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This document summarises the responses received to the public consultationÌýonÌýtheÌýSouthern North SeaÌýdemersalÌýnon-quotaÌýspecies (NQS)Ìýfisheries managementÌýplanÌý(FMP)ÌýandÌýtheÌýassociated environmental report. It alsoÌýsets out the government’s response.

Consultations took place at the same timeÌýonÌý4Ìýother FMPs.ÌýA number ofÌýbroad, cross-cutting themes from the consultation responses, which are relevant to all FMPs, are also addressed in this document.Ìý

This document hasÌý3Ìýmain parts:Ìý

• introduction – context and a high-level overview of the consultationÌý

• summary of responses – summaries of themes and comments received as part of the consultationÌý

• government response – sets out theÌýgovernment’s response and intentionsÌý

FMPs are a requirement of the Fisheries Act 2020 (‘the Act’). TheÌýEnvironmental Improvement Plan (EIP) for England 2025,Ìýalso sets out theÌýimportant roleÌýof FMPsÌýin the sustainable management of our fish and shellfish stocks.

FMPs assess the status of stocks and set out policies and actions to restore stocksÌýto,ÌýorÌýmaintainÌýthem at,Ìýsustainable levels. As set out in theÌýJoint Fisheries StatementÌý(JFS), whereÌýappropriate, these plans will contribute towards widerÌýobjectivesÌýunder the Act.

BackgroundÌýto the consultationÌý

The consultation on theÌýSouthern North SeaÌýdemersal NQSÌýFMPÌýwas heldÌýbetween 10ÌýOctober 2024ÌýuntilÌý19 JanuaryÌý2025.Ìý

The consultation was conducted:Ìý

• using Citizen Space (an online consultation tool)Ìý

• by emailÌý

• through a series of online and in-person engagement events

The analysis given in this summary is based on the responses to the consultation provided through all channels.

Overview of responsesÌý

InÌýtotal,Ìýwe receivedÌý26ÌýdirectÌýresponses to the consultation:Ìý

• 22ÌýwereÌýsubmittedÌýusingÌýthe Citizen Space online surveyÌý

• 4ÌýbyÌýemail

TheÌýbreakdown of responses consisted of:Ìý

• 7Ìýfrom theÌýcatching sectorÌý

• 3ÌýproducerÌýorganisationsÌý

• 3ÌýfromÌýlocal government

• 3ÌýfromÌýrecreationalÌýseaÌýfishing sectorÌý

• 5Ìýfrom environmentalÌýorganisationsÌý

• 2ÌýfromÌýtheÌýEU and other coastal statesÌý

• 3ÌýothersÌý(groups or individuals not already covered)

All responses wereÌýsubmittedÌýon behalf of organisations with no responses received from individuals.ÌýA list of organisationsÌýthatÌýresponded to the consultation is set out in Annex 1.Ìý

WeÌýheldÌýtwoÌýmeetingsÌý(online and in-person)Ìýwhere stakeholders were given the opportunity to discuss theÌýdraftÌýFMP.

Online meetings were also used to gather views from a wide range of sectors and stakeholders including:Ìý

• the catching sectorÌý

• the wider supply chainÌý

• EnvironmentalÌýNon-GovernmentalÌýOrganisations (eNGOs)Ìý

• scientistsÌý

• academiaÌý

• the EU Commission andÌýEU attachés to the UKÌý

• others interested in fisheries managementÌý

These engagement events were usedÌýas anÌýadditionalÌýmethodÌýtoÌýseekÌýand recordÌýviews on the FMP.ÌýViews and comments from these meetings were treated as part of the consultation and are summarisedÌýbelow.

MethodologyÌý

Due to the broad scope of the FMP and the qualitative nature of responses, anÌýanalysisÌýbased on the themes of responsesÌýwas conducted. Using an iterative approach, each response was analysed twice toÌýidentifyÌýtheÌýtopicsÌýraised byÌýstakeholders and policy recommendations put forward. We have summarised each response, which has been used to produce the overall summary of responses outlined below.Ìý

Comments and views were noted at in-person and online meetings. These notes were cross checked and then analysed using the same iterative process. Views from these engagement events have been included in the summary below and have been considered equally alongside the email and online responses.

Headline messagesÌý

We areÌýveryÌýgratefulÌýfor the time that stakeholders have taken to provide constructive input to help us improve and finalise the FMPs.ÌýA wide range of diverse and informative views were presentedÌýfor which we have provided detailed summaries inÌýthe sections below.

Overall, there was broad support for this FMP as an approach to improve the sustainability of demersal NQS stocks in the Southern North Sea.ÌýThere wasÌýsupport for:Ìý

• theÌýgoals,ÌýactionsÌýand management measures

• theÌýcommitment to balancing environmental sustainability with economic viabilityÌý

• recognising the importance of protecting marine ecosystemsÌýalongsideÌýfishermen’ livelihoods

There were calls for:Ìý

• broader stakeholder engagementÌý

• clearer communicationÌý

• greater inclusion ofÌýindustry inÌýthe decision-making processÌý

ÌýThere wasÌýhoweverÌýno firm view on setting upÌýaÌýSouthern North SeaÌýdemersal NQS management group.ÌýStakeholders recognised current limitationsÌýregardingÌýdata andÌýsupportedÌýimprovingÌýstock assessments and fisheries data collection, advocating scientific research and evidence-based decision-making.

Many encouraged the inclusion of species-specific protections, such asÌýminimumÌýconservationÌýreferenceÌýsizesÌý(MCRS), for species likeÌýsmoothhound, red mullet, and gurnards, provided they are based on robust evidence.

There was support for increased researchÌýandÌýforÌýtakingÌýa precautionary approachÌýtoÌýmanagingÌýgrowingÌýcephalopod fisheries. There was also support forÌýsomeÌýprotection,Ìýsuch as codes of conduct,Ìýto helpÌýprovide opportunities for industry diversificationÌýwhile preserving ecological balance.

