Enhancing sustainable fisheries management - Remote Electronic Monitoring

MNWFA have two considerations to make. The first is that a great amount of planning must take place prior to introducing REM into complex mixed fisheries such as the offshore whitefish and mixed fleet segments. With regard to what our members view as a logical sequence, it will be both necessary and important to have a suitable catching policy embedded well ahead of the introduction of REM.
If introduced, MNWFA members hold the position that the use of REM should be applied across all fishing vessels, irrelevant of flag, fishing the same area for the same stocks. In that respect, we take the position that the use of REM should not apply outside Scottish waters if it delivers a departure from this level playing field.

Our members believe that both the purchase and installation costs for REM should be met by government. It is unlikely that a price differential will be gained through the introduction of REM - we have seen very little price differential from MSC certification of several key commercial stocks. As a result, it is unlikely that an improvement in the reputation of the Scottish Fishing industry would financially compensate against the cost incurred.
Whilst the ongoing running costs would seem less onerous it is nevertheless a further cost to the industry at a time when running costs are escalating. The economic stress on a fishing business is currently high and coupled with planned inefficiency as a result of spatial squeeze and displacement, the prognosis for economic viability in the future does not look good, or as good as it should.
In addition, the ongoing commitment to manage our carbon footprint through investment in lighter gears, vessel design and engine efficiency as a result a result of ongoing R and D, will mean less money available for other projects.
On that basis we believe that all costs should be borne by the management authorities.

We make no comment on this issue.

"We make no comment on this issue."

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.

Once again, we feel this is a broader question than it just being focussed on the pelagic sector. MNWFA members believe that the medium to long term focus on the benefits derived from REM should be the scientific element.
Our position regarding the scientific status of a fishing vessel has been made public on many occasions. We view every fishing vessel as being a scientific platform, and as such we should find ways of harvesting the available information that they can provide.
The compliance aspects of REM are, in our members view, a secondary element given that we have the ideal opportunity to create a functional catching policy which will stimulate a culture of compliance.

We have nothing to say regarding the specifics of the pelagic fleet but reiterate our position as set out above that the focus should be on improving scientific information on the stocks.

Whereas we accept that safeguards need to be in place to prevent against gaming, our members hold the view that it would be unreasonable to insist that vessels return to port on the occasion where REM equipment on board fails. For offshore vessels this would be a tiresome obligation and we suggest that in such cases vessels are allowed to complete their trips with the proviso that it must not leave port with defective gear.

We have no comment to make.

We have no issues to raise.

We agree that it makes sense to broadly aligned to existing REM requirements although it is more important to ensure that current regulation relating to REM aligns broadly with any future regulation on the same.

We have nothing to recommend at this time

We have nothing to recommend at this time