Marine resources – remote electronic monitoring: consultation analysis

3. Why REM? (Q1)

3.1. The consultation paper discussed proposals to exercise the Scottish Government's powers to require that Scottish vessels adhere to REM measures when fishing outside Scottish waters. The consultation document highlighted several advantages to this: it would add to the richness of data collected, would assist in compliance, and deliver confidence and accountability in fishing practices. It is recognised that this would lead to Scottish fishing vessels working with more monitoring technology than others, but this was framed as demonstrating Scottish fishing ambition.

Q1. Operation of REM outside the Scottish Zone

Q1: Do you agree that Scottish vessels required to use REM in the Scottish zone should also have REM operational when operating outside of the Scottish zone?

3.2. Question 1 received 46 total responses - 31 from organisations and 15 from individuals. Overall, 57% of closed responses indicated agreement that Scottish vessels be required to use REM both in and outside the Scottish zone while 30% disagree and 13% said they did not know. The level of agreement was lower among organisational responses (48%) and higher amongst individual responses (73%).

3.3. Among organisational responses 35% said that they did not agree with the requirement for Scottish vessels to have REM operational outside the Scottish zone. Fishing organisations were most likely to disagree while most conservation organisations supported the use of REM outside the Scottish zone.

Support for requiring REM outside the Scottish Zone

3.4. Those who agreed with the idea of Scottish vessels having REM operational outside the Scottish Zone highlighted various advantages this would provide.

3.5. Firstly, improved sustainability in the Scottish fishing industry was put forward as not only morally desirable, but, more frequently, marketable to consumers. Linked to sustainability, a few respondents highlighted Scotland's opportunity to demonstrate its position as a world leader and promote best practice across the world. Others additionally mentioned the benefits of the scientific data REM would provide. The responses that tended to focus on sustainability came from fisheries, individuals, and conservation organisations. The following quotes illustrate the above themes:

"The monitoring of fishing should be something that applies across the oceans, not just in territorial waters. By starting this practice, it would be hoped that one day it would become the norm across all fishing nations that their vessels use a monitoring system at all times no matter their location; this could be supported by the additional sustainability credentials that would be afforded to fish caught by Scottish vessels." [Individual]

"Greater transparency in the sustainability and environmental impact of fisheries is increasingly important to consumers. Demonstrating that Scottish vessels obey regulations and have little bycatch wherever they fish can only improve the sustainability credentials of the sector." [Organisation, Fishing Organisation]

"We recognise that such a requirement would mean that vessels fishing in Scottish waters would have more monitoring technology than others operating out with the Scottish zone but believe that such a requirement in Scottish waters could mean Scottish Government play an important leadership role in bringing about the acceptance of REM by other nation's fleets. The EU's fisheries control system, which ensures the Common Fisheries Policy is implemented and rules, including the Landing Obligation, are followed – is currently being reformed and as part of this, onboard cameras could become mandatory. Mandating REM with cameras for all vessels fishing within the Scottish zone (and for Scottish vessels fishing out with) could encourage and accelerate the adoption of REM across the EU." [Organisation, Conservation]

"Many Scottish registered fishing vessels fish out with the Scottish zone; it follows therefore that Scottish vessels should be required to use REM when operating out with the Scottish zone. As interest in provenance of seafood is increasing, only requiring REM to be operational in the Scottish zone would not provide the levels of confidence needed to improve the marketability of Scottish catches and the reliability of scientific stock assessments and advice." [Individual]

3.6. Relating to the practical use of REM for management and compliance, several responses highlighted how the technology generally assists in fisheries management and that not using REM outside Scottish zones would reduce the aforementioned benefits because it would allow space for non-compliance:

"Vessels that are Scottish that are operating outside the Scottish zone still represent Scottish nation's fishing interests and any illegal activity will reflect on Scottish government and the nation as a whole. It will deter opportunities to discard outside of Scottish waters and so improve management of stocks that migrate across national boundaries or are shared stocks. For example, if vessels are not allowed to discard certain species in Scottish waters they may be tempted to sail into other waters, switch off REM and dump unwanted fish unrecorded. If illegal transhipment of catch is a possibility, then it will be deterred. It also provides evidence to defend any false allegations against the Scottish fleet" [Individual]

"All Scottish vessels should have operational REM at all times, irrespective of the waters they are fishing. […] As noted in Sn. 3.3 of the consultation paper, REM provides 'significant scientific and compliance benefits.' The more data collected regarding the activities of vessels in the fleet, the more effectively the fishery can be managed, and the more sustainable it will become." [Organisation, Conservation]

Opposition to requiring REM outside the Scottish Zone

3.7. Opposition to Scottish vessels using REM outside the Scottish Zone focused heavily on the way this would undermine the level playing field. Concern about level playing field came from various groups, but very frequently from representative bodies for fisheries:

"the use of REM should be on a level playing field basis and that all vessels operating in and outside the Scottish zone should be subject to the rules and regulations of the relevant fishing areas." [Organisation, Fishing Organisation]

"As a matter of principle, and in line with the Government's own 'level-playing field' guarantee, Scottish vessels required to use REM in the Scottish zone should not be required to comply with more onerous rules than non-Scottish vessels out with the Scottish zone.

"If REM is a requirement in fishing zones other than the Scottish zone and/or in international waters, then of course Scottish vessels fishing in those zones will have to comply in exactly the same way as every other comparable vessel fishing there." [Organisation, Fishing Organisation]

3.8. Furthermore, relating to REM in general, several responses expressed negative feelings of being policed and felt that compliance was the main purpose of the technology rather than the benefits supporters of the policy highlighted in their responses. A small minority viewed REM as unnecessary given other tracking technology already aboard Scottish vessels such as Automatic Identification System (AIS) transponders and VMS.

"This consultation reads like you are more concerned with policing Scottish boats than managing environmental practice in Scottish Waters. Surely all boats in Scottish waters should be monitored.
I'm all for fisheries monitoring – But what is the point of only monitoring Scottish boats if it will only be used to punish Scottish boats? Surely this data can be supplemented with fishing vessel behaviour from freely available sentinel 2 data and compared to data on found litter at sea." [Individual]

Wider points

3.9. A minority of open responses mentioned the advantages of the creation of matching UK legislation.

"All Scottish vessels should have REM regardless of where they are operating and there should be similar systems in place throughout the UK, to ensure that all UK vessels should have similar systems operating in all UK waters." [Organisation, Fishing Organisation]

3.10. Finally, several responses appeared to misunderstand the question as relating to whether non-Scottish boats in the Scottish Zone would be required to use REM – which the consultation paper stated would be the case.