This is Greenpeace UK’s response to the MMO MPA Fisheries Management Stage 3 Consultation
We have chosen to comment on the overall process, rather than the four individual byelaws.
This consultation response expresses the views on ocean protection of hundreds of thousands of Greenpeace supporters, including over 13,000 who wrote to us directly with their thoughts and concerns on these specific byelaws.
While we support the introduction of all the fishing restrictions that are proposed in these byelaws, we consider the pace and scale of their introduction to be lamentably slow, and strongly criticise the decision to take a partial-site approach for some of the MPAs.
This is yet another missed opportunity for the UK to introduce genuinely world leading domestic ocean protection which would support the delivery of 30×30 in UK waters and help to drive global 30×30 efforts on the High Seas.
With the news of the 7th planetary boundary on acidification being breached this week, the scale of the crisis on our oceans is put into even sharper focus, and the level of ambition from government must reflect this.
The appropriate response is to protect offshore MPAs site-wide from destructive, industrial fishing of all types, using the power enshrined in the Fisheries Act. Anything less will continue to fall short, for marine life and vulnerable habitats, for low impact fishers and fishing communities, and for the wider UK public.
Do you have any additional information about the location, condition, or sensitivity of the designated features?
The sensitivity of the features in question to bottom-towed gear is not in doubt. The government’s own advisors have repeatedly confirmed the extreme vulnerability of these habitats. The JNCC and Natural England’s work on the impacts of different fishing pressures has identified that activities causing physical disturbance and abrasion, such as bottom trawling, have a high-impact risk on sensitive benthic habitats. Dragging heavy gear across the seafloor is fundamentally incompatible with the MPAs’ conservation objectives to ‘maintain’ or ‘recover’ these features.
The stage 3 site assessments carried out by the MMO make plain that comprehensive, long-term monitoring data for these sites is often unavailable. As a result, the government is obligated to act. The UK’s Marine Strategy Regulations 2010 commit the UK to applying the precautionary principle when there is a risk of harm to the marine environment. The acknowledged sensitivity of designated features, from sandbanks to deep-sea reefs, to the pressures of bottom trawling, means any uncertainty about the exact level of damage should trigger protective action, not delay it.
There are additional concerns about the sensitivity of the large quantities of carbon stored in the seafloor sediments to being disturbed by bottom-towed gear. The seabed sediments within UK waters are a nationally significant carbon store, holding an estimated 524 million tonnes of carbon. Bottom trawling physically disturbs these sediments, re-suspending the carbon into the water column where it can be remineralised, contributing to ocean acidification and potentially being released into the atmosphere.
Protecting these MPAs from bottom trawling is a vital climate change mitigation action that also delivers on nature recovery goals.
Do you have information on the type, location, frequency, or intensity of fishing activity within the MPAs?
The primary threat these byelaws seek to address is intense and persistent bottom-towed fishing. This activity is not occasional but a widespread industrial practice; analysis showed that in 2019, destructive bottom trawling took place in 71 offshore MPAs. This has been backed up by Greenpeace’s own at-sea observations in the North Sea and English Channel in the years since, where we have repeatedly encountered bottom trawlers actively fishing within MPAs that are completely lacking the management measures needed to provide actual protection.
The need for the byelaws set out in the stage 3 consultations is urgent because the damage is not historic; it is ongoing. An update of the 2019 investigation by Oceana using Global Fishing Watch data revealed that UK offshore Marine Protected Areas were subjected to over 20,000 hours of suspected bottom trawling in 2024 alone. This continued pressure makes any natural recovery impossible and actively worsens the condition of the very features the MPAs were designated to protect. With every month that passes without these byelaws in place, the damage increases and a restored ecosystem becomes harder to achieve.
While the ban on bottom trawling being proposed in these byelaws is a critical next step, it continues to fall well short of comprehensive protection.
