OEP response to Joint Fisheries Statement consultation
The Office for Environmental Protection has published its consultation response to Defra’s Joint Fisheries Statement (JFS).
While welcoming the government’s ambition to deliver world class, sustainable management of our sea fisheries and marine aquaculture, our response identifies six areas where the proposals should be strengthened.
Dame Glenys Stacey, Chair of the OEP, said: “The Joint Fisheries Statement is a fantastic opportunity for government to set the direction for achieving its ambitions.
“We set out recommendations in our response that we hope will assist and make the Statement more likely to lead to the achievement of the stated objectives.”
“We are pleased to see that the ecosystem objective set out by the Fisheries Act embeds for the first time a direct link between fisheries management and the broader UK Marine Strategy.
“The JFS is an opportunity to take an important step towards meeting this objective. Government can establish a policy framework for sustainable fisheries management which exceeds what was achievable under the constraints of the Common Fisheries Policy.”
The six areas identified for improvement by the OEP are:
Fully integrated approach to management
To deliver the vision set out in the 25 Year Environment Plan, the draft JFS must integrate fisheries management with government’s broader target to achieve Good Environmental Status. This means ensuring that fish stocks are exploited sustainably, but also protecting the wider marine ecosystem that supports these stocks.
Overall, the current draft lacks the detail needed to deliver government’s ambitions. Commitments are often caveated or overly uncertain. We recommend the inclusion of clear, achievable and timebound commitments throughout the draft. This would give the JFS teeth, whilst providing the certainty that the sector needs to effectively plan for future regulation.
Marine spatial planning
Although the draft does briefly acknowledge that marine plans should include policies that consider fisheries, it misses an opportunity to take steps to fully integrate commercial fishing into the marine planning system. We strongly advise that the JFS is amended to support policies which pursue a marine planning system that encompasses all major uses of the seas.
Environmental Impact Assessment
In our view, the draft JFS should set out a clear ambition to incorporate fisheries into an Environmental Impact Assessment (EIA) regime. At present, commercial fishing is one of the only economic activities that does not need to undergo screening for an EIA before a license is granted. Requiring new and existing fishing operations to demonstrate that they would not have a significant effect on the marine environment would bring fishing into line with the regulation governing other extractive processes, where environmental costs must be internalised and not passed on to the rest of society. This would be a major step towards implementing an ecosystem-based approach to fisheries management.
Marine Protected Areas
A well-designed and well-managed network of Marine Protected Areas (MPAs) is perhaps the single most practical tool for achieving the aims of the Marine Strategy. There are known difficulties associated with ensuring compliance within MPAs, however. The JFS can signal clearly the step change needed, by further developing and specifying the way in which fishing activities will be managed effectively.
Reducing bycatch and minimising discards
The draft JFS makes commitments to reduce the incidental catch of undersized fish, marine mammals, and seabirds, but offers limited guidance as to how this will be achieved. It also lacks explanation of how non-compliance with rules to deter bycatch will be monitored and enforced. Whilst we agree that detailed policy should be reserved for FMPs, we believe that the threat that bycatch poses to the achievement of the ecosystem objective justifies a more joined-up approach to mitigation at national level. In the absence of a published UK Bycatch Mitigation Initiative, we advise that the JFS be amended to outline the policies that fisheries administrations should implement to deliver on the commitments being made.
Dame Glenys added: “In our recommendations we have sought to outline what we think is needed to achieve government’s ambitions for Good Environmental Status in UK marine waters. By strengthening the final JFS, Defra can set a new direction for fisheries management that is both ambitious and subject to appropriate public scrutiny.”