There wasÌýa mixed response to theÌýproposedÌýflyseiningÌýrestrictions.ÌýSome stakeholdersÌýsoughtÌýimmediate action, including prohibiting theÌýpractice,Ìýto manage effort, while othersÌýfeltÌýmore robust evidenceÌýwas neededÌýbeforeÌýseekingÌýto implement management measures.Ìý

Some stakeholdersÌýcriticised the FMP for lacking meaningful change, favouring commercial fishing interests, and excluding scientific and environmental groups from the early FMP formulation stages.ÌýOthers stressed the importance of integrating animal welfare considerations into fisheries policyÌýalongside support for voluntary measures for recreationalÌýfishermen.

Summary of responsesÌýto FMPÌýquestionsÌý

As part of the consultation,ÌýstakeholdersÌýwere askedÌýsevenÌýquestionsÌýonÌýCitizen Space.ÌýThisÌýallowed them to express their views on the content of theÌýproposed Southern North SeaÌýdemersal NQSÌýFMP. Summaries of the responses to these questions are detailed below. Email responses and views from coastal meetings have also been summarised in this section.

QuestionÌý1: Do you have any comments on the engagement process for developing thisÌýdraftÌýFMP?Ìý

TheÌýmajority ofÌýstakeholders expressed support forÌýdevelopment ofÌýtheÌýFMP.ÌýHowever, several stakeholdersÌýacross sectorsÌýexpressed frustration with the engagement process.ÌýAÌýlack of meaningful change, excessive detailed information,ÌýandÌýperceived bias in favour of commercial fishing interestsÌýbut againstÌýflyseiningÌývesselsÌýwere noted. Some felt there was aÌýlack of collaboration with wider fisheries stakeholder groups, especially scientific,ÌýenvironmentalÌýand academic.ÌýCatchingÌýsector stakeholders amongstÌýothers, stressedÌýthe need for effective strategies to improve participation. This highlightedÌýindustry disenfranchisementÌýevidencedÌýby low attendance at public consultation events. Some catching sector representatives and otherÌýnon-UKÌýgovernment organisations emphasised the importanceÌýofÌýdiscussingÌýmanagementÌýmeasuresÌýlike MCRS and gear specifications.Ìýwithin forums.ÌýTheyÌýhighlighted that discussions should take place in forums,Ìýsuch asÌýthe SpecialisedÌýCommittee onÌýFisheries (SCF),Ìýwhen considering fisheries management in shared areas.Ìý

Some stakeholders supported UK-EUÌýcollaboration under the Trade and Cooperation Agreement (TCA) for managing the 13 FMP speciesÌýandÌýwanted closer,ÌýearlierÌýSCF involvement.Ìý

A minorityÌýin theÌýenvironmentÌýsector feltÌýconsultationsÌýwere focusedÌýon commercial interests rather than theÌýobjectivesÌýof the Fisheries Act. TheyÌýwarnedÌýof potential industry bias andÌýaÌýlack of best available scienceÌýin FMP developmentÌý– citing they wereÌýexcludedÌýfromÌýengagement pre-consultation.ÌýThe catching sectorÌýraised concerns about replicating theÌýChannelÌýdemersal NQS FMP, which placed restrictionsÌýonÌýflyseineÌýinterestsÌýandÌýcame into force in December 2024. Some respondents felt Defra’s application of the precautionary principle toÌýflyseinersÌýin this FMPÌýwas overlyÌýprecautionary.Ìý

SomeÌýgaps were notedÌýonÌýfullyÌýintegrating the recreational seaÌýfishing sectorÌýintoÌýthe development ofÌýfisheries management.ÌýRecommendationsÌýto improveÌýengagementÌýincluded:Ìý

• evening meetingsÌý

• diverse communication channelsÌý(for exampleÌýtackle shops, surveys)Ìý

• inclusive language to engage recreationalÌýfishermenÌý

• ensuring consultation processes are representative and effectiveÌý

OthersÌýnoted theÌýpotentiallyÌýhighÌýeconomicÌývalue ofÌýsmoothhoundÌýas a recreational target species,Ìýand aÌýdeclineÌýinÌýspecies likeÌýsmoothhoundÌýand spotted dogfish. This was attributedÌýtoÌýtheirÌýlow valueÌýuse as pot baitÌýin commercial fisheries.Ìý

While some in theÌýcatching sector supportedÌýthe overall aims of the FMP, theyÌýhighlighted challenges such as stakeholder fatigue, resource constraints, and the cumulative burden of government workstreams.ÌýWhile there was recognition of engagement efforts by theÌýMarine Management Organisation (MMO) theÌýneed forÌýbroader participation, better resource allocation, and a clear implementation phase to ensure meaningful outcomesÌýwere flagged.

Question 3:ÌýDo you have any comments on the goals in theÌýdraftÌýFMP?Ìý

The majority ofÌýstakeholdersÌýemphasisedÌýthat while sustainable stock management is essential, itÌýshouldÌýtakeÌýaccountÌýofÌýthe economic challenges faced byÌýfishermen. This includesÌýfor example,ÌýtheÌýrising operational costs and reduced quotas. Some catching sector representatives expressed concern about disproportionate economic burdens stemming from proposed measures, particularly in relation to smallerÌýoperators andÌýflyseiningÌývessels.Ìý

There was consensus across all stakeholder groups thatÌýdata gapsÌýremainÌýa critical issue, hinderingÌýaccurateÌýstock assessments and effective monitoring. They highlightedÌýtheÌýneed to include catch data from private and charter vessels to gain a moreÌýaccurateÌýpicture of exploitation. Some advocatedÌýforÌýmoreÌýcomprehensiveÌýdataÌýthroughÌýthe use ofÌýsystems like remote electronic monitoring (REM),ÌýinÌýparticular forÌýaddressing cetacean and seabird bycatch.ÌýImproved data collectionÌýis vitalÌýto ensure evidence-based decision-making. It isÌýparticularlyÌývitalÌýfor data-poor stocks andÌýgrowingÌýfisheries like cephalopods sensitive to environmental changes andÌýwithÌýshort life cycles.ÌýSome stakeholdersÌýsoughtÌýadaptable management strategies forÌýtheseÌýgrowingÌýfisheries to ensure sustainability. ThisÌýsuggestsÌýcephalopodsÌýareÌýfished only when profitable and operationsÌýceaseÌýif their populations decline.Ìý