The seabed and the column are tightly connected, and their conservation cannot be considered in isolation. Just because a gear doesn’t directly contact the seabed, doesn’t mean that it won’t have a strong negative impact on benthic habitats. Industrial pelagic supertrawlers currently operate legally within these same MPAs, and they will be able to continue after these byelaws are introduced. Supertrawlers remove vast quantities of fish and disrupt the entire food web. A Greenpeace investigation from earlier this year showed these vessels spent an average of 7,380 hours per year fishing in UK MPAs since Brexit. A protected seabed is meaningless if the waters above it are stripped of life.
The ongoing fishing of both bottom trawlers and other industrial fleets inside MPAs demonstrates that the current piecemeal approach to marine protection is failing. Banning one gear type while allowing another to continue its destructive impact means these areas cannot be considered ‘fully’ or ‘highly’ protected. Incredibly, less than 0.1% of the UK’s seas are fully or highly protected. Achieving the UK’s 30×30 target, which it is committed to as a signatory to the Kunming-Montreal Global Biodiversity Framework, requires a holistic approach that eliminates all forms of destructive industrial fishing from the entire MPA network.
Do you agree or disagree with the proposed management measures? Do you have any suggestions for other management measures?
We strongly agree with all the proposals to prohibit bottom-towed fishing gear, static gear, traps and the removal of spiny lobster. For these measures to maximise their ecological value, they should apply to the entirety of each MPA.
This whole-site approach is the best way to guarantee protection for the designated features and the surrounding ecosystem, while also providing the clarity and simplicity needed for effective enforcement and compliance. Proposing zoned management or partial closures is an unacceptable compromise that is not supported by science.
A global analysis published in the journal Science found that while fully protected MPAs successfully increase biodiversity and fish biomass, “partially protected areas act as red herrings in marine conservation… [providing] little or no social or ecological gain over open areas”. Such proposals risk merely displacing and concentrating fishing effort into smaller areas within the MPA, leading to rapid, intensified degradation.
The process of introducing byelaws is unnecessarily slow and cumbersome and it lacks ambition. The government first announced the four stages of consultation on English offshore MPAs in 2020, with a goal of concluding by the end of 2024. We are now in late 2025 and it isn’t clear when stage 4 will be conducted. This approach is much too slow in the face of the biodiversity and climate crises.
The government has had the power to act since the start of 2021 via the Fisheries Act 2020, which allows for the restriction of fishing licences to prevent access of fishing vessels to specific areas.
This faster, more agile mechanism should be used immediately to prohibit all destructive fishing gears, including supertrawlers, from the entire MPA network, rather than relying on a multi-year, site-by-site byelaw process. An effective management regime must address all pressures that impact an MPA’s ecosystem. The current proposals only address bottom trawling. To deliver genuine protection and contribute meaningfully to ocean recovery, the government must follow these byelaws with further action to exclude other damaging industrial activities, most notably supertrawlers, from all MPAs. Finally, at least 30% of the UK’s waters need to be designated as fully protected MPAs, which are widely acknowledged as the most effective form of marine protection.
How would the proposed management measures affect you? Or those you represent?
For Greenpeace and hundreds of thousands of our supporters, who represent a broad public desire for healthy oceans, these measures are a welcome, if profoundly delayed, next step. The UK has for years designated MPAs that lacked any meaningful management, creating a network of ‘paper parks’. Enacting these byelaws in part begins to rectify this failure, but the years of inaction and lack of ambition have allowed for continued, avoidable degradation of our most precious marine sites.
Such is the level of inaction and lack of ambition by the government that Greenpeace has been compelled to take direct action multiple times to protect MPAs. First in the Dogger Bank MPA in the North Sea in 2020, then Offshore Brighton MPA in 2021, and finally the South West Deeps (East) MPA in the English Channel in 2022.
These peaceful protest activities helped to kickstart this very byelaws process and have mobilised a movement of over 800,000 members of the UK public to call on the government to ban supertrawlers and other destructive, industrial fishing from the UKs offshore MPAs.
