Marine resources – remote electronic monitoring: consultation analysis

5. Pelagic Vessels (Q3-4)

5.1. The consultation paper discussed the Scottish Government's intention, as set out in the Fisheries Management Strategy, to introduce legislation to the Scottish Parliament making it a legal requirement for all pelagic vessels licenced to fish within Scottish waters (The Scottish Zone) to have a fully operational REM system installed on board.

5.2. Pelagic vessels were defined in the consultation as Refrigerated Sea Water/Chilled Sea Water (RSW/CSW) and freezer vessels, over 12 metres, fishing for small pelagic and blue whiting. The requirement to have an REM system on-board which complies with Scottish Government legislation will extend to all Scottish vessels, as well as other pelagic vessels from outside Scotland, fishing in Scottish waters.

5.3. Data from 2020 shows there were 22 vessels in the Scottish pelagic fleet, and around 155 non-Scottish vessels fishing for pelagic species in the Scottish Zone (though not necessarily landing in Scottish ports). The main species caught are mackerel, horse mackerel, herring, and blue whiting, with the catching season running from late summer to February, depending on species.

Q3. Issues on a level playing field basis

Q3: Are you aware of any issues we need to take account of when we apply REM across all pelagic fishing fleets fishing in Scottish waters on a level playing field basis?

5.4. Question 3 received 35 total responses – 21 from organisations and 14 from individuals – wherein 40% of participants agreed that they were aware of issues to be mindful of where REM is applied across all pelagic fishing fleets fishing in Scottish waters on a level playing field basis. 23% answered No, while 37% said they did not know. The latter response was slightly higher amongst organisations than individuals.

Issues to take into account when applying REM

5.5. Respondents outlined various issues to take into account when applying REM across all pelagic fishing fleets fishing in Scottish waters on a level playing field basis.

5.6. The need for data on and/or application to non-Scottish vessels, in order for these to all be held to the same standard, was commonly mentioned by respondents:

"As REM systems are essentially remotely monitored, it is important that all nations and administrations ensure their REM monitoring and enforcement is consistent with that in Scotland. The presence of an REM system on a vessel is no guarantee the system is being used appropriately or adequately monitored. Data sharing between jurisdictions should be considered" [Organisation, Conservation]

5.7. Compliance was important to participants who felt that, in order to ensure a true level playing field, all fishing vessels operating in Scottish waters ought to comply with a REM requirement. Some noted that this should also be considered for the entire UK EEZ (Exclusive Economic Zone). Additionally, the ability to verify the proper operation of REM systems installed on non-Scottish vessels was deemed important.

5.8. The requirement for consistent surveillance and monitoring was raised by participants, whilst ensuring sufficient and timely assistance for REM system breakdowns was also a concern. In regard to the latter point, however, some sought assurances that, in the event of an unexpected equipment failure occurring whilst at sea, a vessel may complete its trip and not be instructed to return to port immediately to rectify the problem.

5.9. Similarly, respondents noted the breadth, and cost, of the (often specialist) equipment required for REM to work effectively. One noted that approximately 6-12 cameras, depending on vessel, would be necessary to successfully examine all potential discarding points, also noting that:

"Obtaining an independent estimate of bulk catch is also challenging and would require integration with net sensors, hopper scales, water displacement sensors (in RSW vessels), or fish pump and flow meter technology" [Individual]

Q4. Definition of pelagic vessels

Q4: Do you agree with the definition of pelagic vessels provided and are there any unintended consequences from using this definition?

5.10. Question 4 received 30 total responses - 20 from organisations and 10 from individuals. Overall, 57% of respondents agreed with the definition of pelagic vessels provided, whereas 43% disagreed.

5.11. Though few respondents offered additional comments, some felt that the definition of pelagic vessels provided was not clear in relation to target species. It was suggested that other species, such as the sand eel and Norway Pout be included in the definition. Others indicated that:

"The use of any net below 70 mm (in combination with the other criteria) would be sufficient for defining 'pelagic', regardless of the target species" [Organisation, Conservation]

5.12. One respondent was unsure as to why the definition provided did not appear to relate to any of the fleet segments defined in the Future Catching Policy (FCP) and felt that:

"to have several different and overlapping ways to breakdown the fleet is confusing and nonsensical" [Organisation, Conservation]

5.13. Others felt that there could be more clarity around vessel types within the definition, particularly where it is not sufficiently precise to be certain of capturing all foreign vessels which target pelagic fish stocks in the Scottish sector – there were concerns that this, in turn, could provide an advantage to foreign vessels.

5.14. There were also calls for specialist vessels, namely freezer trawlers, to be specifically defined and recommendations that additional camera systems and/or monitoring sensors to cover various features – such as RSW tanks, grading systems, processing deck and freezing holds, in addition to the fishing operation - should be in place.

5.15. Another respondent observed a potential issue wherein the definition of the 'pelagic sector' as described in the proposal becomes conflated with 'pelagic species' or 'pelagic quota'. Though they felt the distinction was made clear in the consultation, they underlined its future importance in allocating pelagic quotas to different fleet segments, as required by the 2020 UK Fisheries Act. They also argued for the potential of smaller vessels to access pelagic species/quota without having to meet the requirements of the definition of 'pelagic sector'.