WhileÌýtheÌýmajority ofÌýstakeholdersÌýsupportedÌýthe FMPÌýgoals,ÌýtheyÌýasked for clarity and specificity in theirÌýwording.ÌýSomeÌýwanted clarity on who wouldÌýbe responsible forÌýtheirÌýimplementation and how this would be achieved.Ìý

There were alsoÌýcalls for greater ambitionÌýin line with the Fisheries ActÌý2020Ìýand transparency in restoration targets, performanceÌýindicatorsÌýand timescales.ÌýEnvironmental stakeholders,Ìýin particular,ÌýsoughtÌýmoreÌýmeasurable targets, clearerÌýdefinitions and precise implementationÌýstrategies,ÌýalongsideÌýbespokeÌýapproachesÌýforÌýboth smallÌýand largerÌýscale fisheries.ÌýSeveral stakeholders, notablyÌýfrom the recreationalÌýsector, wantÌýto seeÌýsocio-economic considerationsÌýregardingÌýcommunities,ÌýbusinessesÌýand individualsÌýgiven equalÌýweighting toÌýecological sustainability needs.ÌýAÌýneed to integrate recreational fisheries data and coastal community impacts into the FMPÌýwas highlighted.ÌýOthersÌýhÌýwantedÌýbetterÌýdevelopment ofÌýtheÌýknowledge, tools, and collaboration needed to manage fisheries and conservation efforts moreÌýeffectively. They alsoÌýwanted betterÌýstakeholder engagementÌýin lineÌýwith recommendations for developing scientificallyÌýbased measuresÌýsuch as a MCRS.ÌýAlignment with broader initiatives likeÌýdiscards reformÌýand strategies for reducing cetacean bycatch to support biodiversity and conservation effortsÌýwere also suggested.

Question 4:ÌýDo you have any comments on the measures and actions in theÌýdraftÌýFMP?

Views on theÌýproposed measures and actionsÌýwere mixedÌýboth between and within sectors. Several stakeholdersÌýsupportedÌýflyseiningÌýrestrictions (includingÌýa full prohibition) toÌýtackleÌýpotential overfishing,Ìýreduce mortalityÌýratesÌýandÌýpotentially high discards and bycatch rates.ÌýOthersÌýwere supportive of management measures to protect NQS species from overfishing,Ìýsuch as introducingÌýaÌýMCRS and a stricter application of the precautionary principle.Ìý

Some producer organisations and non-UK government organisations questionedÌýthe focus on restrictingÌýflyseining,Ìýwhich theyÌýview asÌýsustainable and low-impact fishing method regulated under existing measures.ÌýTheyÌýargueÌýthat increasing mesh sizes to 100mm and limiting engine power to 221kWÌýisÌýunnecessary and potentially harmfulÌýtoÌýcommercialÌýfishermenÌýwithoutÌýclear evidenceÌýof stock health benefits.ÌýThey soughtÌýgreater harmonisation ofÌýmeasuresÌýacrossÌýUK and EU waters to ensure fairness and effectiveness.ÌýPerceived discriminationÌýagainstÌýboth UK andÌýEUÌýflyseinersÌýandÌýanÌýoverly cautious application of the precautionary principleÌýwereÌýhighlightedÌýby some in the catching sector.ÌýIt was asserted thatÌýflyseiningÌýrestrictionsÌýintroducedÌýin the Channel had led to maritimeÌýsafetyÌýissues dueÌýto displacementÌýof effortÌýinto EU watersÌýandÌýassociatedÌýriskÌýofÌýoverfishingÌýin those waters.ÌýA minorityÌýalsoÌýopposedÌýthe introduction ofÌýaÌýMCRS forÌýanyÌýNQS species and any restrictions or measures relating to the cephalopod fishery.

Environmental stakeholders,Ìýin particular,ÌýadvocatedÌýforÌýincreased research and precautionary measures,Ìýto protect theÌýgrowingÌýcephalopodÌýfisheriesÌýand provideÌýopportunities for industry diversification. SomeÌýstakeholders acrossÌýthe environmental,ÌýcatchingÌýandÌýrecreational sectorsÌýsupportedÌýdeveloping codes of conductÌýtoÌýpreventÌýoverfishing and preserveÌýecological balance, such as safeguarding cuttlefish eggs.ÌýManyÌýfromÌýtheÌýenvironmental, recreational and producerÌýsectorsÌýsupportedÌýthe use ofÌýaÌýMCRS for species likeÌýsmoothhound, red mullet, and gurnards, provided these measuresÌýwere evidence based and avoid inconsistencies.ÌýEnvironmental,ÌýrecreationalÌýand catching sectorÌýstakeholdersÌýhad similar views,ÌýcallingÌýfor mandatory REM to improve bycatch research and evidence gatheringÌýandÌýinform decision-making.

SomeÌýcatching sectorÌýstakeholders highlighted the importance of involvingÌýfishermenÌýin the management process, particularly for small-scale fisheries, to ensure that regulations are practical andÌýequitable.ÌýIndustry dialogueÌýis criticalÌýtoÌýeffective fisheries managementÌýwith callsÌýfor a more balanced, regional approach that considers the diverse needs of different fleets.

Question 5:ÌýAre there other measures or variations of the proposed management measures we could consider?Ìý

Several respondentsÌýfrom the recreational and catching sectorsÌýsupportedÌýthe FMP as a comprehensive framework for using scientific evidence to assess stock status and ensure sustainable fishing practices.ÌýManyÌýstressedÌýthe importance of balancing sustainability with economic viability and advocatedÌýfor active stakeholder participation in decision-making.ÌýThe catching sector in particular want further assessment ofÌýimpacts beforeÌýdeciding onÌýspecific management measures. Instead of imposing restrictions, they suggested incentivising sustainable fishing practices.

