advice and wider policy development already underway, in addition to considering what additional evidence, measures or policies may be needed to support both the vision of this FMP and delivery of the fisheries objectives. In most cases, individual actions within this FMP will directly link to one or more of the fisheries objectives and these links are made below. FMPs are one of the tools that support the achievement of the fisheries objectives, although they are not the only policy vehicle available to do this. The fisheries policy authorities have also considered the conservation advice received from the SNCBs and included the outputs from that work in considering where policy action may be needed.

Effective management of the overall marine space is critical to sustainable development of existing and emerging sectors, and the protection of the marine environment. Whilst not a specific topic that is covered in detail within the FMPs, the fisheries policy authorities are working on a range of policies to help manage the increased demand for marine space, reduce the conflict arising from competition for marine space, and ensure that the right protections are in place to manage broader impacts from wider use. This FMP has been developed within the wider context of the Marine Plans in place in England, Scotland, and Northern Ireland. Consideration will also be given to the objectives and principles outlined in the EU-UK Trade and Cooperation Agreement when considering measures.

In Scotland, these policies will help achieve the outcomes set out in the Good Food Nation Plan^[39], and its vision of Scotland becoming ‘a Good Food Nation, where people from every walk of life take pride and pleasure in, and benefit from, the food they produce, buy, cook, serve, and eat each day’.

In most cases further policy development work will be needed for any new actions, which could include further evidence gathering or public consultation, along with the completion of appropriate impact assessments. It should also be noted that WoS herring is a jointly managed stock, and therefore overall fishing opportunities are determined through international negotiation. The stock is also subject to different management measures in different areas of the sea by individual Coastal States.

The policies and actions within this FMP reflect the fact that the evidence base underpinning both the WoS and Clyde herring stocks is poor, however, they also reflect that there are no immediate plans to improve the evidence base given the prioritisation of other stocks of greater commercial importance. This is consistent with section 6(3)(b)(ii) and (iii) of the 2020 Act, which specifies that Fisheries Policy Authorities must specify steps to improve the scientific evidence base where this is needed, or provide reasons why no steps are proposed if this is in the case (see policy 2). In the absence of a more robust evidence base, the actions also reflect the current management action that is in place to continue to manage both herring stocks in such a way as to maintain stock levels (policy 1) – this also addresses the requirement under section 6(3)(b)(i) of the 2020 Act.

The first two policies set out below largely relate to stock management, and the remaining policies set out actions in relation to wider sustainable management.

Policy 1: Continue to manage the WoS and Clyde herring stocks using existing tools to maintain stock levels

Rationale

Given the data poor evidence base for WoS and Clyde herring this FMP falls under section 6(3)(b) of the 2020 Act. That section of the Act requires the Fisheries Policy Authorities to specify policies for maintaining or increasing levels of the currently assessed stocks, and to specify steps to improve the scientific evidence (or provide reasons why no steps are proposed).

Prior to an improved evidence base being established, the Fisheries Policy Authorities will continue to take steps to manage the WoS and Clyde herring stocks, and to maintain the levels of the stocks. As already set out within this FMP, fisheries authorities will continue to take a precautionary approach to TAC setting.

Actions

Ongoing actions

• Continue to take a precautionary approach to TAC setting, following the principles set out in the JFS until sufficient evidence is in place to make a robust assessment.
• For WoS herring, continue to work with the EU with the aim of maintaining the sustainable harvesting of the stock through international negotiations.

Relevant Fisheries Act objectives

The relevant Fisheries Act objectives are the:

• sustainability objective
• precautionary objective
• scientific evidence objective
• ecosystem objective
• national benefit objective

Policy 2: Improve the evidence base underpinning the stock, in order to support sustainable harvesting of the WoS and Clyde herring stocks, with biomass maintained above the level capable of producing MSY

Rationale

The primary aim of FMPs, where there is not sufficient evidence to enable an assessment of MSY is to specify the steps (if any) that the relevant authority or authorities propose to take to obtain the scientific evidence necessary to enable an assessment of the stocks MSY to be made or, if not doing so, state reasons. This is in line with section 6(3)(b) of the 2020 Act. As part of this, the role of fisheries managers is to help ensure stocks are harvested sustainably, in order to protect the long term viability of the stocks and the fisheries that prosecute them.

The use of TACs is a fundamental part of sustainable management and the negotiation principles and management approach followed by the UK helps to ensure that the fishing pressure in the harvesting of WoS and Clyde herring stocks is kept within sustainable levels, whilst also taking account of relevant socio-economic factors. This is consistent with the sustainability objective of the 2020 Act. The current data poor evidence base for WoS and Clyde herring means that a precautionary approach to TAC setting is generally followed.

