Marine resources – remote electronic monitoring: consultation analysis

8. The pelagic REM System (Q7-9)

8.1. The consultation document discussed various technical details and requirements for proposed REM systems. Section 3.4.1 outlined the general information that the consultation expected REM systems to provide:

• Confirmation of fishing activity taking place and location of fishing activity
• Weight of fish caught, retained, and landed (providing there are no disparities between these figures will give confidence that no discarding has taken place)
• Species composition of fish caught
• Video footage of the sub-sampling for length and weight undertaken by the crew

8.2. The consultation document stated that cameras and sensors will be necessary to collect this data, with net sensor data possibly being used to increase confidence in the data for both science and compliance purposes.

8.3. Section 3.4.2 then outlined in more detail the proposed minimum REM system capabilities for pelagic vessels. They should be able to:

• Provide visual verification of fishing activity taking place, along with sensor data to indicate shooting and hauling of nets. Sensors would be placed to indicate shooting and hauling of nets.
• Provide visual verification via cameras that no discarding or slipping is taking place. It would also be helpful to position an additional camera(s) over the side of the vessel where the net is brought alongside to monitor bycatch of vulnerable species e.g., cetaceans.
• Provide visual confirmation of pump rate (via cameras) to aid with verification of catch data and estimation of weight of catch.
• Provide visual confirmation of separators to determine which tanks are receiving what fish at what time.
• Provide visual data via positioning of camera above the vessel's subsampling station, to include confirmation of length and weight (grams) data of the subsample in order to supplement the scientific data set.
• Provide GPS information – position information should be recorded at a minimum frequency of every 10 seconds, meaning this is more reliable than VMS information. This would allow the interpretation of location data and would aid in deterring and detecting misreporting.
• Provide pump rates – with the manufacturer's specification on the maximum that can be pumped in a set time, the camera visual will provide data for how long pumping was in operation. Between these two figures, the maximum number of fish expected to have been brought on board can be calculated and compared against reported figures.
• Provide visual data by positioning the camera above any open channel/separator in order to estimate species composition and collect length and/or weight data if possible or as candidate footage for Machine Learning (ML) development.

8.4. The consultation proposed that the above specifications would allow REM to meet benefits highlighted in Section 3.3 of the paper, summarised as:

• Improved data for scientific purposes and analysis
• Improved tool for compliance purposes to assess conformity with existing fishing legislation and rules

Q7. Benefits of system outlined

Q7: Do you agree that the system as outlined in section 3.4.2 (System specification) should be able to meet the benefits described in Section 3.3?

8.5. Question 7 received 36 total responses – 24 from organisations, 12 from individuals. The overall level of agreement that the system as outlined in the consultation should be able to meet the benefits outlined (72%) did not vary greatly from the level of agreement among organisational (71%) and individual responses (75%).

8.6. Of those that provided additional comments (30 of the 36 total responses), some took issue with the benefits that were outlined in section 3.3. Some echoed sentiment from Q1 of feeling policed and others argued that the focus should be on science.

8.7. The responses that directly answered the question about whether section 3.4.2 matched the ambitions of section 3.3 highlighted some possible issues in reaping benefits from the technology.

Standardisation challenges

8.8. Many argued that standardisation across different vessel types and from different countries would be challenging and could undermine the level playing field principle.

"The Association seeks assurances that REM systems for Scottish vessels and 3rd country vessels have the capability of reporting identical information, including the format the data is delivered in, and the timeframe for delivering that information is the same." [Organisation, Fishing Organisation]

"Sounds like a very complex specification to standardise. It will have to adapt to every different boat." [Individual]

Specific technical components

8.9. Regarding specific technical components of the system, several respondents pointed out the need for additional cameras and others were sceptical of the relevance of pump rates as a measure and what role machine learning would play. The following response outlines these issues in more detail:

"We cannot see how a camera system using machine learning/artificial intelligence can monitor and determine the composition, length, weight etc of pelagic fish entering a fish/water separator. This is purely due to the rate of fish going through the system. Some vessels separator arrangements would not work well with this either due to their design.
[…]

Using pump rates provided by fish pump manufacturers would be highly inaccurate. They will only be able to provide maximum theoretical pump rates of the unit. Pumping fish on board can also be highly variable. This is dependent on a number of factors. There could be an unknown restriction that would severely impact the pump rate. This could be up to 75% slower. Each cod end also pumps at a slightly differing rate compared to another. Even if it is of the same design. This is entirely independent of the fish pumps capability. Fish pump systems also operate on a variable pressure control. Lower pressure is used to pump slightly slower for higher quality fish. Therefore, the pressure of oil going to the pump (or in terms of electric pumps – RPM of the impeller) would have to also be recorded. This would be extremely difficult to record. Each fish species also pumps at a different rate." [Organisation, Fishing Organisation]

Observation for compliance

8.10. Finally, upon the collection of data, several responses expressed their views with regards to a perceived lack of planning put forward in the consultation for who, or what, will observe the videos for compliance and how this will be enforced to achieve the benefits identified in section 3.3.

"The long list of system specification described in pages 15-16 will generate a truly huge data stream. The amount of time to observe one haul would be considerable, so there are concerns about the amount of actual replay monitoring that can be accomplished.

