1. In spring 2022, the Scottish Government undertook a public consultation on 'Enhancing sustainable fisheries management - Remote Electronic Monitoring'. The consultation ran from 15 March 2022 to 7 June 2022. This report presents findings from an independent analysis of the responses.
2. The consultation received 48 valid responses. Responses were submitted by 15 individuals and 33 organisations or groups. Organisational responses included fishing organisations, conservation organisations, public sector and third sector organisations. Throughout the consultation responses it was clear that fishing organisations and conservation organisations expressed differing viewpoints on a number of matters.
3. The purpose of this public consultation was to seek views on the following:
- The general principles of Remote Electronic Monitoring (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:
- 1) 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.
- 2) 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.
4. Following the principles set out within the Scottish Government's 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 in the consultation for these different sectors vary in coverage, specification, and timescale for implementation.
5. The following views supporting the use of REM cut-across several questions in the consultation responses:
- REM has the potential to be a driver to improve sustainability in the Scottish fishing industry. The benefits of this are both ecological and commercial due to consumer attitudes towards sustainable fishing.
- Adopting the proposed mandatory use of REM would position Scotland as a world leader in promoting sustainable fisheries management.
- That REM could provide significant scientific benefits in terms of monitoring of stocks and minimising negative impacts on the wider marine environment including sensitive species bycatch (the unintended capture or entanglement of non-target species in fishing gear).
6. The following views opposing the proposals cut-across several questions in the consultation responses:
- Requiring the use of REM on Scottish vessels outside the Scottish zone could undermine the level playing field and place Scottish vessels at a disadvantage compared to non-Scottish vessels.
- That there were likely to be significant compliance issues associated with REM systems and concerns were raised around the practicalities of enforcement of any compliance requirements.
- That these requirements could introduce significant costs to fishers.
7. The following considerations to the proposed application of REM cut-across several questions in the consultation responses:
- That a true level playing field could only be achieved where all vessels, regardless of origin, were subject to the same REM requirements and standard of application in Scottish waters.
- Wider consultation may be required including with non-UK vessels.
- Effective data monitoring and sharing would be critical in ensuring the ambitions of the application of REM could be met.
8. The Scottish Government published a consultation on its proposed Future Catching Policy in parallel with the consultation on REM. Within both consultations, the clear links between the two policies were identified by some respondents. For example, by requesting that additional monitoring of bycatch be undertaken using REM to inform action under the Future Catching Policy. The Scottish Government will need to consider the results of both consultations to inform the development of these policies in a complementary way.
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