Marine resources – remote electronic monitoring: consultation analysis

10. REM system specification for scallop dredge vessels (Q11-12)

10.1. The consultation paper also discussed the REM requirements set out in Article 6 of the 2017 Order, which the Scottish Government considered have proven an effective tool for monitoring the scallop vessels within scope of the provision.

10.2. The current REM requirements include winch sensors and at least 2 digital cameras. Sensors are mounted on the vessel to capture location and activity data. GPS and other data such as speed, direction and winch movement detection are provided to ascertain vessel location and what fishing activities the vessel is engaged in at that location. The two cameras are positioned to monitor all fishing activity on location.

10.3. The Scottish Government proposed that these established REM provisions would be replicated in the new legislative instrument (but their application would be widened to ensure that all vessels carrying and/or deploying scallop dredge gear in the Scottish zone have a fully operational REM system installed on-board that meets the standards required).

10.4. At present, the legislation specifies video imagery of 1080 pixels per frame, though this does not allow for continuous video streaming and only still images, making analysis difficult. Thus, the consultation paper sought views on a new requirement that the REM system must have the ability to record footage to a minimum of 5 Frames Per Second (FPS).

Q11. Alignment with existing REM requirements

Q11: Do you agree that REM requirements on vessels carrying and/or deploying scallop dredge gear in the Scottish zone should be broadly aligned to existing REM requirements provided for in Regulation 6 of the 2017 Order?

10.5. Question 11 received 32 total responses - 25 from organisations and 7 from individuals. 30 closed responses were collected, wherein the vast majority (80%) of respondents agreed that REM requirements on vessels carrying and/or deploying scallop dredge gear in the Scottish zone should be broadly aligned to existing REM requirements provided for in Regulation 6 of the 2017 Order.

10.6. Organisation respondents were more likely to agree (86%) that the REM requirements should be broadly aligned to existing REM requirements than individual respondents (67%). All of the fishing organisations who responded to this question agreed that the requirements should be broadly aligned to the 2017 Order.

Alignment with requirements

10.7. Many of those who agreed with the requirements commented on their familiarity with the 2017 Order and the usefulness of aligning further REM requirements with those provided for in Regulation 6.

10.8. However, other respondents felt that the requirements need to be expanded, with special consideration needed around the use of additional equipment or other features. As seen in response to other questions in the consultation, there were repeated suggestions that REM requirements ought to employ more cameras; in this case, it was felt that more cameras should be used to allow catch data, ETP (Endangered, Threatened and Protected) interactions, safety and crew welfare, and discard opportunities to be monitored.

10.9. Others recommended that work first be done to strengthen intentions and research plans for catch composition and asked whether the requirements would cover bycatch, which was noted as an issue in the parallel FCP consultation.

10.10. One respondent stated that answers given depend on the interpretation of 'broadly aligned.' A few of those agreed with the requirements did so on the basis that at least four cameras, which can record video imagery of at least 5 Frames Per Second (FPS) at a resolution of 1080 pixels per frame with 5-15 FPS where needed, are utilised in practice. GPS data and other data on speed and direction was also considered important in order to better enable responsible operators to demonstrate legal practice.

10.11. A few respondents felt that an assessment of the effectiveness of existing REM technology requirements (given the recent voluntary rollout of REM use on scallop dredge vessels in Scotland) would be useful, so that any learnings from this rollout could be accounted for in any new REM requirements.

Dissatisfaction with proposal

10.12. Some respondents were dissatisfied with the proposal where they felt that REM requirements on vessels carrying and/or deploying scallop dredge gear in the Scottish zone were poorly thought out and failed to reflect the reality of challenges with technology, data coverage, and general conditions at sea.

Wider points

10.13. Again, the adoption of a level playing field approach to all vessels was a recurring feature in responses.

Q12. Changes to REM system specification

Q12: Do you consider that any other changes (in addition to the ability to record footage to a minimum of 5 Frames per Second) should be made to the REM system specification?

10.14. Question 12 received 31 total responses - 23 from organisations and 8 from individuals. 28 closed responses were collected, wherein most (71%) respondents considered there to be changes which should be made to the REM system specification (in addition to the ability to record footage to a minimum of 5 Frames per Second).

10.15. There was some level of overlap between Questions 11 and 12 where respondents began offering notes and suggestions alongside their dis/agreement with the proposal.

Benefits of proposed changes

10.16. Several respondents, though not replying directly to the question, felt positively about the potential for changes to the REM system specification (including the ability to record footage to a minimum of 5 Frames Per Second) to improve the quality, and speed up the analysis of data – particularly where this can be accommodated by cameras already installed. In addition, the higher accuracy in terms of times for shooting and hauling was deemed a benefit of the proposed system.

Changes to proposed specification

10.17. A need to specify a minimum optical resolution per area being observed, as well as an onus to engage in detailed discussions on system specification with industrybefore postulating what the performance should be, were also mentioned by respondents, some of whom noted a lack of available detail as to what is required. One respondent raised a question around inconsistencies in system recording and their possible implications on prosecutions:

"Would Marine Scotland be able to prosecute vessels because the time of shooting on the REM system does not match the e-log? As mentioned before, the e-log system in inherently poor" [Organisation, Fishing Organisation]

10.18. Respondents tended to offer practical ideas around REM system technicalities, including provision to enable vessels to view the images and data captured (in 'read only' form) to verify that they are sufficient quality for their intended purpose and that the system is working. The potential for unfair prosecutions were again of note, as one individual expressed:

"through no fault of the vessel, a lens could be dirty or obscured, a light could be out, a camera could have moved, a cable broken and so on. Potentially prosecuting a skipper when they had no means of knowing that they were non-compliant is unfair" [Individual]

10.19. Points around data transfer efficiency and numbers of operational cameras were also raised, particularly where the fastest possible data transfer rates and multiple I/O [Input/Output] Ports were considered vital in allowing more than one card (or disk) to be downloaded at once by those reading and archiving the data on land. Others recommended that higher frame rates, such as 24 Frames Per Second, may assist with machine learning for identification of bycatch species. The same respondent went further in highlighting that setting the colour space on cameras and having durable colour reference charts installed on vessels would aid species identification.

10.20. There was broad consensus that the REM system should be fit for purpose – to ensure compliance with the landings obligation and observe bycatch of both quota and non-quota species, for example. However, they recognised that more work must be undertaken to determine the increased cost of the necessary technology and ensure that the appropriate financial support is available to enable its introduction, with one respondent proposing that the system be trialled prior to a large-scale rolling-out:

"Trial it in areas where mobile coverage is standard at 1mbps and ensure the system works in these conditions before rolling out" [Individual]

10.21. In line with this, a few respondents mentioned that any additional changes to specifications should be a matter of further consultation, so as to maintain confidence in REM systems. It was also suggested that REM system specification be expanded to assist with scientific monitoring, in line with fisheries dependent data collection requirements from Marine Scotland Science.