A number ofÌýrecreational and environmentalÌýstakeholders highlighted the ecological damage caused by beam trawling. They calledÌýfor it toÌýbe phased out,Ìýas wellÌýasÌýprohibitingÌýflyseining,Ìýto addressÌýhigh bycatch rates and habitat disturbance, while promoting more selective, low-impact fishing methods.ÌýAÌýminimum mesh size of 100mm for commercial vesselsÌýwas suggested.Ìý

EnvironmentalÌýstakeholdersÌýgenerallyÌýsupportedÌýspecies-specific measures such asÌýintroducingÌýminimum and maximumÌýconservation referencesÌýsizes, especially for finfish and slower-growing species. TheyÌýsoughtÌýconservation measures for vulnerable species and proposedÌýharvest control rules for cuttlefish to avoid overfishing.

BothÌýenvironmental and recreationalÌýstakeholdersÌýwere keenÌýto prioritiseÌýthe implementationÌýofÌýREMÌýto helpÌýreduceÌýbycatch.ÌýOther points raised included theÌýimportance ofÌýmitigatingÌýbenthicÌýimpactsÌýand risks to seafloor integrityÌýTheyÌýcalled forÌýspatial management measures, effort limitations, and improved vessel tracking to ensure compliance with wider fisheries legislation.Ìý

SomeÌýinÌýlocal governmentÌýsuggestedÌýaligningÌýNQSÌýapproaches acrossÌýEnglish and Scottish waters, recommending a regional strategy due to geographical differences.Ìý

Further suggestions wereÌýtoÌýexploreÌýalternative harvest strategies.Ìýsuch asÌýMaximumÌýEconomicÌýYieldÌý(MEY)Ìýand ecosystem-based fisheries management.ÌýSuggestionsÌýhighlighted these strategies should beÌýsupportedÌýby independentÌýadvice fromÌýtheÌýInternational Council for the Exploration of the Sea (ICES)Ìýon:Ìý

• rebuildingÌýdepleted stocksÌý

• addressingÌýsignificant data gaps in bycatch and habitat impacts

QuestionÌý6: Do you have anyÌýadditionalÌýcomments on theÌýdraftÌýFMP?Ìý

WhileÌýappreciative ofÌýthe summary provided withinÌýthe consultation documentation, some in local governmentÌýfeltÌýthe lengthÌýand complexity ofÌýconsultationÌýdocuments madeÌýthem inaccessible to some stakeholders.ÌýOther sectorsÌýechoedÌýthis viewÌýnoting the critical importance of stakeholder engagement,Ìýwith callsÌýfor more concise,Ìýaccessible communication.

There wasÌýsomeÌýcriticism of theÌýFMP drafting process. Some feltÌýthat itÌýwas notÌýtransparentÌýorÌýinclusive,Ìýparticularly concerning flyseining and lacked evidence, with an over-reliance on the precautionary approach. Some favoured including wider marine sectors in developing the FMP, given the Southern North Sea is a busy region. However, they did not want these sectors to disproportionately influence commercial fishing activities. A perceived lack of evidence regarding proposed management measures in the supporting DMA and environmental report was also mentioned.

The need forÌýaÌýregular reviewÌýof the FMP, carefulÌýimplementationÌýand early engagement withÌýfishermenÌýto ensure effective outcomesÌýwas also noted.ÌýSomeÌýcatching sector stakeholders reiterated concerns regarding the exclusion of flyseiners from certain zones being a potential breach of the TCA, urging adherence to international obligations. Others opposed the FMP and any proposed flyseining restr ictions.

Greater use of the SCFÌýto discussÌýshared NQS fisheries, and potential negative economic impacts were also highlighted. These impacts included, for example, displacement of fishing effort into EU waters, or reduced UK quotas if NQS became TAC species. A number of stakeholders across sectors challenged Defra’s stance on voluntary measures being less enforceable than compulsory measures.

A variety ofÌýrecommendationsÌýwere made by recreational,ÌýcatchingÌýand other sectors. TheyÌýranged fromÌýfurtherÌýspecies protection and sustainable stockÌýexploitationÌýfor marine habitatsÌýtoÌýthe diversification of commercial inshore fisheries (particularly for growing cephalopod fisheries). This emphasised the sustainability of seasonal fishing practices.

ÌýThe economic and ecological importance of species like squidÌý(targetÌýspeciesÌýand bycatch)ÌýwasÌýnoted,Ìýwith calls forÌýconsideration of impacts on relatedÌýnephropsÌýand pot fisheries.ÌýTheÌýdesignation ofÌýsmoothhoundÌýas a recreational-only speciesÌýwas suggested,Ìýin recognition ofÌýits limited commercial value but significant socio-economic importance to recreationalÌýfishermen.ÌýA ban onÌýindustrial-scale trawling within UK territorial waters,Ìýgreater awareness ofÌýfish welfareÌýandÌýintegration into wider policyÌýobjectivesÌýwereÌýalso raised.

QuestionÌý7:ÌýDo you have any comments on the assessment of the environmental effects ofÌýthe FMP, as set out in theÌýenvironmentalÌýreport?Ìý

StakeholderÌýconcernsÌýfocused onÌýthe FMPÌýneeding to ensure itÌýachievesÌýa balance between environmental sustainability and economic interests. They notedÌýthat the proposed measures might disproportionatelyÌýimpactÌýfishing livelihoods in the short term.ÌýStronger enforcement and clearer explanationsÌýwere proposedÌýto avoid conflicting regulations.

Stakeholders from the catching and producer sectors acknowledged that the environmental report highlights seabed disturbances caused by demersal towed fishing gear and other marine activities. ThisÌýhindersÌýprogress toward achievingÌýGood Environmental Status. However, they also stressed the importance of considering natural sediment movements in the assessment.ÌýOtherÌýconcerns wereÌýraised over potentially biased mortality estimates for harbour porpoises in the Greater North Sea and the use of data that could lead to unrepresentative bycatch limits.

