Defra’s consultation on the proposed Southern North Sea and Eastern Channel Mixed Flatfish Fisheries Management Plan (FMP)

ClientEarth argues that the proposed FMP for mixed flatfish in the Southern North Sea and Eastern Channel lacks binding commitments and fails to adhere to the precautionary and ecosystem-based objectives of the Fisheries Act 2020. The submission specifically calls for fishing limits to be set below Maximum Sustainable Yield (MSY) to build climate resilience, the recovery of the depleted witch stock, and the implementation of firm Minimum Conservation Reference Sizes (MCRS) and towed gear measures.

• ClientEarth contends that the FMP's objectives and actions are often too vague, non-binding, or scheduled over excessively long timeframes to effectively achieve the goals of the Fisheries Act 2020.
• The submission argues that aiming for exploitation 'at MSY' is insufficient to meet the precautionary objective of the Fisheries Act 2020, which requires maintaining populations 'above' biomass levels capable of producing maximum sustainable yield.
• To address climate change and ecological uncertainty, ClientEarth recommends setting ecosystem-based fishing limits below single-stock scientific advice, suggesting a biomass target of at least 120% of that which achieves MSY.
• The document identifies a management failure regarding the witch stock, noting that catches have routinely exceeded ICES single-stock advice every year since 2014 and that the stock remains outside safe biological limits.
• ClientEarth criticizes the UK government's stated position that there is no need to take a precautionary approach to managing flounder, asserting that the Fisheries Act 2020 legally mandates a precautionary approach when MSY assessments are insufficient.
• The submission calls for firm commitments to Minimum Conservation Reference Sizes (MCRS) for lemon sole, turbot, and brill, and concrete requirements for towed gear management, rather than the current non-committal language of 'exploring' options.

APA

ClientEarth (2023). Defra’s consultation on the proposed Southern North Sea and Eastern Channel Mixed Flatfish Fisheries Management Plan (FMP). https://www.clientearth.org/media/rxqgasoa/defra-fmp-consultation-response-september-2023-updated.pdf

Chicago

ClientEarth. Defra’s consultation on the proposed Southern North Sea and Eastern Channel Mixed Flatfish Fisheries Management Plan (FMP). 2023. https://www.clientearth.org/media/rxqgasoa/defra-fmp-consultation-response-september-2023-updated.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Defra’s consultation on the proposed Southern North Sea and Eastern Channel Mixed Flatfish Fisheries Management Plan (FMP) |date=September 2023 |url=https://www.clientearth.org/media/rxqgasoa/defra-fmp-consultation-response-september-2023-updated.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2023defras, author = {{ClientEarth}}, title = {{Defra’s consultation on the proposed Southern North Sea and Eastern Channel Mixed Flatfish Fisheries Management Plan (FMP)}}, publisher = {ClientEarth}, year = {2023}, month = sep, url = {https://www.clientearth.org/media/rxqgasoa/defra-fmp-consultation-response-september-2023-updated.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }