Marine resources – remote electronic monitoring: consultation analysis

Analysis of public consultation on remote electronic monitoring (REM) as part of ensuring the long term sustainability of marine resources.

6. Timeline (Q5)

Q5: How much lead-in time should pelagic industry be given to prepare for compliance with the mandatory REM requirement? - Please provide details in the text box below

6.1. The consultation asked respondents to consider the appropriate lead-in time to allow the pelagic industry time to prepare for compliance with the mandatory REM requirement.

6.2. It is noted that unlike scallop dredge REM, using REM on pelagic vessels in Scottish waters is a new concept. The consultation document notes that pelagic REM is complex and that vessels to which the requirements would apply would need to source, produce, and install REM systems to meet the parameters required in the legislation.

6.3. Taking into account the complexities and the actions involved in the manufacture, purchase and installation of REM, the proposed lead-in time in the consultation document is around 12 months.

6.4. There were differing views among respondents in terms of the lengths of time that was appropriate for the pelagic industry to prepare for compliance with the mandatory REM requirement.

12 months

6.5. Many respondents agreed that 12 months sounded like an appropriate amount of time given the complexity. However, some who felt this was appropriate noted that the legislation would have to be introduced swiftly and that there would need to be consultation with the pelagic industry, non-UK vessels and REM manufacturers in order to enable implementation in this time. It was also noted that the degree of information included in the legislation would need to be sufficient to allow for REM system procurement and that there would have to be some leeway initially in terms of potential extensions.

6.6. The following quotes illustrate some of the views presented among those who felt 12 months was an appropriate amount of time:

"The proposed lead in time of 12 months sounds realistic. Meaningful consultation with the pelagic industry and REM manufacturers will be crucial to enable timely implementation." [Organisation, Third Sector]

"The 12 months proposed appears adequate, however there should be modest allowance for extensions as and when required." [Organisation, Fishing Organisation]

6.7. Others felt that while 12 months was achievable that the Scottish Government should consider looking abroad for lessons learned from systems installed elsewhere in the world.

Less than six months

6.8. A small number of respondents expressed the view that the lead-in time should be less than six months stating that there should be no reason to wait 12 months and that it had already taken too long to arrive at this point.

36 months

6.9. A group of respondents felt that the minimum lead-in time should be 36 months rather than 12 months. The question referred to the pelagic industry, but some responses stated that they felt that the question was generic and with this in mind states that 36 months was reasonable for the following reasons:

  • Complexity of the various fleet segments
  • Current issues within the supply chain for acquiring electronic equipment
  • The need for enhancing the quality of science and to allow for the release of a realistic Future Catching Policy

6.10. The following quote is illustrative of views expressed among those who stated that they felt a 36-month lead in time was necessary:

"Given this question is generic and not just applying to Pelagic vessels we would suggest that each fleet metier, as they are introduced to REM, should be given 36 months lead-in time. Fitting cameras onboard the limited number of pelagic vessels will be a significantly easier task than fitting cameras across other sectors where the number of vessels runs to the hundreds not the tens, as is the case with the pelagic fleet." [Organisation, Fishing Organisation]

Wider points

6.11. Some respondents did not outline a timeline as such and instead stressed the importance of the need to consult with non-UK vessels, time for evaluating REM systems on the market and taking the required time to get the policy right rather than aiming for a specific timeline by which to implement. The following quotes help to illustrate some of these views:

"Discussions with third countries should be undertaken to ensure that whatever systems are used work with each other's regulatory bodies. We would not want the situation whereby we need one system for Scottish waters and another for Norwegian or EU waters." [Organisation, Fishing Organisation]

"The lead-in time should be the same for all vessels and should be sufficient to ensure that all the REM equipment requirements are in place and similar for all UK pelagic vessels." [Organisation, Fishing Organisation]

"The mention of a specific lead-in time in the consultation document (12 months) is perhaps premature, as we have received no indication that non-Scottish fleets have been consulted on what REM systems would be appropriate for their various types of vessel. We suggest that the lead time is defined (and applicable to all vessels, without exception) once the technical specifications for necessarily different REM systems are established." [Organisation, Fishing Organisation]



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