The health of fish stocks can change over time and is also affected by a range of different factors not only fishing activity. At the time this FMP was produced the relevant fisheries policy authorities did not have sufficient evidence to estimate MSY reference points for the WoS and Clyde herring fisheries covered by this FMP, although for WoS herring advice followed the ICES MSY approach under their framework for Category 3 stocks. The FMP sets out a longer term path to improve the overall management approach by considering how the evidence base can be strengthened. As stated throughout this FMP, this is likely to take some time to deliver given the precedence given to other fish stocks.

The actions also reflect that the WoS herring stock is managed internationally, therefore maintaining the stocks above the levels capable of producing MSY is a result of the joint management of the stock.

Actions

Ongoing actions

• Continue to undertake scientific surveys and participate in ICES working groups to support ongoing data collection and maintenance of the international scientific evidence base which supports the setting of fishing opportunities at sustainable levels.
• Continue to participate in international stock assessments and contribute to the international advice process.
• Continue to use the best available data to underpin management decisions and refine the management approach as additional information becomes available.
• Continue to participate in international stock assessments for WoS herring and contribute to the international advice process.
• Continue to seek relevant additional evidence and data from academics, researchers and the fishing industry as part of the review of the Clyde herring stock and take relevant information into account when setting the TAC.

Medium to long term actions (three to five years)

• Utilise additional and new data streams, including the use of biological data from the self-sampling scheme of the SPISDCP, and scientific data derived from new technology such as REM
• Consider options to improve data gaps in assessments.

Relevant Fisheries Act objectives

The relevant Fisheries Act objectives are the:

• sustainability objective;
• precautionary objective;
• scientific evidence objective; and
• ecosystem objective.

Policy 3: Monitor catches of WoS and Clyde herring and ensure that where possible all catches are counted against quotas

Rationale

This policy is in accordance with section 4.2.8 (‘Reducing Bycatch and Minimising Catches of Sensitive Species’) of the JFS.

Pelagic fisheries are, in the main, classed as a relatively ‘clean’ fishery, meaning that issues with discarding and bycatch are deemed to be minimal. Given the capability of pelagic trawl vessels to take large tonnage hauls, the impact of any discarding/slipping, should it take place, would be considered high.

There is a legislative requirement under the landing obligation to land all species of fish and for fishers to ensure that all catches are counted and recorded. From 7 March 2026, all pelagic fishing vessels fishing in Scottish waters and all Scottish pelagic vessels wherever they fish, must have REM on board. Similar measures are being developed for English waters. REM is an effective way of ensuring that fishing vessels comply with relevant fisheries legislation.

REM will also support fisheries managers to understand levels of fish bycatch within pelagic fisheries and take appropriate action if needed. This is consistent with the action suggested within the pelagic conservation advice.

Actions

Ongoing actions

• Continue to monitor pelagic fishing activity using REM (where available) and other tools and take appropriate action to tackle non-compliance as needed.
• Continue to monitor levels of fish bycatch within pelagic fisheries and take appropriate management action if needed.

Relevant Fisheries Act objectives

The relevant Fisheries Act objectives are the:

• bycatch objective
• scientific evidence objective
• sustainability objective

Policy 4: Identify and support implementation of ecosystem-based fisheries management approaches appropriate for the WoS and Clyde herring fisheries

Rationale

This policy is in accordance with section 4 (‘Delivering Sustainable Management of Fisheries’) of the JFS.

A thriving fishing industry is underpinned by healthy and productive seas. As set out in the JFS and the Act, the UK and Scottish Governments are committed to an ecosystem-based approach to fisheries management that will account for, and seek to minimise, impacts on non-commercial species and the marine environment. This also links to existing initiatives such as the Bycatch Mitigation Initiative and Clean Catch UK.

Understanding and minimising these impacts is an important part of delivering an ecosystem-based approach. The fishing industry has taken a number of steps over previous years to try and mitigate against this, for example by using more selective fishing gears, or trialling new tools to reduce bycatch of mammals and seabirds. The conservation advice that supports this FMP has identified some impacts and evidence gaps that need to be addressed in order to ensure that the risk posed by pelagic fishing to the wider marine ecosystem is minimised.

In particular, conservation advice has flagged the need for an improved evidence base around bycatch levels and a recognition of the need for greater understanding and identification of potential actions in relation to predator/prey interactions, given the importance of pelagic species in the marine food chain. In addition, wider environmental impacts of other marine activities are also important to consider.

Gravel substratum is an essential habitat for herring spawning Activities that have a negative impact on spawning should not occur unless the effects of these activities have been assessed and shown not to be detrimental to the productivity of the stock. Activities such as the dumping of dredge spoil, the extraction of marine aggregates (e.g. gravel and sand; de Groot, 1979, 1996), and the placement of structures such as wind turbines in the vicinity of spawning grounds are known to have a negative impact on herring spawning success and are causes for concern.

Actions

Ongoing actions

• Continue to monitor levels of bycatch in pelagic trawl fisheries through REM, to improve understanding of risk and to support appropriate management if required.
• Continue to promote existing good practice within the fishing industry in relation to handling of sensitive marine species and returning them to the sea unharmed, where practical to do so.

Short-term actions (one to two years)

• Work with UK experts to consider the ecological role of pelagic species in the North Sea and West of Scotland, and how an ecosystem-based approach could be integrated into fisheries management especially in relation to our goals for commercially important fish species which interact with West of Scotland herring.

Medium to long term actions (three to five years)

• Work with ICES to consider further developing ecosystem-informed assessments and ecosystem modelling approaches in the future.
• Explore avenues to protect and enable recovery of habitats that have been identified as important for herring from the pressures that pose risks to them.

Relevant Fisheries Act objectives

The relevant Fisheries Act objectives are the:

• sustainability objective
• ecosystem objective
• bycatch objective

Policy 5: Support fishing businesses to deliver socio-economic and cultural benefits for communities

Rationale

The UK Government holds an ambition to enable fisheries to continue to deliver social and economic benefit to coastal communities to benefit present and future generations. As already set out in this FMP, herring is an important component part of UK pelagic fisheries, and is a significant part of the business model for fishing businesses. In turn, these businesses collectively support jobs and underpin local communities, providing a source of economic input and output and underpinning the rich cultural heritage of the UK at both a local and national level. Fish is also a rich source of protein and forms an important component of food production within the UK.

There is an ongoing role for Governments to help create the right conditions for businesses to operate sustainably and with certainty about the future.

Actions

Ongoing actions

• Continue to take account of socio-economic considerations as part of international negotiations and as part of the process to determine fair fishing opportunities across the UK.
• Continue to gather and use evidence on economic aspects of the fishery to ensure management decisions are informed by the best available evidence.

Relevant Fisheries Act objectives

The relevant Fisheries Act objectives are the:

• equal access objective
• national benefit objective
• sustainability objective

Policy 6: Reduce the impact of fishing on climate change and support the fishing industry to adapt to the impacts of climate change

Rationale

This policy is in accordance with section 4.1 (‘Delivering Sustainable Management of Fisheries - Our approach to Fisheries Management’) of the JFS.

The evidence base underpinning climate change and fisheries is developing, and more work is needed to fully understand a) how carbon emissions can be reduced in a sustainable way, and b) the likely impacts of climate change on fish stocks and fishing communities and the scale / nature of change required to adapt.

We know that there will be changes to the distribution and size composition of the herring stock as a result of climate change, but the overall impacts are not yet fully understood. The actions below consider how we can build and use an improved evidence base in order to make informed decisions on management action for the future.

In comparison to other forms of food production, pelagic fishing provides a high-protein and low carbon method of production and offers opportunities to provide food security particularly as we move towards net zero. However, we also know that fishing vessels need to reduce fuel emissions in the future although there are no ready solutions in place for fishing vessels to currently utilise.

The actions set out below will also apply to other stocks in the fishery. However, as our evidence base grows, we will understand better the specific impacts of climate change on herring, and the scale of change required to support vessels fishing for herring to reduce their emissions and also adapt to changes in the herring stocks and general fishing conditions. These actions are likely to adjust over time and will become more refined.

Possible measures which could support this are already in development and / or being delivered. The FMP will support these measures, although it is not directly introducing or delivering them.

Actions

Medium to long term actions (three to five years)

• Collaborate with partners across government, industry, and academic sectors on initiatives to reduce environmental impacts of the herring fishery (including CO2 emissions).
• Collaborate across the UK and internationally on further evidence and analysis to understand the impact of climate change on herring and develop options for how the herring fishery may adapt to climate change impacts in the future.
• As additional information becomes available in relation to climate change, explore the implications for this.

Relevant Fisheries Act objectives

The relevant Fisheries Act objectives are the:

• sustainability objective
• climate change objective
• Ecosystem objective