FurtherÌýconcerns were raised byÌýproducer sectorÌýstakeholdersÌýover inconsistencies in FMP measure.ÌýIn particularÌýgearÌýmesh sizesÌýwereÌýcriticised for being precautionary yetÌýareÌýunsupported by evidence. Some stakeholders suggested the environmental report is too broad, does not focus on localised issues and focuses primarily on Marine Plans, overlooking connections to other FMPs. Others felt the environmental report lacked contextual evidence. Recommendations from various stakeholders included:

• undertakeÌýfurther studies on fishing gear effects on benthic resources and sediment typesÌý

• giveÌýgreaterÌýconsideration toÌýtheÌýadverse impacts on fishing communities when managing fishing in marine protected areas

Government response: FMPÌý

Views were diverse with a range of opinions within and betweenÌýstakeholderÌýgroups.ÌýWe have considered all views providedÌýby those whoÌýrespondedÌýto the consultation.ÌýThis section explainsÌýthe change we have made to the FMP in response toÌýthese views and why we have takenÌýparticular decisions.

OverviewÌý

The FMPÌýsets outÌýhow weÌýplan to manage fishing activityÌýforÌýdemersalÌýNQSÌýstocks in the Southern North Sea. The aim isÌýtowards more sustainable fisheries, and for the benefit ofÌýmarine users and local coastal communities.

FollowingÌýa publicÌýconsultation, thereÌýwas broad support for the proposed goals and actions in the FMP. There was some opposition from some producer organisations and non-UK government representatives to our proposedÌýflyseiningÌýrestrictions. However, this was counter-balanced with support across sectors for restrictingÌýflyseiningÌýactivity,Ìýwith some calling forÌýaÌýtotal ban for this gear type.Ìý

To achieveÌýthe ambitions of the FMP, we will improve our scientific and evidence bases to better understand the fisheries that are included in the FMP. We will continue collaborating with stakeholders toÌýidentifyÌýhow we can close the main evidence gaps affecting how we manage these fisheries.

We will conduct research into growing cephalopod fisheriesÌýandÌýconsider MCRS for certain NQS species in the medium term.ÌýWe’llÌýalsoÌýlook at increasing education into species, identification,ÌýhandlingÌýand welfare across the recreational and commercial fishing sectors.Ìý

All the measures in the FMP are focused on achieving our ambitions for sustainable demersal fisheries in the Southern North Sea for current and future generations. The measures in the FMP will take time to implement. However, we will continue to collaborate with individuals and representatives across all the fishing sectors,ÌýregulatorsÌýand wider interest groups on the sustainable management of the Southern North SeaÌýNQS fishery.

Changes to the FMP following consultation

RecognisingÌýconcernsÌýaboutÌýclarityÌýand accessibility, weÌýhave amendedÌýtheÌýlanguage inÌýthe finalÌýFMPÌýtoÌýremoveÌýambiguityÌýandÌýensureÌýtheÌýrationaleÌýfor measuresÌýis clear.Ìý

We acknowledge the strength of opinionÌýfromÌýa small number of stakeholders regarding best available evidence, application of the precautionary approach and the rationale underpinning measure for managing flyseining effort in ICES Areas 4b and 4c. We reaffirm that the best available evidence including socio-economic data has been used to develop the FMP. We note that little alternative, verifiable evidence was provided in the consultation responses. Also, we recognise remaining concerns that data-poor NQS stocks are at risk of exploitation with little or no sustainability assessments. However, we will consider the implementation of these measures further and have updated the language in the FMP to reflect this.

AnÌýerror in theÌýdeÌýminimisÌýassessmentÌýhasÌýbeen corrected. InÌýparagraph 4 in the problem under considerationÌýsection, 2021Ìýlandings in ICESÌýareas 4b and 4cÌýwere given asÌý11,000 tonnes valued at £21.6Ìýmillion.ÌýHowever, the correctÌýlandingsÌýtotalled 2,200 tonnes, valued at £5.9 million. We have also added a reference to the Animal Welfare (Sentience) Act 2022 in the FMP that formally recognises cephalopods as sentient beings.

You can readÌýheÌýfinal versionÌýof theÌýSouthern North Sea demersal non-quota species fisheries management plan.

Overview of cross-cutting or common responses and questions across FMPs in the consultation

In this section, we summarise the various cross-cutting FMP themes that emerged through the consultation responses. We explain why we have taken particular decisions. Given the volume, breadth and detail or the responses, we are not able to provide detailed explanations on all points raised.

Engagement and collaborative working

We are grateful for the support of the fishing sector and wider stakeholders for engaging with our process to develop the FMPs.

While stakeholder views on theÌýengagement process for developing the FMPs varied, many recognised the significant efforts that went into engaging stakeholders, However, it wasÌýgenerally feltÌýthat it could have been better. Notably, the UK General Election in 2024ÌýnecessitatedÌýa hiatus in development and engagement.Ìý

The collaborative approach taken was valued byÌýthe majority ofÌýrespondents. However,Ìýthere was some criticism that the process prioritised the fishing sector in some instances,Ìýleading to inherent bias in the FMPs.

There was little common ground between or within interests or sectors on the preferred engagement method. Some favoured tailored engagement,Ìýwhile othersÌýsoughtÌýa fully collaborative approach. While we aim to find a balance across sectors with frequently variable views, we recognise there is scope to bring some sectors into the process at an earlier stage. This would ensure genuine collaboration.

A clear message from many respondents was recognising the importance of enabling those with a stake in fisheries,ÌýtoÌýparticipateÌýin the management of those fisheries. We are committed to working with the fishing sector and wider interests to co-design FMP policies and measures. WeÌýacknowledgeÌýthat a greater role in decision making carries sharedÌýresponsibility toÌýensureÌýwe are abiding by our legal and international commitments. It also helps ensure weÌýare balancingÌýenvironmental,ÌýsocialÌýand economic sustainability along withÌýthe otherÌýobjectives.