The extremely slow pace of the offshore MPA byelaw process has delayed the UK public from receiving benefits of a healthy marine ecosystem. As the Chair of the Environmental Audit Committee warned, “every further day of delay risks further destruction of our seabed“. The current pace of protection – a handful of sites at a time over many years – means many crucial areas remain unprotected from many types of destructive industrial fishing, undermining the resilience of the network as a whole. Moving forward, the government must adopt a default position of whole-site protection for all MPAs from all destructive industrial activities. This would align the UK’s actions with the scale of the nature and climate crises, bringing the benefits of a thriving marine ecosystem to all of the UK’s communities.
UK public support for stronger protection
Greenpeace UK launched a survey to supporters to bring the voices of those we represent into this submission. Over 13,000 Greenpeace supporters responded.
99% of respondents do not think any industrial fishing should be allowed in MPAs, and think that stronger ocean protection is necessary to improve their life and the lives of future generations.
7,227 supporters responded to the question ‘Are there parts of the English coast or sea that you feel a personal connection to or want to protect? Please tell us where and why.’
3,708 responded that they want all of the English coastline and sea to be protected.
“All of our coast and marine life is precious & needs extra protection”
“ALL coastal areas around the UK are beloved by me. The Atlantic ocean, English Channel and the North sea are all connected and swirl around the whole of the UK. I live on the far north coast in Scotland and any exploitation of the UK’s waters affects marine life everywhere. I want to continue enjoying healthy marine creatures and habitats everywhere in this country. And when I’m gone, I want the same privilege for my children and future generations. Marine protection areas should be a haven, not a convenient place for industrial fishing.”
In addition, those with connections to areas of the coastline and sea shared personal stories and experiences.
“I live in Hastings where we have the UK’s only beach fishing fleet. There are generations of fishermen here who abide to very strict rules about where they can fish and how much they can fish. Industrial fishing and different EU rules have almost put our fishermen out of business and ruined their livelihoods. I care passionately about the English coastline and protecting the livelihoods of the locals who live and work here.”
“North East coast, as I was brought up in Newcastle, The Farne Islands and Northumberland coast. The Cornish, Devon and Dorset coast as holiday there. But all areas of the English coast are important – I think Industrial fishing should be banned as it is so destructive to marine habitats and devastating to fish populations.”
“I spent my childhood in Hartlepool on the north east coast of England. We spent many hours not only on a beautiful sandy beach at Seaton Carew, but also walking the coastal paths in County Durham and North Yorkshire. Hartlepool had a fishing fleet and bought wonderful fresh fish in local shops. It is heartbreaking that so much of this has gone, and industrial fishing is partly to blame.”
“West Cornwall. I grew up here and discovered the joys of watching birds and other wildlife in the late 1960s. It was rich in life and has become depleted by overfishing.”
“South coast where I lived for 10 years. Welsh coasts where I climb and walk, same with Cornwall and Devon. Scottish coasts where I recently saw puffins and dolphins. The UK has a fantasticly varied coastline, beautiful and unique, it needs valuing and protecting. Millions of people love going to the seaside in all its forms and it is an essential part of British maritime heritage. Our sea birds and marine wildlife deserve our protection, not just being seen as an economic resource.”
“Sussex coast. Bognor Regis. There is a trawler ban in this area, particularly aimed at stopping the destruction of the sea bed. Over the last four years or so there has been a recovery and many species of fish, kelp, oysters etc have returned. The ban is working and improving the environment for sea life, the ocean and for humans.”
“The Yorkshire coast, from Whitby down to Bridlington, has long been a holiday destination for our family, be it day trips or weeks away. Where my Dad could marvel in and support these local communities when he was a boy, my son only gets to witness a coastal area in decline and a sea he can’t paddle in. It would benefit the local and UK economy to see these coastal towns invested in and protected.”
“Sussex coast where I live has seen significant damage to the seabed and some areas are only just recovering. Whilst many fishermen on a small to medium scale depend on making their living along this coast, I believe it would benefit from restrictions on large vessels and those that destroy the seabed. A reserve that covers the more endangered parts of this coast would be of great benefit.”
“I live on the North Sea coast and have seen a decimation of marine life. Any industrial fishing upsets the delicate balance of life in our waters.”
