Marine resources – remote electronic monitoring: consultation analysis

9. REM for scallop dredge vessels (Q10)

9.1. The consultation paper discussed the Scottish Government's intention to make it a mandatory requirement for all scallop dredge vessels active in Scottish waters to have a fully operational REM system on-board. The consultation explained that the proposed new legislative instrument would be focussed on REM systems being fully operational on vessels carrying and/or deploying scallop dredge gear in the Scottish zone, and therefore needed to be considered alongside the current provisions (relating to gear restrictions) in the Regulation of Scallop Fishing (Scotland) Order 2017^[4](the 2017 Order), including:

• Restrictions on number of scallop dredges for king scallops (Articles 4 and 5 of 2017 Order).
• REM requirements (Article 6 of the 2017 Order)

Q10. Application of REM to scallop dredge vessels

Q10: Are you aware of any issues we need to take account of when we apply REM requirements consistently across all scallop dredge vessels in the Scottish zone, regardless of scallop species being targeted or number of dredges being deployed?

9.2. Question 10 received 38 total responses - 28 from organisations and 10 from individuals. 34 closed responses were collected, wherein 53% of respondents agreed that they were aware of issues to be mindful of when applying REM requirements consistently across all scallop dredge vessels in the Scottish zone, regardless of scallop species being targeted or number of dredges being deployed.

9.3. There was some support for installing REM across all scallop dredge vessels where this provides accurate mapping of where commercial scallop dredging is taking place, with some respondents noting that REM will provide more accurate information than previous 'flawed' systems, such as VMS. Some respondents thought the improved spatial data from REM could be used to refine the existing boundaries of protected areas.

9.4. A few respondents stated a need for incentives – and a fairness in how these are distributed. One noted a current incentive for REM fittings on vessels able to fit 10 dredges per side, highlighting that it would be unfair to require smaller vessels, which cannot fit any more dredges per side, to install REM without also providing them with an incentive.

9.5. Effective data monitoring and data sharing between jurisdictions was also deemed critical. Given that REM systems are remotely monitored, respondents felt it essential that all nations and administrations with fishing vessels in Scottish waters ensure their monitoring of REM systems and enforcement is consistent with that in Scotland. There were further recommendations that vessels should not leave ports without confirming that cameras and sensors are operative, to prevent misuse, as some highlighted that:

"the presence of an REM system on the vessel is no guarantee the system is being used appropriately or adequately monitored" [Organisation, Conservation]

9.6. Several respondents described a lack of consideration for bycatch in scallop dredging, indicating that the system should also be able to monitor and quantify flatfish bycatch associated with the fishing method, which was considered economically valuable.

9.7. Many participants emphasised the need to consider practicalities around data use and installation, whilst others noted that privacy concerns have been raised by some smaller scallop boats where their small size and confined conditions mean there is limited space onboard for filming. Similarly, there were questions as to whether it would be reasonable to impose the cost and responsibility of the continuous operation of REM on to small businesses, as well as concerns around adequate lighting for video-recording at night and sufficient data coverage for the transmission of data. Again, respondents pointed out that procedures for the failure of REM equipment on voyages, including those undertaken by scallop dredge vessels, should be clear and noted that an immediate return to port, if necessary, would be particularly difficult for larger offshore nomadic vessels.

9.8. The importance of using REM was further qualified by the suggestion that dredgers ought to be able to have access to their own data to defend any allegations against them, such as those around dredging through static gear or breaking access rules. Some respondents put forward that more than two cameras were required to monitor bycatch, as:

"all they can do is report fishing effort (time in and out of water), estimate beam length and count dredges, so no cameras are available to monitor catches or discards" [Individual]

9.9. More broadly, others used this response box to reaffirm their broad support or opposition to REM, as well as calls for an effective, non-discriminatory 'level playing field' whereby the entire scallop dredge fishing fleet operating in Scottish waters should be required to have REM.