As part of ongoing work to explore how we continue to develop and implement a collaborative approach to FMPs and fisheries management more widely, we held an engagement pilot. It took placeÌýin Cornwall in October 2024ÌýandÌýbought together commercialÌýfishermen,ÌýregulatorsÌýand government to discuss key fisheries issues,Ìýincluding FMPs. Future opportunities engaging a broader range of stakeholders and different areas of the country are being considered.Ìý

Some stakeholders cited ‘FMP fatigue’ as an issue andÌýsoughtÌýmore streamlined communication across plans.ÌýWe welcome continued engagement with the FMP development process by all interested stakeholders. It is impractical for government and regulators to engage individually with all those with an interest, in the same way it is impractical for all individuals to engage with us. In recognition of the resource constraints highlighted by most respondents, we encourage sectors to consider how to organise themselves into representative groups to feed views into the wider FMP programme. This will reduce the associated burden of engagement.

We continue to review our engagement.ÌýBuilding on workÌýinitiatedÌýlast year,Ìýwe have improved communication across the FMP programme. WeÌýlaunchedÌýan FMP blog in May 2024,ÌýthatÌýbringsÌýthe latest FMP developments and engagement information together on a single,Ìýaccessible platform with regular updates.Ìý

Many respondents called for continued participation through to the implementation phase of the FMPs. Stakeholder involvement and ongoing collaboration underpins successfulÌýdelivery of the FMPs and will continue into the implementation phase.

Consultation processÌýandÌýdocumentationÌý

Many respondents criticised theÌýlargeÌýnumberÌýof FMP consultations. Combined with other policies relevant to the fisheries sector, they create an overwhelming engagement burden, leading to calls for a coordinated approach across government. While we recognise the resource impacts for industry and wider stakeholders, the formal consultation process gives allÌýinterested parties the opportunity to give their views and help shape the developing FMPs. This is in line with the co-design principle supported byÌýthe majority ofÌýstakeholders. ItÌýalso recognisesÌýthe guidelines for public consultations and our statutory requirements.

As mentioned, efforts to find common ground and form representative organisations within or across sectors is encouraged,Ìýto help minimise the resource burden. Moreover, we would be interested to understand from stakeholders their views on streamlining engagement on fisheries management issues more generally.

Some respondents felt the consultations lacked sufficient scientific evidence to support the main consultation documents. Our consultation approach is designed to be transparent and provide evidence and supporting material to help stakeholders provide informed responses. It follows extensive engagement and informal consultation prior to the draft FMPs being developed.Ìý

We learned valuable lessons from the consultation process on the first set of FMPs in 2023. In response to stakeholder feedback, we adopted a different approach. We aimedÌýto strike a better balance between the volume of consultation documentationÌýandÌýalsoÌýensuringÌýstakeholders have sufficient information to engage meaningfully with the consultation process. We reduced the overall volume of material, the number of consultation questions and incorporated evidence directly supporting the proposed goals or measures into each plan. We publishedÌýtheÌýmore detailedÌýevidenceÌýstatement duringÌýtheÌýconsultation periodÌýso those who want further background information can read it. We acknowledge doing this in parallel with launching the consultation would have been more beneficial for some respondents and will make this happen in future consultations.Ìý

Inconsistent language across FMP documentation was raised as an issue by some stakeholders,Ìýmaking it difficult to understand the rationale for proposed or timescales for delivery. We acknowledge that FMP terminology has been variable and are working to simplifyÌýitÌýwhere possible. We are also working toÌýensure greater consistency across the FMPs and allÌýfuture plans.

Consultation is an on-going process. Our aimÌýisÌýto strike a balance between formal and informal consultation activity that allows thoseÌýimpactedÌýby the policies to meaningfully engage in the process. We will continue to consider different approaches in future as well as how much information is published at various stages.

Implementation and pace of change

In December 2024 following public consultation, we took the decision to amend the timescales for FMP production and publication contained in Annex A of the JFS.ÌýThe decision was made after changes to scientific advice and a pause in work resulting from the 2024 UK General Election.Ìý

Some respondents expressedÌýa strong desireÌýfor clearer commitmentsÌýandÌýmore specific and faster timescales for delivery of actions. This issue was raised in earlier FMP consultations and changes made accordingly to deliver some key changes more quickly. However, it has led to fresh concerns about the impacts of delivering change too quickly on the fishing industry. It includes a need for continued stakeholder involvement in designing FMP measures. We have therefore balanced views against resources and a recognition that too much change would not be deliverable or could create unreasonableÌýburdens on the fishing sector.Ìý

Many of the actions in the FMPs are to gather more data and consider options. This is because most of the plans cover non-quota stocks which have little management and are data poor. This requires new evidence to ensureÌýappropriate measures,Ìýbased on the best available scientific advice,Ìýare introduced. We are learning continuously and through implementation of the FMP actions, changes will be made to the fisheries management.ÌýThe FMPs will be reviewed at least every six years.

We are working collaboratively with sector representatives to define how best to deliver the goals of published FMPs. ThisÌýapproach will continue during the implementation phase of these plans.

Some stakeholders raised the issue of REM and were keen for it to be mandatory toÌýfacilitateÌýmonitoring and compliance of FMPs. We are consideringÌýcollaborative and innovative ways of gathering and using data, including technologies such asÌýREM.

Cumulative impactsÌý

Questions wereÌýraised about the cumulative impacts of FMP measures,Ìýboth within and across the plans.Ìýas well as overlap with other policies and activities in the marine environmentÌýthatÌýcontributeÌýto spatial pressures on the fishing sector.

FMPs are designed to appropriately balance impacts.ÌýThis includesÌýbeing mindful of maintaining economic viability without jeopardising the sustainable long-term recovery of stocks or delivery of a healthy marine environment for all sectors. Impacts are considered as plans are developed, ensuring they are deliverable. As those plans are implemented, further consideration of the cumulative impacts of measures will be made. Our collaborative approach to delivering FMPs, will enable the fishing sector to contribute its information on activities and impacts to help co-design management actions.