Respondents also emphasised that the purpose of Marine Protected Areas should be protection, and highlighted the destructive nature of industrial fishing
“The sea is important to so many people in so many different ways. Scouring it in an industrial way is not going to help the ecosystems which make coastal regions so iconic.”
“No. I want to protect all of it, but especially those areas designated as Marine Protected. How can they allow industrial trawling when that is supposed to be what they are protected from?”
“Marine Protected Areas where fishing is not permitted have been shown to increase the amount of sea life both within and outside their boundaries, this helps to create sustainable fisheries outside of the MPAs. Therefore it is important that industrial fishing is not allowed in MPAs. We should also pay attention to preserving sea grass meadows which act as spawning grounds for fish and absorb carbon dioxide.”
“The already accepted 178 Marine Protection Areas in which all bottom trawling and industrial fishing should be banned, and the further MPAs proposed by the Joint Nature Conservation Committee over 10 years ago. And in particular, the waters around Lundy, and our preferably inshore fisheries off Devon and Cornwall which should be restricted to small boats and recreational fishers.”
“The whole of our coast requires active protection to allow marine life the capacity to breed & thereby maintain populations at a sustainable level. There needs to be enforcement & monitoring of fishing fleets, both foreign and domestic, to allow Marine Protected Areas to fulfill their original intent.”
Many respondents reflected tension between local fishing livelihoods and large-scale/industrial fishing practices.
“Massive supertrawlers drag nets hundreds of meters long, indiscriminately scooping up everything in their path—including delicate species like seahorses, basking sharks, and spider crabs. These practices devastate seabed habitats and disrupt food chains, harming not only wildlife but also local fishing communities. Living in Cornwall, I understand that fishing at a sustainable scale provides food now and for the future. Industrial fishing (specifically super trawlers) undermine biodiversity, erodes sustainable livelihoods, and risks turning vibrant marine habitats into ecological dead zones. Coastal communities have a strong connection to the sea for health, recreational and livelihoods. Industrial practices can destroy all that, impacting humans as well as marine diversity and healthy waters.”
“South coast of Devon and Cornwall, having lived in the area for 45 years, small local fishermen deserve to maintain their livelihood and heritage, and the seabed and sea life it supports needs to be protected.”
“I grew up in Mousehole and Newlyn in Cornwall so I am passionate both about the Cornish coast, and about sustainable fisheries that can support livelihoods.”
“The north Norfolk coast is my home. Rare corals are found there. Crabs are fished for sustainably and this area needs protection, both for the environment and the livelihoods of the crab fishermen.”
“All of it. It’s fundamentally connected to our health and national livelihood”
What impacts, if any, do you anticipate the proposed management measures will have on UK fishing vessels, operators, or supply chains?
There is overwhelming evidence of the positive long-term impacts of effective marine protection on biodiversity, fishers and wider coastal communities.
International scientific evidence is clear: a comprehensive 2024 review in Scientia Marina found no documented cases of MPAs creating a net economic cost to fisheries. The paper looked at MPAs that have meaningful fisheries management measures, not paper parks, and over 90% of the MPAs provided benefits to adjacent fisheries, including increased fish stocks, higher catch volumes, larger fish and lobsters, and enhanced larval export. This is reinforced by the government’s own assessment, which projects that the monetised benefit of these byelaws to UK society will be £3.1 billion over twenty years through the restoration of ecosystem services.
The MMO’s own economic assessment concludes that the cost to business is low. The total estimated cost to the UK fishing industry is an equivalent annual net cost of just £530,000. This figure is likely a “significant overestimate”, as the MMO states it does not account for fishers offsetting losses by fishing elsewhere. This minimal investment is insignificant compared to the total £978 million landed value of fish caught by UK vessels in UK waters in 2022, and pales in comparison to the long-term benefits of stock recovery and the potential for increased and more stable catches.
