Every Electronic Monitoring (EM) program has different management goals, species to account for, and politics to navigate. In most cases, the impacts of the design decisions cannot be compared across EM programs. However, the multi-species groundfish fisheries in New England and the Pacific have more in common than most programs. This overview discusses how each region addressed some of the main issues that any EM program faces, such as stakeholder engagement approaches, field testing, video review, and regulation development. We want to take an honest look at the implications of different design choices in similar US fisheries.
Program origins and status
Pacific
In the 1990s, the West Coast Groundfish trawl fishery was in decline. Both participation and catch were decreasing, a number of stocks were overfished, and in 2000, the fishery was declared a federal disaster. To try to protect overfished species and rebuild the fishery, the Pacific Fishery Management Council (PFMC) implemented recovery measures, including spatial closures and strict bi-monthly trip limits. Trip limits were effective at limiting landings. However, they also led to significant discarding at sea, which undermined their value. To address this, in 2011, the fishery transitioned to an individual fishing quota (IFQ) program with 100% at-sea monitoring. Fishermen were required to use logbooks to report all fish retained and discarded on each trip. Onboard human observers verified those discards and shoreside Catch Monitors (CMs) accounted for retained catch during offloads. Vessels were required to contract with approved observer companies, and first receivers were required to contract with approved CMs for offloads. As of 2015, the fishing industry has been responsible for paying for all costs associated with observers.
Twelve years later, the IFQ program is largely seen as successful from an ecological perspective. It has resulted in a dramatic decline in discards and contributed to the rebuilding of 9 out of 10 overfished stocks. However, from an economic perspective, the financial burden associated with monitoring threatens to drive smaller operations out of business. The average daily cost for an at-sea observer is estimated to be above $500, and fishing trips tend to last between two and five days. Based on NMFS’s Economic Data Collection program information, observer costs represent 30-60% of an average vessel’s net revenue. There is also a significant logistical burden associated with human observers/monitors regarding vessel capacity, trip planning, and limited availability in smaller ports. Not only do high monitoring costs threaten the long-term viability of the IFQ program, they also represent a significant barrier to the development of more accountable management regimes in other fisheries on the West Coast and beyond.
In response, PFMC, NMFS, and stakeholders have dedicated significant effort to developing a cost-effective EM program to help reduce these burdens. After a decade of testing and design work, regulations allowing for fleetwide use of EM went into effect in January 2024.
New England
Much like in the Pacific, the New England groundfish fishery underwent a period of significant overfishing in the 1990s and early 2000s. In an effort to rebuild stocks, the New England Fishery Management Council (NEFMC) sequentially reduced the number of days fishermen were allowed to fish and their trip limits. However, these effort controls were only marginally effective, as any benefits were largely offset by an increase in at-sea discarding. The restrictions also had severe economic impacts on coastal communities. In response, the Council transitioned the fishery to a catch share program in 2010 under Amendment 16 to the FMP after a long and controversial design process. A key component of the program was that onboard observers would monitor discards to increase accountability and stay within annual catch limits. However, the NEFMC initially set observer coverage rates at 40% which soon declined to 15-25%, which sharply contrasted with the 100% coverage rate adopted in the Pacific. At the time of the catch share’s implementation, setting the human observer coverage rate at 100% would not have been politically feasible, but these low rates have impacted sustainability. Managers assumed that the fishing behavior and activity on monitored and unmonitored trips were the same (later analysis showed this assumption to be flawed). Based on landing data, the fishery only exceeded the Annual Catch Limit (ACL) for individual species in the groundfish complex three times since the catch share was implemented. However, the ACLs have likely been exceeded more often, as the fishery has not had sufficient monitoring to accurately account for the overall catch. Some fishermen bemoaned the illegal discarding by other fishermen around them and became advocates for greater accountability.
In 2012 the New England groundfish fishery was declared a disaster after a new assessment of the iconic Gulf of Maine cod stock showed a sharp decline, which would lead to near 80% quota cuts.
