Marine resources – remote electronic monitoring: consultation analysis

Introduction and background

Introduction

1.1. This report provides an analysis of responses to the Scottish Government consultation on 'Enhancing sustainable fisheries management - Remote Electronic Monitoring'. The consultation ran from 15 March 2022 to 7 June 2022.

Policy Context

1.2. Scotland's seas host an abundance of marine life providing a healthy, low carbon source of food in addition to a source of employment for Scotland and the international community. The Scottish Government's Fisheries Management Strategy^[1]sets out a responsibility as managers of this public resource to ensure that fishing takes place sustainably and responsibly, and that fishing activity is accountable while delivering confidence for consumers and the wider public with regards to the products offered.

1.3. Technology such as Remote Electronic Monitoring (REM) and advancements in Machine Learning (ML) provide opportunities to modernise the way in which accountability and confidence is provided in delivering responsible and sustainable management.

1.4. REM places an enhanced and independent level of monitoring on board, for example by using cameras, sensors, and GPS. These monitoring devises mean fishing activity taking place can be determined. REM is a key fisheries enforcement and scientific tool and forms an important part of the ten-year Fisheries Management Strategy.

1.5. The proposals detailed within the consultation paper^[2]are set in this context, arguing that the following benefits can be delivered using REM technology:

• improve the capacity to monitor fishing activity at sea and increase compliance with legislation for all vessels fishing in Scottish waters,
• enhance scientific capability and knowledge, supporting sustainability of fish stocks and management of natural resources,
• deliver the confidence and accountability that consumers and the public want to see from seafood products,
• improve fishing data to help the fishing industry co-exist with other marine users, better assist marine planning, and build resilience in fishing fleets and stocks.

1.6. The Scottish Government already monitors limited vessels in Scottish waters using REM and has committed to mandating the technology on scallop dredge and pelagic fleets. Given the proposed benefits of REM, through the consultation the Scottish Government sought views on various aspects relating to the usage of REM as regards Scottish vessels (and all other vessels fishing in Scottish waters).

1.7. This stage of implementation looks to make REM mandatory for scallop dredge and large pelagic vessels, while also exploring options for further rollout to other parts of the demersal fishing fleet.

1.8. The legislation will ensure a level-playing-field whereby the requirements will apply to all vessels fishing in Scottish waters, regardless of origin.

1.9. During the public consultation period for REM, the Scottish Government was also running a separate but related consultation on proposals relating to the Future Catching Policy (FCP).^[3] The FCP looks to develop new rules to regulate activity at sea in order to support increased accountability and more sustainable fishing practices.

The consultation

1.10. The purpose of this public consultation was to seek views on the following:

• The general principles of REM and stakeholder views on these points as they will apply across fleet segments - not just those consulted on at this stage.
• Formal consultation on mandatory REM requirements in the:
  • Pelagic sector. Defined in the consultation as Refrigerated Sea Water /Chilled Sea Water (RSW/CSW) and freezer trawls fishing with a mesh size of 70mm or less within Scottish waters, targeting mainly mackerel and herring, with a significant catching capacity whilst delivering high quantity and value seafood products. This requirement is being implemented following the consultation, but views were sought on aspects of the policy.
  • Scallop dredge sector. This requirement is being implemented following the consultation, but views were sought on aspects of the policy.
• Initial views regarding REM in the demersal sector, defined as mobile vessels with an overall length of 12 metres and over – specifically, large whitefish and mixed fishery vessels fishing in Scottish waters. The aim was not to formally consult on the implementation of REM for this sector, but to seek initial views from stakeholders on a range of options.

1.11. Following the principles set out within the Fisheries Management Strategy, that a one-size-fits- all approach to management should be avoided to take account of the variations in fishing practices across different fleet sectors, and the need for proportionality, the proposals for these different sectors vary in coverage, specification, and timescale for implementation.

1.12. The consultation contained 14 questions - 2 open, and 12 closed with space to provide further comments. The questions covered:

• Why REM? (Question 1)
• Costs (Question 2)
• Pelagic Vessels (Questions 3-4)
• Timeline for compliance with the mandatory REM requirement (Question 5)
• Benefits of REM in the pelagic sector (Question 6)
• The pelagic REM system (Questions 7-9)
• REM for scallop dredge vessels (Question 10)
• REM system specification for scallop dredge vessels (Questions 11-12)
• REM for large demersal vessels (Question 13)
• Business Regulatory Impact Assessment (Question 14)

1.13. Annex 1 contains a complete list of consultation questions.

Aim of this report

1.14. This report presents a robust analysis of the material submitted in response to the consultation. The structure of the report follows the structure of the consultation paper and considers the response to each consultation question in turn.

1.15. Annexes 1-3 provide further detail about the consultation questions, the responses, the respondents, and the views expressed.

Approach to the analysis

1.16. The analysis seeks to identify the most common themes and issues. It does not report on every single point raised in the consultation responses. All responses, where the respondent has given permission for their comments to be published will be made available on the Citizen Space website.

1.17. Equal weighting has been given to all responses. This includes the spectrum of views, from large organisations with a national or UK remit or membership, to individuals' viewpoints.

1.18. This analysis report quotes and paraphrases some of the comments received. However, this does not indicate that these comments will be acted upon or given greater credence than others.

Comment on the generalisability of the consultation findings

1.19. As with all consultations, the views submitted in this consultation are not necessarily representative of the views of the wider public. Anyone can submit their views to a consultation, and individuals (and organisations) who have a keen interest in a topic – and the capacity to respond – are more likely to participate in a consultation than those who do not. This self-selection means that the views of consultation participants cannot be generalised to the wider population. For this reason, the main focus in analysing consultation responses is not to identify how many people held particular views, but rather to understand the range of views expressed and the reasons for these views.