Marine resources – remote electronic monitoring: consultation analysis

11. REM for large demersal vessels (Q13)

Q13: What is your view in relation to the various options outlined for deployment of REM to parts of the demersal fleet as outlined in Section 5: REM for large demersal vessels?

11.1. The consultation also sought views on deployment of REM to parts of the fishing fleet beyond the pelagic and scallop vessels. Specifically, for large demersal vessels.

11.2. One option set out in the consultation was the use of a reference fleet. The consultation explained that this would likely involve placing an REM system on a limited and defined number of Scottish vessels to provide reference data for both compliance and science purposes. The data collected from the reference fleet could be used to provide a benchmark for compliance with rules and regulations, though the reference fleet would have to be representative of the full fleet in order to do this. Data for REM equipped vessels in the reference fleet could then be compared to non-REM vessels.

11.3. It was noted that this option would likely only apply to Scottish vessels and could act as a precursor to wider rollout. This would mean that in the initial stages that there would be no level playing field between Scottish and non-Scottish vessels.

11.4. Another option considered in the consultation was a broader rollout of REM for all vessels fishing as part of specific fleet segments. It was argued that the approach could have the advantage of providing greater coverage and would ensure that REM could be delivered on a level playing field basis. This option would require significantly more lead-in time.

11.5. The consultation sought views on each of these options and on whether there were any alternative options which should be considered. There is also reference made to a desire to take a co-management approach to the rollout of REM and to discuss the outcome of the consultation with the Fisheries Management and Conservation Group (FMAC) and to consult more widely if required.

11.6. Question 13 received 43 responses (11 individuals and 32 organisations).

Roll-out with a reference fleet

11.7. Respondents offered differing views on the proposed option of using a reference fleet for initial rollout for large demersal vessels.

11.8. There were a group of responses that believed a reference fleet was a sensible way forward ahead of a wider roll-out. These responses were largely among fishing organisation and public sector organisations.

11.9. Some advantages of the reference fleet given in these responses included that a reference fleet trial would provide useful data on levels of bycatch, allow for assessing the adoption of REM and the positive and negative factors of implementation ahead of a wider rollout in the demersal fleet.

11.10. Others noted that in terms of the demersal sector that observer schemes and/or reference fleets were the preferred means for evidencing compliance given that they also have added benefits of additional biological data collection that are not available through the use of REM alone.

11.11. It was also noted by one response that the effectiveness of a reference fleet would depend on its structure and careful consideration would be required in order to ensure that the reference fleet did not develop into just a fleet monitoring tool.

11.12. One response cites the Norwegian reference fleet as an example of the potential for reference fleets to progress fisheries monitoring beyond the standard observer scheme. The quote below provides the case for this:

"As is the case with the Norwegian reference fleet, this would:

• Provide long term quality controlled biological sampling of catches from commercial fisheries.
• Document fishing effort and species composition of the total catches, including bycatch, discards and non-commercial species.
• Allow access to undertake 'on demand' sampling for a range of species.
• Contribute to improved cooperation and understanding between fishermen, scientists and managers." [Organisation, Fishing Organisation]

11.13. Another theme in relation to the implementation of a reference fleet was that it could damage the level-playing field and would leave reference Scottish vessels at a disadvantage relative to their counterparts fishing in the same waters, particularly if REM were being used for compliance purposes. For example:

"We believe that the reference fleet approach is the best approach, especially where the information gathered supports management decisions on fishing operations and stock assessments.

That said, our members hold the firm belief that if Scottish vessels are subject to REM in their own waters, then vessels flying other flags should be subject to the same conditions, a position we set out earlier in our response.

There can be some deviation from the above position if REM was used for scientific purposes only. If this was not the case, then we would view REM as being used for compliance purposes and insist that all vessels flying a foreign flag are subject to a condition that requires REM when operating within the Scottish zone." [Organisation, Fishing Organisation]

11.14. However, other responses reflect opposition to the option of using a reference fleet. Some opposition was on the basis that the use of a reference fleet may lead to issues of over-representing those who are already compliant unless Marine Scotland select the reference fleet, or it was randomly selected while others felt that only a full roll-out was acceptable in spite of the additional lead-in times.

Broader roll-out

11.15. Many responses felt that a broad roll-out was preferable to using a reference fleet. While it was noted that with this option longer lead-in times are required and that this comes with increased complexity that a broader roll-out maximises the benefits in terms of confidence, compliance with regulations and maintaining a level playing field. The following quotes illustrate some of these views:

"A broad rollout of REM to all vessels in the demersal trawl fleet would be the preferred option. Despite longer lead in times, this would permit the maximum benefits in terms of confidence in compliance with regulations, greatly improved knowledge of discards and in providing a level playing field for all fishers in Scottish waters." [Organisation, Conservation]

"REM can work on all class of vessel so if it is affordable for Marine Scotland to undertake the video and data reviews and enforce any infringements detected, then all vessels should have REM. the data will improve science and management and reduce illegal discarding. There is no other way to enforce a Landing Obligation or similar management tool." [Individual]

"Effective application of REM in high-risk demersal fleet segments would help address both the discarding of undersize fish and high-grading of certain species, both of which contribute to overfishing." [Organisation, Conservation]

11.16. Some respondents questioned why the roll-out was targeted to the pelagic sector in the first place and that for the benefits set out in the consultation to be realized that REM would have to be extended across the whole demersal trawl fleet.

11.17. Others felt that the roll-out should also apply to the gillnet and longline fleets on the basis that REM could be used to monitor vessels in order to provide an understanding of impact and where mitigation can be applied it should and be monitored for use and efficacy. It was argued that prioritisation of vessels that pose an elevated risk to protected species would align the Scottish Government with the approach of fisheries managers in New Zealand, who have been phasing in REM through their Integrated Electronic Monitoring and Reporting System (IEMRS).

11.18. Among some respondents the need for co-design and management of any roll-out was expressed as vital.

Other views raised

11.19. Some other views were raised in relation to the deployment of REM among respondents in response to Question 13.

11.20. Concerns were raised around compliance and the severity of any measures introduced by the roll-out of REM and whether REM has a place as an enforcement tool in the face of choke risks.

11.21. Others raised concerns about the proposals and questioned the science behind some of the arguments made in favour of REM in the consultation document and noted that the application of REM in the industry would be unworkable given the level of uncertainty in relation to individual stock levels.

11.22. The cost of the roll-out whether that be for a reference fleet or broader roll-out were raised as issues in some responses, while others queried the definition of large vessels used and some raised potential issues in relation to the technology required for effective roll-out of REM.