Marine resources - ensuring long term sustainability: remote electronic monitoring (REM) consultation

3. Pelagic vessels (RSW and freezer vessels)

3.1 Overview of Proposal

As set out in the Fisheries Management Strategy, Scottish Ministers intend to introduce legislation to the Scottish Parliament making it a legal requirement that all pelagic vessels licenced to fish within Scottish waters (The Scottish Zone) will have a fully operational REM system installed on board. As noted above, pelagic vessels are defined as Refrigerated Sea Water /Chilled Sea Water (RSW/CSW) and freezer vessels, over 12 metres, fishing for small pelagics and blue whiting. The requirement to have an REM system on-board which complies with Scottish Government legislation will extend to all Scottish vessels, as well as other pelagic vessels from outside Scotland, fishing in Scottish waters.

The latest data from 2020 shows there were 22 vessels in the Scottish pelagic fleet, and around 155 non-Scottish vessels fishing for pelagic species in the Scottish Zone (though not necessarily landing in Scottish ports). The main species caught are mackerel, horse mackerel, herring and blue whiting, with the catching season running from late summer to February, depending on species.

Question 3: Are you aware of any issues we need to take account of when we apply REM across all pelagic fishing fleets fishing in Scottish waters on a level playing field basis? If so, please provide details

Question 4: do you agree with the definition of pelagic vessels provided and are there any unintended consequences from using this definition?

3.2 Timeline

Unlike scallop dredge REM, using REM on pelagic vessels in Scottish waters is a new concept. Pelagic REM can be a complex system which requires sufficient lead-in time to support implementation across all vessels. Vessels will need to source, procure and install REM systems which meet the parameters required in legislation. This process will understandably take time, and for that reason, the lead-in period will allow for systems to be installed and operational by a specific date.

Taking into account the complexities around implementation of REM, we recognise that a lead-in time will be useful for vessels to enable them to properly kit out their vessels prior to the mandatory requirement to have REM on-board taking effect. Given the actions involved in the manufacture, purchase and installation of REM to a number of vessels at the same time, we propose that this lead-in time could be around 12 months.

Question 5: how much lead-in time should pelagic industry be given to prepare for compliance with the mandatory REM requirement?

3.3 The benefits of REM in the pelagic sector

There are significant scientific and compliance benefits from having REM on board pelagic vessels, along with the general benefits around marketability and demonstrating sustainability, as indicted in the sections above.

For science, REM can provide additional verification that data collected via scientific programmes is valid. This would allow a REM system to confirm that what is being caught (species, volume, sizes) is the same as what is being landed. To have certainty over the current landings data, it is important to know that no slipping or discarding is taking place. Having this certainty will result in significantly improved input data into stock assessments. In addition, access to additional data gathered by pelagic vessels as they subsample their catch at regular intervals, particularly to confirm individual fish length and weight data, will significantly add to the data set available to scientists, and hence improve the reliability and resilience of scientific stock assessments and advice.

For compliance purposes, REM provides a system to demonstrate compliance with relevant legislation. In the case of pelagic vessels this is mainly the landing obligation, but also includes legislation on high grading, slipping of catch, and misreporting (all of which is legislation designed to support the sustainability of fishing activities). To do this the REM system needs to be able to confirm how much the vessel has caught and how much the vessel has landed. These two pieces of data will deliver confidence that what has been caught has been retained.

The introduction of the landing obligation in 2015 was intended to end the wasteful practice of discarding fish at sea and, along with it, also address associated issues with slipping and high-grading. There is limited evidence that the landing obligation has been successful in its primary objective: rather, there is evidence that discarding/ slipping and high-grading continues within the fleet. By high-grading we mean selecting out the most profitable fish from a catch, and discarding those which are less profitable – a practice which has been illegal since 2009. By slipping, we mean fish caught in a net and released into the sea without being brought on board the vessel. By misreporting we mean vessels intentionally reporting catch in one area when it has been caught elsewhere – in breach of existing legislation.

Without enhanced surveillance and monitoring at sea it is difficult to see how such practices can be effectively deterred or appropriate enforcement action taken.

Currently, Marine Scotland's compliance priorities are determined on a risk basis. This includes activities such as boardings and visits to fish markets and processing factories. Activity at sea is monitored remotely and through boardings undertaken by Marine Protection Vessels (MPVs) and using aircraft surveillance. The practice of discarding is unlikely to happen when an MPV is known to be in the area acting as a deterrent. However, existing resources cannot cover all of the sea, all of the time.

Pelagic vessels are capable of catching large quantities of fish within short periods of time. The scale of waste, should discarding occur, is therefore significant. The introduction of REM to the pelagic fishing fleet should deliver confidence that discarding no longer takes place in this high-volume, high-profit fleet segment.

Question 6: Do you agree with the scientific and compliance benefits of REM for the pelagic fleet as set out in this document? Are there other benefits which you can consider, including to industry, the environment, or local communities?

3.4 The REM System

3.4.1 System requirements

In order to deliver the optimal level of benefits set out in section 2.3, we are seeking for REM systems, coupled with existing monitoring systems, to be able provide the following information:

• 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

In our view, this information can best be captured using a camera system to cover the various stages of the fishing operation, and by supplementing this with sensor data as needed to capture the information needed for both compliance and scientific purposes.

In addition to using cameras, we think there is considerable benefit to be gained from having access to net sensor data, which some pelagic vessels will already have on board. Access to net sensor data would provide an increased confidence level for both science and compliance purposes, to verify that what is caught in the net is retained and landed (with a comparison possible with landing data). However, we understand that this technology may not be available on-board all pelagic vessels and that there would be costs associated with requiring its presence above and beyond the costs already identified within the costs section above. This might mean a significant change in proposed costs – i.e. whether we can utilise existing sensors, or if new sensors would need to be installed. We are therefore seeking views on whether this is required at this point.

3.4.2 System specification

We propose that the REM system on-board a pelagic vessel should, as a minimum, 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 amount 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.

Question 7: do you agree that the system as outlined in this section should be able to meet the benefits described in Section 3.3? For clarity, these are summarised as follows:

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

Question 8: do you foresee any specific operational problems with the system specification set out within the document? If yes, what?

Question 9: do you believe that we should require net sensor data as part of the system specification at this point?