Association for Professional Observers Electronic Monitoring Position Statement1

June 2021

The Association for Professional Observers (APO) is a non-profit, non-governmental organization dedicated to strengthening fisheries observer programs through advocacy and education. It is our intention that the results of our activities may encourage the recruitment and retention of professional observers to foster the best quality observer data for the purposes of conservation and the responsible management of marine living resources. As such, APO remains firmly committed to the interests of the men and women who serve as observers in various observer programs throughout the world.

APO acknowledges that technological advancements have made Electronic Monitoring (EM), more practical and feasible for fishers and fisheries managers. EM integrates the use of video cameras, gear sensors, and GPS to provide data on fishing methods and gears, compliance to conservation measures, fishing locations and times, and catch and bycatch (including discards). EM may also include systems such as Automatic Identification Systems (AIS), Vessel Monitoring Systems (VMS), electronic measuring boards and callipers, Passive Integrated Transponders (PIT) and PIT tag readers, automated flow scales, motion-compensated scales, or other electronic systems as defined by a particular regulatory authority.

APO’s core responsibility is to the integrity and independence of fisheries monitoring data and we believe that well prepared and supported human observers are able to best serve that function. APO acknowledges that while human observers provide a superior option for the collection of fisheries information, there is widespread consensus that EM as a complementary tool will benefit observers and sustainable fisheries management.

APO believes that EM and Electronic Reporting (ER) can play a role in augmenting and improving existing observer programs. They would provide timely access to observer data for management decisions, deter captains who wish the observer would change their entries and provide for cameras in areas of needed monitoring where it would otherwise be dangerous or impossible for human observers to be present.

The APO nonetheless opposes its exclusive use as an alternative to or replacement for human observers. EM should serve as a complementary tool to the increased deployment of human observers under improved conditions for the latter.

Numerous scientists support the complementary usage of EM in addition to human observers.2 Consensus exists for ER to improve the paper onboard logbooks or reports provided by skipper and Observer. Digitalisation of logbooks, reports and journals, combined with EM installations reduce opportunities for tampering with data provided and when applied appropriately, that is with data instantly being uploaded, enhances quick analysis and rapid reaction capacity for RFMOs.

Nevertheless, there is a need for alignment of data provided by human Observers on board and EM technology. EM standards need to be implemented, lining up data collected by human observers and by EM.3

EM may further be seen as an opportunity to obtain increased observer coverage where it is still needed, in particular in long line fisheries. Observer coverage on purse seine fleets in the ICCAT, WCPFC and IATTC is mandatory on all vessels, but targets for observers’ presence on long line vessels remain very low at a 5% level for WCPFC and IATTC, to name two examples, while even the 5% observer coverage is not met in reality.4

Low levels of observer coverage create a convincing case for supplementing human observers with EM, as acknowledged by regional fisheries bodies, such as the WCPFC,5 where the technology has partially been implemented.6

In the WCPFC alone “78% of the longline fields can [could] be collected with current EM technology, with 84% of these used in scientific analyses. For the 16% of fields not routinely used in scientific analyses, the introduction of EM may facilitate a sufficient increase in data availability to support their future use.”7 A holistic and integrated use of EM in future research and monitoring programmes in global longline fisheries is advisable.8

However, it is crucial not to disregard shortcomings of EM, stressing the importance of using technology to complement human monitoring, not to replace it, such as:

  1. EM is deficient in identifying species that require close inspection, may not be brought on board, or that are otherwise not viewable in the camera’s visual frame; Nor can EM collect biological samples needed for stock assessments, effectively assess or assign injuries and mortalities to species/stocks, or collect biological data from tagged specimens.
  2. Observers can provide advice to fishing vessel operators to prevent a violation before it occurs.
  3. EM systems can be turned off, tampered with or otherwise prevented from collecting the necessary data, whereas an observer can report on obstruction and be cross-examined or interviewed.
  4. The length of time required to obtain and review video and extract all requisite information can be excessive with EM.
  5. Details regarding data aggregation and public access to the data remain unresolved.
  6. Most critical information on MCS or Illegal, Unreported and Unregulated (IUU) issues provided by observers is gathered through observations, conversation and opinions that are recorded in the observers’ field journals. Without actual observers on board, it may be difficult to verify allegations of compliance violations observed on camera or through other electronic means.
  7. EM cannot report on human rights abuses and injuries in places outside the view of the camera, such as in cabins or the galley.
  8. Observers play a critical role in identifying IUU practices of other vessels in the same area with the use of binoculars, which is currently not planned for when using EM exclusively.

Conclusion

Any implementation of EM should be made according to a robust, third party analysis subject to public review and comment as well as, in all cases, be subject to review and validation by human observers. Moreover, seasoned observers, with a history of proven quality data collection, must be included in any design, review, or analysis of any proposed or existing EM system.

Observers are uniquely qualified to examine the necessary components of their duties and are invaluable in understanding specific duties where EM could be complementary. Most importantly, any fishery that engages EM must use qualified, seasoned observers in the review of any data, such as video imaging to ensure that the quality and integrity of data collection is maintained at a high level.

We note that some advocates of EM in the fishing industry claim that fishers can perform the scientific duties that cameras cannot and respond that the modern observer programs were established because the fishing industry proved unreliable in collecting exactly this information.

The independence and objectivity of the observer is paramount to achieving the quality, objectivity, integrity, and utility of information necessary for use in fisheries decision-making processes. APO affirms that observer programs must maintain complete transparency and independence from the fisheries that are monitored.

In conclusion the APO opposes the exclusive use of EM and ER as an alternative to or replacement for human observers. EM should serve as a complementary tool to the increased and improved deployment of human observers and increased observer coverage.

1 Old statement from 2015: Electronic Monitoring Position Statement April 2015
2 see: Timothy Emery et al., “The Use of Electronic Monitoring within Tuna Longline Fisheries: Implications for International Data Collection, Analysis and Reporting,” Reviews in Fish Biology and Fisheries, August 29, 2018, https://doi.org/10.1007/s11160-018-9533-2.
3 see also: HRAS, “DEVELOPING RECOMMENDATIONS & POLICY IN SUPPORT OF FISHERIES OBSERVERS’ SAFETY, SECURITY & WELL-BEING” (Havant, 2020).
4 see also: HRAS.
5 WCPFC, “Electronic Reporting | WCPFC,” WCPFC, 2019, https://www.wcpfc.int/electronic-reporting.
6 WCPFC, “Annual Report on the Performance of the E-Reporting Standards and Their Application | WCPFC,” WCPFC, 2019, https://www.wcpfc.int/doc/wcpfc-tcc15-2019-rp10/annual-report-performance-e-reporting-standards-and-their-application.
7 Emery et al., “The Use of Electronic Monitoring within Tuna Longline Fisheries: Implications for International Data Collection, Analysis and Reporting.”
8 Emery et al.