Marine resources – remote electronic monitoring: consultation analysis

4. Costs (Q2)

4.1. The consultation paper discussed estimates of 3 types of costs associated with implementing and maintaining REM systems, and estimates of variation in these costs across vessel:

4.2. The consultation recognised that challenges in meeting these costs may vary in distinct parts of the fishing fleet and suggested that public funding for upfront and purchasing costs or grant funding, for example via Marine Fund Scotland, may be appropriate for some Scottish vessels in some circumstances.

Q2. Barriers to vessels meeting REM systems costs

Q2: Do you foresee any barriers to vessels meeting the costs associated with the REM systems themselves? This includes upfront and ongoing costs.

4.3. Question 2 received 45 total responses – 30 from organisations and 15 from individuals. Overall, 64% of respondents foresee barriers to vessels meeting the costs of REM. Organisations were more likely to foresee barriers to costs (73%) than individuals (47%). Fishing organisations were particularly likely to state that they could foresee barriers to vessels meeting the costs associated with REM systems.

Costs identified

4.4. Although this question specifically asked about foreseeing any barriers to meeting costs, various costs were identified by respondents in their open answers. This could demonstrate perceptions of costs that may not exist, or costs that have not been accounted for in the consultation document:

• Upfront purchasing and installation costs
• Maintenance costs/repairs
• Damages incurred during installation
• Video review costs
• Developing the REM systems themselves
• Additional fuel
• Damage to sector when vessels are found to be non-compliant and cannot fish.

4.5. Of this list, most respondents focussed on the costs associated with purchasing, installing, maintaining, and repairing REM systems, with only a small minority mentioning the others listed.

Fragility of the fishing industry

4.6. Many responses highlighted the current fragility and challenges faced by the fishing industry. This context was recognised not only by representative bodies for fisheries, as may be expected, but also by individuals, fishing organisations, conservation organisations, third sector, and public organisations. The quote below illustrates current challenges facing the sector:

"Additional costs, as part of fleet modernisation and the introduction of REM, are inevitable. Therefore, there is a role for public support, particularly in the context of recent market disruption, the covid-19 pandemic, and rising energy prices." [Organisation, Public Sector]

"WRT the demersal fishing … The cost of buying or leasing quotas added to the increased cost of fuel is already pushing small fishing businesses to sell up or go bankrupt. There seems very little understanding within the government about the strain the industry is under and too much emphasis on enforcement." [Individual]

Funding Assistance

4.7. A majority of responses (which came from a wide variety of organisation types and individuals) suggested some form of funding assistance should be provided. These suggestions varied in where they believed this funding should come from, with the vast majority suggesting the Scottish Government. The suggestions also varied in the extent of funding they believe will be required, from funding covering every part of an REM system's lifecycle, to funding exclusively for upfront and installation costs. The following response went beyond most others to consider how costs would vary in different areas:

"The installation costs of all REM should be fully grant funded for all vessels, however, the additional fuel and gear costs being faced by all vessels could prevent many vessels for being able to meet all the annual running and maintenance costs. Vessels operating in remote locations where they do not have access to engineers that could repair REM equipment will be placed at an unfair dis-advantage of the steaming costs associated to travel to mainland ports, especially during periods of adverse weather conditions." [Organisation, Fishing Organisation]

4.8. The reasoning provided by some respondents for vessel operators to cover maintenance and repair costs was varied:

"As a general principle it is likely that there will be a need for some government support in the set-up phase, but that replacement of technology should fall to operators as this will disincentivise intentional damage to technology at sea." [Individual]

"[We] anticipate that there will be some objections to paying the costs associated with REM - both upfront and ongoing costs - among fishing vessel owners, particularly those who view REM as being purely for enforcement purposes. However, given that REM provides significant scientific and compliance benefits, and that fish stocks are a publicly owned resource, the costs of REM, should be borne by the vessel owners, rather than by the public.

[We] recognises that the costs (especially upfront costs) could be burdensome so there is a case for some directed public financial support. One benefit of such support could be that it would speed up installation of REM. However, [we] believes that ongoing costs, and any replacement equipment, should be covered by fishermen without support." [Organisation, Conservation]

Uneven Impacts

4.9. When discussing the need for funding assistance, various responses acknowledged that different fleet segments and differently sized fishing operations could be impacted in different ways in relation to meeting the costs of REM. In particular, that those barriers could be more acutely felt by smaller vessels. When it came to differences among fleet segments, various respondents argued that given pelagic vessels already have extensive monitoring equipment onboard any additional costs should be covered by the government. Demersal vessels tended to be discussed in the context of the challenges being faced by the industry, suggesting they could struggle with the costs. Finally, in the few instances scallop vessels were specifically mentioned, there was disagreement on whether or not costs would be easily met.

"Pelagic vessels have an extensive system of monitoring equipment fitted in most working areas of the vessel. Any additional REM equipment required that is in addition to the vessel's system should be grant funded by Scottish Government." [Organisation, Fishing Organisation]

"The costs as detailed in the consultation document should not impose a significant burden on scallop vessels." [Organisation, Fishing Organisation]

"The upfront costs will be hard to meet for scallop vessels, especially with the high fuel prices. The current scallop vessels with REM are happy to have it on but it was free for them." [Organisation, Fishing Organisation]

4.10. More broadly, it was acknowledged that smaller fishing operations could struggle to fund the installation and running costs of REM:

"but funding should be provided for smaller companies if costs are prohibitive, and loan schemes for larger organisations" [Organisation, Fishing Organisation]

"Purchase, installation and running costs are significant, especially for the smaller operators. Grant funding should be available wherever possible. This will improve user support for REM." [Organisation, Conservation]

Wider Points

4.11. Of the minority that did not foresee cost barriers, very few provided reasoning in the open answers

4.12. Finally, several responses stated that they struggled to answer the question as they didn't think they had enough information, or posed their own questions for more detailed costing in their open responses, for instance:

"The [organisation] questions whether the costs outlined reflects the full cost of retro-fitting REM equipment and all the necessary wiring to large and complex pelagic vessels. Who would bear the costs of any damage done to the vessel or its equipment as a consequence of REM installation?" [Organisation, Fishing Organisation]