NWWAC raises concerns with DEFRA over implementation of REM

Given its role as legitimate EU fisheries stakeholder body and the geographical remit of its work, the NWWAC prepared the following position paper in response to the consultation.

In its analysis of the consultation, the NWWAC raises a number of serious concerns regarding the objectives of the REM and what approach the UK will be using to implement it. The NWWAC also concerns about the standardisation of REM use. In the UK , the government in Westminster has left it to the Scottish government to implement REM there but have asked whether there will be a standardisation of REM between the UK nations and the EU, rather than forcing vessels to change equipment and systems in each area.

It also raises the question of procurement and ownership. The NWWAC asks questions in regard to data transfer, analysis and storage and regarding equipment control.

The NWWAC response is laid out below:

General remarks

Before addressing the main points of this consultation, the NWWAC wishes to make a few general remarks.

• The NWWAC highlights the need for a certain degree of harmony in managing fisheries between the European and UK waters. Vessels active in the North Wester Waters often fish in both areas. Having two diverging systems to comply with when crossing the border between EU and UK waters represents a great concern and would create unbearable difficulties for fishers. The NWWAC urges both parties to address this aspect as a matter of priority and strive for cohesive and harmonised management systems.
• As mentioned above, several consultations have been launched by DEFRA since July 17 with a duration between 11 and 12 weeks. These consultations were launched in the middle of the summer period, where most of the people were on leave, and will close early after the beginning of the school year, which leaves a very short time to read all the related documentation. This is especially more difficult for stakeholder organisations such as Advisory Council, where certain consultation procedures need to be followed in order to meaningfully engage members and reach consensus on a position. Overall, the NWWAC acknowledges that the duration of the consultations is reasonable, but feels that setting up these consultations at this time of the year is not cooperative with stakeholders.
• As control is a major common aspect, the NWWAC emphasizes the great need to link this fishery management plan to the landing obligation.

REM objectives and approach

The purpose of this Fishery Management Plan is to achieve fully documented fisheries across all fishing activities in English waters. According to the DEFRA, REM is a complex and challenging technology that will help to achieve this goal but is not a complete solution.

The NWWAC would like to point out that REM is promoted in this consultation as of great scientific interest, with the possibility to gather data for ICES stock assessment, whereas it will mainly be a compliance device within the first years of implementation.

It is then explained that REM system will be tailored to each priority fisheries depending on the consultation targets and may include some of the following integrated on-board systems: cameras, gear sensors, video storage, satellite modem and GPS system. The NWWAC would like to point out that, among the five priority fisheries identified, with different objectives, the presence of a camera onboard seems unavoidable (e.g. catch composition verification, interaction with sensitive species or monitoring discards).

Concerning the approach, it is stated that the implementation will begin with volunteers within the five priority fisheries identified. The NWWAC points out the lack of information on this volunteer part of the process: how many volunteers are needed per fishery? Will there be an equity between the number of volunteers vessels from the UK and the ones from the EU? Will there be advantages for the volunteers? How the trials actually conducted on EU vessels for other programs can be included? Moreover, the timeline seems a bit vague concerning the transition between the trial phase and the mandatory phase: it is stated that there will be a minimum 24-month period to ensure industry has time to adapt to change before mandatory requirements are introduced, but it is not explained how much time will fishermen have to adapt at the maximum.

To finish with, there is a proposal to set up steering groups with volunteers (early adopters), as well as with other fishers, scientists, fisheries managers and technical experts to create REM programs. The NWWAC would like to know how EU flagged vessels will be able to get involved in those groups, as well as scientists, fisheries managers and tech experts from the EU. Will there be a representative proportion of UK-EU representants in those steering groups?

The NWWAC recalls the importance of having a proportionate, achievable and pragmatic expansion of REM within UK and EU waters.

Standardization of REM use

It is stated in the proposal that fisheries monitoring is devolved. The Scottish Government is progressing plans to implement REM in their waters (with a primary focus on the scallop fleet and pelagic vessels) that will be out soon. As plans by the English Government have already been released, the NWWAC wonders how they will ensure interoperability at the United Kingdom (UK) level. It is noted in the consultation that the UK wishes to be the vanguard of REM in their waters and the waters with shared stocks. As REM are considered at the EU level in the new revision of the fisheries control regulation, the NWWAC would like to know how UK intends to proceed. The NWWAC wants to recall the importance of having standardized systems in English, Scottish and European waters to prevent vessels with an extensive work area to change equipment and systems in each area, and to avoid additional costs. To this end, the NWWAC advises to conduct UK/EU steering groups regarding REM evolution.

Procurement and ownership

Concerning the procurement of the REM system, it is noted in the consultation that three options are discussed. In the single operator model, it is clearly explained that all English vessels operate the same equipement. The NWWAC would then like to know if, when the single operator model is approved, the equipment chosen will also apply to EU vessels entering UK waters. In general terms, the NWWAC emphasizes the need to have a uniformity in the REM approach between the EU fisheries control regulation, the DEFRA fishery management plan and the one from Scotland that will be released soon. As it is a matter of control, will the UK have access directly to EU vessels data? Or will they have to ask data to each vessel’s Member State?

The NWWAC would like to raise awareness concerning data ownership (especially videos). If fishers will purchase and own the system required, the NWWAC emphazises the importance of the skipper owning the data captured aboard his/her vessel, in order to prevent datarequest and obtention by anyone. Is it noted in the consultation that onboard cameras will be installed to monitor only areas of a vessel associated with fishing-related activities. As fishers tends to work in those areas, the NWWAC wishes to point out the necessity that videos taken are processed with a face blurring system to protect their image rights.

Data transfer, analysis and storage

There are currently several method of data transfer. The NWWAC would like to know which ones are considered. Since the consultation documents are unclear about this, the NWWAC is asking for more information and requirements concerning the organisms in charge of the analysis. Moreover, control issues are a matter of state, so each vessel’s data should be analysed by its country.

All of these methods are costly and need some logistics. The NWWAC emphasizes the need for a thorough reflection on the precise method that is going to be employed to best suit each type of priority fishery targeted, minimize costs and facilitate logistics, but also on who will be in charge of these expenses.

As the videos will represent a large amount of data, and might require a large number of analysts, the NWWAC would like to point out the need of qualified analysts with a degree in marine biology. It is essential here to prioritize quality over quantity.

The NWWAC acknowledges that no mention of artificial intelligence is made through the consultation document concerning data analysis, and wonders if this technology will be considered in the future.

The NWWAC perceives a significative lack of clarity concerning the intended use of REM data and is asking for more inputs on the validity and conservation of the data.

Equipment control

The consultation document does not give any information on the measures planned for future monitoring and control of REM requirements, once the mandatory phase is in place. The NWWAC members fear that some small unintentional infringement can lead to punitive action. For example, if the technology is faulty before leaving port, the vessel could be prevented from going out to fish. The NWWAC emphasizes that REM technology should be brought in with the understanding of the complexities of the industry