While the overall economic impact is minimal, the MMO analysis shows that impacts could be concentrated in a few ports, with Devon and Cornwall accounting for 50% of the total predicted revenue lost. Some of these ports, such as Brixham, Hartlepool, and Newlyn, are located in some of the most deprived neighbourhoods in the country. This highlights the need for a just transition, where the government provides targeted financial support and investment for affected fishers and communities to adapt and diversify away from destructive gear and unsustainably fished species. It should still be anticipated that the proposed byelaws will have a net positive impact on fishers operating out of those ports.The MMO assessment confirms that over 99% of businesses in the UK fishing industry are small or micro-businesses. Banning industrial gear like bottom trawls creates exclusive access and a healthier resource base for these low-impact fishers, who are often the lifeblood of coastal communities.
Well-designed MPAs provide sustainable benefits for fishing communities, helping to revitalise local, sustainable fishing economies.
What impacts, if any, do you anticipate the proposed management measures will have on non-UK fishing vessels, operators, or supply chains (including those from the EU)?
These byelaws must, and will, apply to any vessel operating in UK waters, regardless of its flag. This is a core principle of non-discriminatory resource management. The MMO’s assessment shows significant fishing activity from non-UK vessels in the management areas, so robust and equal enforcement is essential for the measures to be effective and to ensure a level playing field for the domestic fleet.
Fish populations are a shared resource that do not recognise national borders. The positive impacts of MPAs, such as the spillover of adult fish and the export of larvae, are universal principles that will not be confined to UK waters. Non-UK fleets operating in adjacent areas of the North Sea and other regional seas will also benefit from the increased abundance and resilience of fish populations that these scientifically documented effects will bring, contributing to the health and productivity of the entire region.
By properly protecting these MPAs, the UK demonstrates its commitment to international conservation targets like 30×30 under the Global Biodiversity Framework. This sets a positive precedent and encourages reciprocal action from neighbouring states, including EU members. A healthier marine environment in UK waters contributes to the overall ecological health of the Northeast Atlantic, which is a shared resource and a shared responsibility. The MMO estimates an average annual landings value of £15.7 million derived from these areas by EU vessels, a tiny fraction of the roughly £500 million that the EU catches in total in UK waters. It is critical to note two things. First, the MMO states this is a “considerably overestimated” figure of the true economic impact, as it is based on landings revenue, not profit, and does not account for fishers offsetting this by fishing elsewhere. Second, the comprehensive Costello (2024) review found “no evidence of net costs of MPAs to fisheries anywhere”. Therefore, any initial reduction in gross revenue for non-UK fleets is likely to be offset by the long-term benefits of healthier, more resilient, and more productive shared fish stocks.
What other impacts could the proposed management measures have? For example, on fishers, the wider fishing community, coastal communities, employment, upstream and downstream supply chains, people with protected characteristics under the Equality Act 2010, fish stocks, the marine environment.
The most significant social impact is the potential to restore public faith in the concept of marine protection.
For years, the public has been told that vast areas of our seas are protected, while destructive activities continue unabated. Polling has repeatedly shown the high level of public support for properly protecting MPAs and how surprised people are to learn that protection is currently inadequate. Making protection real would finally align government action with public expectation and demonstrate a genuine commitment to ocean recovery. This would also strengthen the government’s credibility in international nature and oceans forums.
The proposed byelaws will be able to make a positive impact on the UK’s climate goals. Protecting the seabed in these MPAs prevents the disturbance of vital blue carbon stores. A 2024 study estimated that globally, bottom trawling could have released 8.5-9.2 billion tonnes of CO2 into the atmosphere over the 25 years between 1996 and 2020, or 370 million tonnes a year.
The ultimate environmental impact will be the recovery of fish populations and the restoration of complex marine ecosystems.
By protecting critical habitats, including spawning and nursery grounds for commercially important species in the North Sea, these measures will help rebuild populations that have been overfished for decades. This enhances the resilience of the marine environment to other pressures like climate change and creates a more secure resource base for the entire fishing community for generations to come. Coastal communities will also experience benefits far beyond fishing. A healthier marine environment will support a thriving blue economy, including tourism, recreation, and education. International evidence shows that individual MPAs can generate millions of pounds annually in tourism revenue and create jobs and prosperity.