Marine resources – remote electronic monitoring: consultation analysis

12. Business Regulatory Impact Assessment (Q14)

Q14: Taking into account the Business Regulatory Impact Assessment (BRIA) supplementing this consultation, do you have any comments or views which you would like to put forward?

12.1. The consultation document was supplemented by a draft Business Regulatory Impact Assessment (BRIA).^[5] Respondents were asked to express any comments or views on the BRIA. In total, 22 respondents expressed views on the BRIA.

12.2. Some respondents noted the draft nature of the BRIA prior to making comments and suggested that the BRIA should be discussed at FMAC.

12.3. Other respondents used this question to reiterate points made throughout the consultation.

12.4. In terms of comments relating to the BRIA, some raised doubts over some of the scientific assertions made within the BRIA and queried whether the improved scientific data for REM would improve that already collected in the pelagic fleet.

12.5. There was discussion around costs with some responses alluding to resource constraint within the industry and for Marine Scotland. It was noted that the BRIA did not give costs for the analysis and interpretation of REM data, and this raised doubts over the extensiveness of any analysis that will take place. Another response raised SD cards should be included in specification costs and that the type required for REM would have to be high capacity which are expensive and harder to acquire.

12.6. The view was also raised in one response that the Scottish Government was not best placed to make assertions on competitiveness and that private businesses were in a much better position to judge what they had to improve market position and profile consumers.

12.7. A group of responses expressed the view that any costs to the industry, taxpayer, or combination of both was outweighed by the benefits of the roll-out with REM. And one response stated that the BRIA should estimate the cost to society of failure to implement the landings obligation, high grading and slipping alongside an inability to fully comply with ICES advice in the absence of a fit for purpose REM system across all fleet segments.