The NFFO examines the Fisheries Bill’s requirement of mandatory CCTV cameras on board UK fishing vessels
Remote Electronic Monitoring (REM) has become a dividing subject amongst the fishing community across the UK as the Government looks towards using it as an enforcement tool for new regulations at the end of the Common Fisheries Policy (CFP).
As the Fisheries Bill passes through the House of Lords, amendments have been laid down that would make CCTV cameras aboard all fishing vessels mandatory, the National Federation of Fishermen’s Organisations (NFFO) provides its view.
Remote monitoring using electronic equipment has an important role to play in the future management of UK fisheries. In various forms, it is already widespread in other industries and new applications are developed every year.
Vessels over 12m already carry transponders which provide data on vessel location via satellite when at sea. This is a strong aid to effective monitoring control and enforcement. Likewise, electronic logbooks for vessels over-10 metres in length, and a mobile phone catch-app for under-10m vessels, have strengthened the flow of information necessary for the effective management of our fisheries.
CCTV cameras have been successfully used on a voluntary basis in the UK and Denmark, in projects that provide assurance that catches of cod are kept within permitted limits. Other initiatives using CCTV have been used in a similar way to help scientists understand specific catch patterns and provide more useful advice to fisheries managers. Groundfish fisheries in western Canada are the recognised leaders in the development of CCTV technologies and the use of these new approaches to providing transparency for managers, customers and the general public. Link
Universal Control Measure
Some have argued that these examples of the successful applications of modern technologies in fisheries, should be taken to the next step and made mandatory by requiring CCTV on all fishing vessels whenever they leave harbour. This is problematic from legal, ethical and practical perspectives:
- Put simply, fishermen do not want that level of intrusion into their working lives.
- Fisheries control authorities tend to be split between the authoritarians and those who favour policing by consent. The former favour a tool that could be used remotely under all conditions. The latter, currently in the majority, recognise that the route to high levels of compliance lies through dialogue, shared objectives and resolving the management challenges that underlie most examples of non-compliance. Both groups recognise the dangers of pitting the ingenuity of fishermen against any “infallible” method of monitoring and control. A wise fisheries scientist once said, “There are no technocratic solutions.”
- Legal safeguards for citizens exist to protect privacy, personal data and civil rights. Mandatory, universal, CCTV is regarded as a step too far in a world that already bears an uncomfortable resemblance to George Orwell’s Big Brother in the novel 1984
- The UK has inherited retained EU law on fisheries which still contains many examples of conflicts or contradictions between legal requirements. It will take time for these to be eliminated. For example: which takes precedence – catch composition rules which limit the percentage of a certain species in a vessel’s catch, or the landing obligation which requires all quota species must be landed? CCTV would only amplify this regulatory conflict, leaving vessel operators exposed to prosecution whichever option they chose. At the moment this dilemma is managed through pragmatic policing. Cameras would provide solid evidence of repeat infringements day-in and day-out, putting the authorities under pressure to act.
- New technologies generate new challenges. The retrospective detection of repeat area infringements through satellite monitoring have generated not only fines but loss of the licence to fish through accumulated penalty points. The problem here is that the new technology has removed the traditional educative role which effective policing depends on. A warning after the first offence might be all that’s needed, either to dispel ignorance or as a warning shot. Instead, the matter is automatically escalated to the point where fishermen’s livelihoods – both for master/owner and crew are at risk.
All these reasons should give pause for thought before creating a legal obligation to carry functioning CCTV cameras.
The examples where CCTV cameras have been introduced successfully on a voluntary basis are instructive. Most importantly, there is a sequence to be followed:
- Ensure that fleet capacity in the fishery is aligned with available fishing opportunities. Without that balance fishing vessels will struggle to be profitable and legal within their quota allocations
- Ensure that there are no regulatory conflicts of the type described above
- Bring those who are subject to the regulations into the process of policy formulation, and the design and implementation of the management measures for their fisheries. The scope for management plans contained in the Fisheries Bill, would provide the space at the fishery level, to deliver co-management, through which fisheries administrators, fisheries scientists and fishers cooperate in the design and implementation of management measures in specific fisheries
- Bring control authorities (in England, the Marine Management Organisation) into the relevant co-management structures and the conversations within them. Fishers and control authorities have a deep shared interest in ensuring that fisheries policy and management measures are practical at the vessel level
- Only when the fundamental fisheries management issues in any given fishery have been resolved, should consideration be given to whether the participants in that fishery would benefit from providing outward assurance to fisheries managers, customers and the general public, by installing appropriately located CCTV cameras. This is a choice for participants in each fishery at the right moment, not for legislators, remote from the practical issues involved
Advocating CCTV cameras as a universal panacea, without addressing resolving the underlying fisheries management and compliance issues, is just lazy. CCTV cameras and other forms of remote electronic monitoring have a big future in fisheries, as they do in most other industries. But a mandatory requirement for fishing vessels to carry functioning CCTV equipment is as offensive, provocative and impractical as placing a policeman on every fishing vessel – or in every office or living room.