Remote Electronic Monitoring (REM): island communities impact assessment - draft

Consultation

Background

The Scottish Government’s intention to deliver a legislative requirement for REM onboard pelagic and scallop dredge vessels was developed as part of the Fisheries Management Strategy (published December 2020). The publication provided an early opportunity for extensive engagement with stakeholders on the Strategy’s proposals on REM. A national discussion was undertaken in the form of a discussion paper that was supported by a range of stakeholder events based in key fishing areas around Scotland as well as other online events.

Public Consultation

A full public consultation^[1] on the use of REM took place from 15 March to 7 June 2022. The consultation sought views on the implementation, impact and general principles of the use of REM in the pelagic sector and was well publicised in Scotland and also throughout the rest of the UK and internationally.

Responses to the consultation were mixed between individuals and organisations, and between environmental / conservation groups and fisheries organisations and have proved helpful in providing stakeholder views on a number of key questions. In total the consultation received 48 valid responses. We published our analysis report^[2] of the responses to the REM consultation in August 2023.

The public consultation was wide reaching on the principles of REM, its specific application to the scallop dredge and pelagic trawl fleets and initial views on its application to the demersal fleet. The consultation did not focus on the policy’s specific application to islands and no concerns explicitly to do with islands were received.

An issue that was raised in some of the consultation responses related to potential disadvantage to vessels operating from rural coastal locations, where access to engineers and repairs may be limited. Given the rurality of island communities, these comments would likely include the 37% of the scallop dredge fleet and 38% of the pelagic fleet that are islands based. However, any concerns covering this section of the fleet also apply to vessels operating from mainland rural coastal areas and have been accounted for and mitigated in the development of the legislation.

Stakeholder feedback also included the need for realistic lead-in times given potential limitations on access to installation of REM systems in rural coastal areas. This is especially relevant to the pelagic fleet and, taking the feedback onboard, we have extended the 12-month timeframe for the pelagic industry to become compliant that was put forward in the consultation to a longer lead in time – the pelagic provisions will not take effect until 7 March 2026. This will enable the pelagic fishing industry to source and install the required equipment and will provide sufficient opportunity for ancillary support services to be put in place.

All active Scottish scallop vessels have already been provided with considerable time and Scottish Government support to prepare for the introduction of the policy with these boats receiving funded REM installations that meet the requirements of the new regulations.^[3] These installations have taken place around the Scottish coastline, including on Orkney, Shetland and the Western Isles.

Industry Consultation

For the pelagic element of the policy, meetings have taken place with the Scottish Pelagic Fishermen’s Association (SPFA) to explain the policy and provide opportunity for discussion. Engagement with this sector did not highlight any particular concerns with regard to island communities, although the need to maintain a level playing field approach for all pelagic vessels regardless of their country of origin was stressed. Establishing a level playing field approach to REM has been factored into the policy throughout its development and has resulted in a uniform approach for the installation and use of REM by both Scottish and non-Scottish vessels fishing in Scottish waters.

For the scallop dredge element of the policy, there are already a number of vessels (operating in the 6-12 nautical mile zone and deploying 10 dredges per side) that are required to have an REM system installed and operational^[4]. The remaining elements of the sector acknowledged the value of using REM to demonstrate responsible fishing practices and for wider benefits. Following positive dialogue with Scottish Government and the Scottish Scallop Sector Working Group (now represented through FMAC) the remainder of the sector (island based and non-island based vessels) have been leading the way in adopting funded REM systems on a voluntary basis^[5] mainly between 2021 and 2023.

Internal Consultation

Internal discussions have been carried out with local Fishery Office managers who hold a high level of expertise in relation to the fishing industry. In their view, whilst electronic engineers that service the fishing industry and other infrastructure are not as prevalent in island communities or mainland communities out-with areas with significant marine infrastructure (for example NE mainland), provision does exist in these areas – this is by necessity given that the general operation of marine sectors and the fishing industry cannot take place without technical support.

Electronic engineers already support the fishing industry through, for example, VMS and e-log requirements, as well as general work and repairs. REM will require some diversification in the work of engineers, as was the case with the rollout of VMS and e-logs, but the voluntary rollout of scallop REM has demonstrated it is possible, regardless of location for the appropriate level of electronic and technical support to be in place.

Whilst Shetland is the island grouping with the most scallop dredge vessels and pelagic vessels, given the marine infrastructure and diverse marine sectors present there, our assumption based on our prior experience is that there is sufficient expertise available with at least average coverage of engineers and so should manage in much the same was as mainland communities outwith the NE do. Additionally, many of these vessels already operate technical electronic systems, particularly the pelagic vessels, and so the REM system is expected to simply be an ancillary system to the existing operation requiring only some training. Furthermore, the active Shetland scallop dredge fleet are already carrying REM on a voluntary basis, with installations having been carried out by local engineers. As such it is the Marine Directorate's view that there should be no capacity issues with availability in Shetland relative to Scotland at large.

The introduction of the legislation has been, and will continue to be, well publicised amongst non-Scottish vessels, with other fisheries administrations being provided with relevant information to help support their fishing vessels to understand and comply with the new regulations.