Given budgetary constraints how will Marine Scotland resource staff, with the required expertise, to review the vast amount of REM data collected? What is a realistic target figure for analysis? Furthermore – How would trips be selected? Who would undertake the analyses?" [Organisation, Fishing Organisation]

"The effectiveness of REM is not about whether the REM system has collected the data or not it is more about how the data is reviewed, how results are communicated back to fishers, clear penalties for breaking any rules, and consistent enforcement. Once you stop reviewing the footage correctly or dealing with issues in a timely and consistent manner, the assumption becomes that no one is looking at the data, which removes the incentive to comply." [Individual]

Q8. Specific operational problems

Q8: Do you foresee any specific operational problems with the system specification set out within the document?

8.11. Question 8 received 34 total responses – 23 from organisations and 11 from individuals. Overall, 59% of respondents foresee specific operational problems with the system specification, with this rising to 65% of organisational responses and falling to 45% of individual responses. Fishing organisations were more likely to say that they could foresee specific operational problems with conservation organisations less likely to say this.

Operational problems

8.12. Within open responses provided, a number of specific operational problems were highlighted. It was generally mentioned that there could be unexpected issues/teething problems with the system, and concerns were raised about how long a boat could continue to fish if the system malfunctions during their voyage.

'Whereas we accept that safeguards need to be in place to prevent against gaming, our members hold the view that it would be unreasonable to insist that vessels return to port on the occasion where REM equipment on board fails. For offshore vessels this would be a tiresome obligation and we suggest that in such cases vessels are allowed to complete their trips with the proviso that it must not leave port with defective gear.' [Organisation, Fishing Organisation]

8.13. On the other hand, several respondents also expressed the view that a vessel should return to port if there is a fault with the system.

"The system must be tamperproof and the legislation should require that, should the system stop working, the vessel must return to port and the certified engineer be called to return it to operation." [Organisation, Conservation]

8.14. Concerns about the application of this system to the factory operation of freezer trawlers were also raised by various organisations.

"There is no mention in the consultation document of the REM specifications envisaged for the factory element of freezer-trawler operations. This is a significant omission and would need to be remedied before the Scottish fleet could have confidence that a level playing field had been secured." [Organisation, Fishing Organisation]

"[We] believe that, before moving to the next stage beyond consultation it is imperative that Marine Scotland specifies how the factory operation onboard freezer trawlers will be fully documented" [Organisation, Fishing Organisation]

Wider points

8.15. Beyond these themes that were repeated by several respondents' open answers, a number of other issues were mentioned by smaller groups of respondents:

• Transmission issues at sea
• Cost of operation
• Data security/privacy concerns
• Lack of technical assistance
• Unclear duties of care for REM equipment
• Insufficient information about GPS standards
• Monitoring of videos
• Difficult to standardise across Scottish and non-Scottish boats
• Lack of incentives for implementation.

Q9. Net Sensor Data

8.16. Question 9 received 33 responses in total – 21 from organisations, 12 from individuals. 64% of responses were in favour of requiring net sensor data as part of the system specification, with this breaking down to 67% of organisations, and 58% of individuals. Fishing organisations were much more likely to disagree that net sensor data should be included as part of the system specification at this point while conservation organisations were much more likely to agree.

Arguments for and against net sensor data

8.17. Clear arguments for and against the use of net sensors emerged from the open answers to question 9. The key argument in favour was that this would provide more data for science and to improve sustainability. Many of these responses came from conservation organisations, such as the two quoted below:

"Appropriate net sensors would be important for monitoring the quantities and identifying the species of fish entering the net. Such sensors also have the potential to monitor the presence of vulnerable species such as sharks and cetaceans. Consideration should be given to grant aiding the additional installation costs of such sensors." [Organisation, Conservation]

"Net sensors will provide valuable data on fishing activity patterns and importantly, CPUE. Excluding such data at the outset will mean that the benefits described in Section 3.3 will not be achievable, and the fisheries will not be fully documented." [Organisation, Conservation]

8.18. A couple of responses hedged their answers advocating for this technology by suggesting it be voluntary initially. One other respondent called for a separate consultation on this topic.

8.19. However, several arguments were put forward against this suggestion. The most popular reason by far was that net sensors would provideinaccurate data.

"Most vessels are now using wide bags to improve the quality of the fish while retained in the net. Skippers state there is a huge fluctuation on the ability of the catch sensor to accurately tell how much fish has been caught in a wide bag, making this a very unpredictable source of information now." [Organisation, Fishing Organisation]

"It only provides you with a bulk estimate of catch, but to what accuracy and to what level. If net sensors are only accurate to with 25% then it seems pointless. it would be better to introduce alternative technology to capture more accurate assessments, such as hopper, crane scales, flow meters, displacement sensors, laser scanners for volume estimates etc. Also, what happens when a net sensor fails or lost at sea, would this invalidate all data for the haul or would the vessel be required to replace it at sea or stop fishing and dock until it is fixed or replaced? Compliance would suddenly be reliant on the reliability of the builder of the net sensor." [Individual]

"Net sensor data would not be an appropriate indicator of catch levels. Each vessels sets their catch sensors differently and the quantities caught between vessels can be significant. Even the catch levels of differing cod ends on board a particular vessel can vary significantly. The newer style of "wide" cod ends are also extremely difficult to gauge catch level. The net sensor data that is displayed on the catch monitoring systems would also have to be output to a stand-alone system. The catch monitoring software may not have this capability and the system manufacturer may not be willing to make this option available in their system. The overall REM system would also have to be designed to receive the catch sensor info and then store it appropriately." [Organisation, Fishing Organisation]

8.20. Additionally, it was argued that installing REM is already going to be expensive, adding a requirement for net sensors would exacerbate this. Furthermore, some respondents mentioned that this may not be relevant to all fishing methods and therefore could create an unlevel playing field.