We have heard very clearly,Ìýthe concerns about increasing spatial pressures and continue to talk to the fishing industry and wider government about these issues. The cross-government Marine Spatial Prioritisation programme continues to engage with various sectors to discuss potential barriers and solutions to co-location.

Our FMPs recognise that displacement of fishing effort can result from the introduction of spatial, and other restrictions. To address this, actions toÌýmonitorÌýand where applicable mitigate displacement and its social,ÌýeconomicÌýand environmental impacts have been included.

FMPs allow for adaptive management and so can take changes in evidence or wider use of the seas into account in their implementation.

Application of the precautionary approach

Respondent views on the application of the precautionary approach varied between and within sectors.ÌýSome calledÌýfor management measures of data poor stocks to be prioritised.ÌýOthers were concerned about the risk of potential social and economic impacts in its application. Questions were raised about the process for developing precautionary management measures, particularly within mixed fisheries, and how stakeholders would be involved.Ìý

In lineÌýwith the Fisheries Act, FMPs set out goals and measures to manage stocks sustainably based on the best available scientific advice and using a precautionary approach where there is insufficient data. Lack of data is not a reason to not act or postpone the implementation of effective management measures that will conserve a stock or its environment. Decisions on precautionary management measures must be balanced and proportionate alongside the other fisheries objectives. This approach will also take account of wider responsibilities including international agreements.

In response to feedback, we have strengthened the language in the FMPs, making clearer the factors used toÌýdetermineÌýprecautionary measures. Our aim is to work with the fishing sector and wider stakeholders to develop and agree the right precautionary measures to proportionately manage the risks and ensure fish stocks are sustainable into the future.

Collaboration with the EU and compliance with the UK and EU Trade and Cooperation Agreement (TCA)

A number ofÌýEU respondents raised the importance of ensuring sufficient engagement opportunities in the FMP development process, and at an early stage. While membership of working groupsÌýestablishedÌýto develop the draft FMPs appropriately consistedÌýof UK stakeholders, plansÌýare required toÌýgo through a public consultation giving all interested parties the opportunity toÌýprovideÌýtheir views.

The importance and value of close working with other coastalÌýStates on fisheries management, particularly for shared stocks, continues. We are working with the EU to pilot new ways of working on FMPs at earlier stages of development and on implementation of published plans. This will strengthen cooperation and our collaborative relationship.

EU stakeholders were keen for measures to be developed throughÌýthe SCF, to harmonise fisheries management and make implementation more effective. Recognising the transboundary nature of fisheries and working collaboratively with coastalÌýStates wereÌýalso encouraged by some of our domestic stakeholders. While it is not a requirement to discuss FMPs at theÌýSCFÌý(or for the EU to discuss their policies), co-operation with the EU on the management of shared stocks will continue. For example, the UK and EU will discuss a multi-year strategy forÌýking scallops, and we will continue to engage with the EU during the development and implementation of FMPs which will affect EU vessels.Ìý

EU stakeholders were also concerned that proposed measures might affect access arrangements agreed under theÌýTCA. TheyÌýstronglyÌýemphasisedÌýtheÌýprinciples of cooperation, proportionality, non-discrimination and using best available scientific evidence to manage stocks sustainably. The TCA preserves the regulatory autonomy of the UK to manage its fisheries while ensuring that the interests of the EU and vessels of member states are properly considered. FMPs have been developed to ensure the UK complies with its obligations under the TCA including during the implementation phase when proposed measures may be taken forward.

A few respondents disputed our application of the precautionary principle, and the interpretation of best available scientific advice under the TCA. It is right to pursue policies and consider the introduction of measures in order to protect stocks. The FMPs have been designed to balance the requirements of the Fisheries Act, along with the UK’s international obligations. including those in the TCA. This includes basing measures on the best available scientific advice and adopting the precautionary approach where appropriate. Additionally, FMPs allow us to introduce bespoke, evidence based and adaptive management.

FMP evidence and data

MostÌýrespondents were positive about the approach to developing an evidence pathway that promotesÌýcollaborationÌýbetween industry,ÌýacademiaÌýand fisheries managers to address evidence gaps. We willÌýcontinueÌýwith this approach.

We acknowledge the substantial amount of evidence that needs to be collected to fill existingÌýgaps.ÌýWe also acknowledgeÌýtheÌýquestions raised aboutÌýtheÌýgovernment’s ability to address:Ìý

• evidence gapsÌý

• timelines for deliveryÌý

• making FMP evidence more accessible to the fishing industryÌý

We are starting to address some of the highest priority gaps through Defra funded researchÌýprojects including improving data collection and stock assessment methods, exploring sustainable fishing practises and managementÌýtoolsÌýand improving the social and economic evidence base of FMPsÌý

FMPs are a priority for fisheries funding. The Fisheries and Seafood Scheme (FaSS), provides financial assistance for projects that support the development of the catching, processing and aquaculture sectors, and for projects that enhance the marine environment. The latest round of funding announced on 9 June will support projects in the 2025 to 2026 financial year covering science fisheries partnerships. Projects will be required to collect data to address evidence gaps identified in FMPs.

However, it will not be possible orÌýappropriate forÌýtheÌýgovernment to fund all the evidence gapsÌýidentifiedÌýacross the FMP programme. PrioritisationÌýof FMP evidence gaps continues alongside looking at innovative ways to fill thoseÌýgaps, including for example remote electronic monitoring. Where evidence gapsÌýidentifiedÌýin these FMPs are prioritised,ÌýtimeframesÌýmay be bought forwards.

