Oceana UK                            GME0060

Additional written evidence submitted by Oceana UK for the EAC Committee inquiry: Governing the Marine Environment

Dear Committee,

We are writing to provide additional information to the Committee following comments made by the National Federation of Fishermen's Organisation (NFFO) during the latest evidence session on Wednesday 5th March. The comments included misleading claims about industrial fisheries and impact of bottom towed gear. We feel obliged to respond to these claims to provide a truer picture of the impact of destructive bottom trawling.

Taking the claims from the NFFO representative in turn:

“Most (fisheries) activities don’t have any negative conservation impacts... Commercial fishing is well over 1000 years old as an industry. We're still doing it in places we've been doing it in for generations.”

Academic analysis of historic catch data dating back to 1889 has found a staggering decline in fish populations and ecosystem damage due to intense commercial fishing. Researchers assessed annual demersal fish landings from bottom trawl catches landing in England and Wales and corrected the figures for increases in fishing power over time as well as a recent shift in the proportion of fish landed abroad. Their estimate of the change in landings per unit of fishing power (LPUP), a measure of the commercial productivity of fisheries, found this had reduced by 94% - 17-fold - over the past 118 years. The researchers concluded that this implies an “extraordinary decline” in the availability of bottom-living fish and a profound reorganisation of seabed ecosystems since the nineteenth century industrialisation of fishing.[1]

This helps to explain Oceana’s findings in 2023 that over a third of 104 stocks in UK waters were being overfished, and a quarter had been depleted to critically low population sizes. Of the ‘top ten’ stocks on which the UK fishing industry relies, half are overfished or their population size is critically low.[2] The consistent decision by UK and European governments to agree catch quotas above the scientific advice further perpetuates this damage.

Most of this damage is not a result of smaller, low-impact vessels, who continue to struggle to survive. It is the result of a small number large-scale, industrial vessels. In 2024, Oceana found using Global Fishing Watch data that over 100,000 hours of apparent industrial fishing activity took place within the UK’s 63 offshore benthic MPAs in 2023 alone, primarily from a relatively small number of large industrial trawling vessels.[3] These marine protected areas (MPAs) are designated specifically for the importance of their seabed features, ranging from rare reef formations to ocean quahog clams which can live for hundreds of years.[4] Equivalent research on the damage from pelagic “supertrawlers” has recently been released by Greenpeace.[5]

“Most bottom trawling activity doesn’t do to the seabed what most people think... Trawl gear is designed to skim the seabed as lightly as possible, not dig into it... They're going to places where consistently there's a healthy crop of scallops or flatfish and they're still there after generations in the same place.… A single winter storm will do more than every single trawler in the country could do to the seabed”.

The impacts of bottom-towed fishing gear on seabed ecosystems, storage of blue carbon and  livelihoods of other lower-impact fishing sectors, have been extensively documented and are clear to see. A full review can be found, for example, in Chapter 5 of the report “The Trawl Supremacy”.[6] This includes direct damage to seabed habitats, from deep sea corals to sands and seagrass meadows, bycatch and removal of non-target species such as sharks and cetaceans, changes to ecosystem functioning and disturbance of seabed carbon.

Scallop dredging is a particularly insidious form of fishing – the damage to previously flourishing marine sites is clear in before and after photos (left - images from the Transform Bottom Trawling Coalition).

The Marine Management Organisation (MMO) was clear when it restricted bottom trawling across the Dogger Bank Special Area of Conservation in 2021 that this was an activity causing significant damage to the marine environment: “The MMO assessment of fishing impacts at this site concluded that bottom towed fishing (including semi-pelagic trawling and demersal seining) is not compatible with the conservation objectives of the site and may result in an adverse effect on site integrity.”[7] A ban has since been successfully implemented across the site.

This assessment has been emphasised by a group of 20 leading marine scientists who have recently penned a letter to the Environment Secretary warning that “These fishing practices are simply not compatible with meaningful marine protection: they are extremely intensive and unselective, involving the dragging of heavy nets across the seabed, which scoop up almost all life in their path. Just a single brief pass of bottom-contact fishing gear has been shown to reduce species richness of seabed invertebrates by 19% and diversity by 26%, while recovery would take many years.” We have provided a copy of the letter to the Committee.

“(Farmers) don’t plough at random...they go where they know the crop is and they harvest it... So trawlers go to where they know, year after year, in some cases decade after decade... They aren't roving wildly across the seabed. They're going to places where consistently there's a healthy crop”.

Finally, we dispute the comments that dredging and trawling are comparable to ploughing a field, which is both false and disingenuous.

We remind the committee that:

-          Intensive agriculture, including repeated disturbance of soils by ploughing, is the single largest direct cause of terrestrial biodiversity decline, as shown by repeated State of Nature reports.[8] The losses of farmland birds with the rise of such agriculture is greater than any other class of bird[9], in what is already one of the most nature depleted countries on earth.

-          Intensive agriculture depends on the supply of inputs of fertilisers and pesticides to maintain output over an area the farmer controls. Bottom trawling, and indeed commercial fishing in general, operates by catching wild populations of fish across locations, with no direct implications for trawlers on future seabed damage as a farmer would have to deal with.

-          The majority of intensive agriculture does not take place in terrestrial protected areas, particularly Sites of Special Scientific Interest or Local Nature Reserves. The more appropriate analogy is that bottom trawling inside MPAs is the equivalent of bulldozing the treasured protected forests, wetlands or wildflower meadows that have been saved from the damage of decades of intensive farming.

Indeed, evidence shows that bottom trawling is actively targeting marine protected areas and other areas of high biodiversity importance. It has been shown that in some cases, the average intensity of trawling within MPAs is 1.4 times that of unprotected areas. Without effective management, these areas will continue to be targets for destructive fishing, especially if this fishing is displaced towards MPAs as a result of other activities.[10]

Finally, we wish to emphasise that as Oceana fights for UK seas to get the protections they deserve, we also support resilient and regenerative fisheries that operate within a recovered marine environment. Our Mission Regeneration report[11] provides our vision and roadmap for managing fisheries to reward those that fish in harmony with nature, while holding those destructive parts of the sector to account. This includes supporting a fair transition away from the most damaging forms of fishing to support a ban in bottom trawling within marine protected areas (MPAs). We need to fish less, and fish better.

ENDS

Should you have any questions, please contact Alec Taylor, Director of Policy and Research

March 2025