We continue working with the fishing sector and wider stakeholders to support the delivery of evidence requirements. AnÌýevent held in March,ÌýexploredÌýthe future direction of collaborative science for FMPs. It includedÌýa callÌýsubsequentlyÌýissued to industry and widerÌýstakeholders seeking theirÌýhelpÌýto provide the evidenceÌýrequiredÌýto support the phased approach of FMP delivery and implementation.Ìý

Some stakeholders were keen for the scientific advice used to inform the development of management measures,Ìýto be more clearlyÌýevidencedÌýin the FMPs. Others emphasised the importance of adhering to the TCA principle of using the best available scientific advice and collaboration with EU scientific bodies.Ìý

There were also a few comments about FMPs not contributing to the ICES scientific advice benchmarking process,Ìýwhich appear to have been misunderstood. UK scientists make a significant contribution at all levels of its advisory process, including on the Science and Advisory Committees and through participation in expert groups. We continue toÌýdetermineÌýFMP policies and management measures informed by the best available scientific advice, including that from ICES.Ìý

A number ofÌýrespondents felt the FMPs could be strengthened by the addition of harvest control rules (HCRs) or harvest strategies based on alternative biomass reference points.ÌýIn line with the Fisheries Act,Ìýthe overarching harvest strategy for all FMPs is for fisheries to be managed sustainably. FMP harvest strategies can includeÌýappropriate HCRsÌýwhich will require a sufficient level of data and understanding of a stock to be developed and implemented.

Government response: environmental reportÌý

This section sets out the government’s response to theÌýSouthern North SeaÌýdemersal NQSÌýFMPÌýStrategic Environmental AssessmentÌý(SEA),ÌýenvironmentalÌýreport consultation.Ìý

Stakeholder responses have been considered and theÌýSouthern North SeaÌýdemersal NQSÌýFMPÌýenvironmental reportÌýhas been updated withÌýadditionalÌýrecommendations. These updates have been considered in the revised FMP.ÌýTheÌýfull environmental reportÌýhas been published alongside the FMP.

Changes to the environmental report following consultationÌý

Some stakeholdersÌýnotedÌýtheÌýreports highlightsÌýthe widespread disturbance of seabed habitats by demersal towed fishing gear and marine activities, preventing good environmental status.ÌýWhile other stakeholders emphasised the importance of accounting for natural sediment movements when considering seabed disturbance.ÌýIt is our view that theÌýstatutory natureÌýconservation bodiesÌý(SNCB)Ìýadvice for the FMP provides sufficient evidence at this stage toÌýdetermineÌýthe potential effects of fishing on the benthicÌýenvironment. We acknowledge that further studies would be useful but would be directed by the Benthic Impact Working Group,Ìýas set out in the report.

WeÌýnoteÌýconcerns aboutÌýtheÌýevidence used within the environmental report related to harbour porpoiseÌýbycatch.ÌýWeÌýacknowledge that there may beÌýdiscrepancies in the data used by the underlying studies referenced.ÌýInÌýresponse, weÌýhave proposed to gather more data on bycatch to better our understanding.Ìý

ToÌýaddress concerns that the report focusedÌýlargely onÌýmarineÌýplans, raising questions on relevance for in-combination effects of the FMP, we have addedÌýadditionalÌýdetailÌýfor clarity.ÌýMarineÌýplansÌýare helpful tools that:Ìý

• set out priorities and directions for future development within the plan areaÌý

• inform sustainable use of marine resources and help marine users understand the best locations for their activities

Marine plans alsoÌýconsider all marine activities,ÌýresourcesÌýand ecosystems. This means assessing FMP policies against marine plan policies is the most efficient way of determining how FMP policies will broadly interact with other marine activities. It also ensures compliance with section 58 of the Marine and Coastal Access Act 2009.

AnotherÌýconcernÌýwasÌýthat the FMP does not address where different gear types areÌýallowedÌýto useÌýdifferent mesh sizes such as 80mm mesh for otter trawl vessels and 40mm gear for otherÌýdemersalÌýNQS fisheries. In comparison,ÌýflyseinersÌýwould have to use 100mm mesh sizes.

Having different meshÌýsize requirements for different gearsÌýcan already be foundÌýin fisheries managementÌýforÌýdifferent reasons, such as improvingÌýjuvenile survivability. While there were some concerns about the impact of other bottom-towed gear types and other methods of fishing, flyseining was identified as a priority for introducing stock protection measures. Introducing effort management for vulnerable and data-poor NQS in a new fishery with large capacity vessels, is based on the best available scientific evidence. It is also supported by the precautionary objective in the Fisheries Act. However, we will consider implementation further and have updated the language in the environmental report to be consistent with the updated wording in the FMP.

Annex 1:ÌýList of organisations that did not request confidentialityÌý

• Angling TrustÌý

• BassÌýAnglingÌýConservationÌý

• Blue Marine FoundationÌý

• ComitéÌýNational desÌýPêchesÌýMaritimes et desÌýElevagesÌýMarinsÌý

• ComitéÌýrégionaleÌýde laÌýpêcheÌýmaritime et desÌýélevagesÌýmarinsÌýHauts-de-FranceÌý

• Cuttlefish Conservation InitiativeÌý

• East Anglian Charters

• Eastern England Fish Producers OrganisationÌý

• Eastern Inshore Fisheries and Conservation Authority

• European Association of fish Producers OrganisationsÌý

• Fishing Forward UKÌý

• French authoritiesÌý

• Historic EnglandÌý

• Humberside Fish Producers Organisation LtdÌý

• Joint Nature Conservation CommitteeÌý

• Kent & EssexÌýInshore Fisheries and Conservation AuthorityÌý

• National Federation of Fishermen’s Organisations

• Natural England

• NederlandseÌýVissersbondÌý

• North Sea Advisory CouncilÌý

• North Sea Fishermen’s OrganisationÌý

• Northumberland Inshore Fisheries and Conservation AuthorityÌý

• Office for Environmental Protection

• The Open Seas TrustÌý

• Permanent Representation of Belgium to the EUÌý

• Scottish Fishermen’s FederationÌý

• Scottish White Fish Producers AssociationÌý

• Shark TrustÌý

• Whale and Dolphin ConservationÌý

• Wild Animal Welfare Committee