Amendment 23 to the New England Multispecies Fishery Management Plan sought to address this by increasing the target monitoring rate to 100%. Implemented in 2023, the Amendment allows fishermen to either carry a human observer or at-sea monitor, or use EM. While accountability has dramatically increased, EM adoption has been relatively slow. This is in part because monitoring costs have been covered by Congressional appropriations almost continuously since 2010. So while observers are still a logistical burden for New England fishermen, they are not a significant financial constraint in the way they are for fishermen on the West Coast. This means there are fewer incentives for fishermen to switch to EM, with less than 20% of the fleet currently choosing cameras over human observers.
Early testing
Pacific
An NGO and industry coalition began exploring using EM as an alternative to human observers through an Exempted Fishing Permit (EFP) in 2013. Between 2015-2023, more than 50 groundfish vessels operated with EM on the West Coast under a range of EFPs. The Pacific States Marine Fisheries Commission (PSMFC) conducted video review, and participating vessels followed detailed catch-handling and retention requirements outlined in Vessel Monitoring Plans (VMPs). The purpose of these EFPs was to gain on-the-water experience with EM to inform the development of new regulations, which would eventually allow EM to be a monitoring option for the rest of the fleet.
New England
Despite the lack of cost drivers, the logistical burden of observers incentivized some small boat fishermen in Maine, Cape Cod, and Rhode Island to look for alternatives. This was the basis of a long-term partnership with NGOs and fishermen groups to explore EM through starting in 2013. As in the Pacific, the testing goals were to familiarize fishermen with EM, and to develop best practices on catch handling and review rates that could help inform a broader regulatory program. Government and private funding through the NFWF Electronic Monitoring and Reporting grant program was key to the development of these EM programs. To expand participation, the coalitions were able to secure gear and access incentives from NOAA Fisheries under the EFPs to encourage other vessels to use EM. These incentives included access to closed areas for hook gear, exemptions from tuna gear requirements, and other gear/mesh exemptions. Over time, the scope and scale of testing grew to 31 boats out of a fleet of 180 boats. The experience gained through this phase was instrumental in informing elements of Amendment 23.
Engaging stakeholders in program design
Pacific
Collaboration and regular communication between fishermen, NMFS, PSMFC, and private EM service providers was critical to the success of the EFPs and in navigating design issues. In particular, creating an ad-hoc Council committee called the Groundfish Electronic Monitoring Policy Advisory Committee (GEMPAC) was a key step. The GEMPAC effectively focused the expertise of industry and subject matter experts on critical issues and helped ensure that the program was designed in a cost-effective and practical way. A key contribution of the GEMPAC was the development of the EM Program Manual, which provides the practical details for how the EM program will operate. While engagement with NMFS was generally constructive, on occasions both NGOs and fishermen had to advocate forcefully for clarity, responsiveness, and increased flexibility from the agency. Having the GEMPAC’s voice helped amplify concerns and proposed solutions throughout the development process.
New England
In New England there was an early EM Working group, but it was discontinued and there is no ongoing dedicated Council advisory body focused on the development of EM, and the NEFMC was generally hands-off throughout development. This required NGO and industry partners to engage in more ad-hoc organization and advocacy efforts. This included, hosting a regional EM workshop with the NEFMC in 2014, and regular annual or more frequent meetings with fishermen, NMFS staff, and fishing associations. The goal of these engagements was to facilitate peer-to-peer sharing to address fishermen’s concerns, to encourage broader uptake of EM, and to create a venue for direct conversations with NMFS EM staff leads. Future US EM programs should consider combining these ad hoc peer-to-peer opportunities while also establishing a standing Council stakeholder body to ensure that broad industry expertise is directed towards key program design elements.
Dockside monitoring
Pacific
On the West Coast, human observers often play a dual role. While on the vessel, they monitor discards; when the boat docks and offloads, they can switch roles and become a shore-side Catch Monitor (CM) to validate the first receiver’s report on what was landed. This CM function is a critical part of accountability in the program, ensuring that individual quotas and the fleetwide ACL are not exceeded. While the CM role is critical, the transition to EM meant that vessels would no longer be bringing a third-party observer that could switch to act as a CM for the offloading facility. This means the buyer needs to separately arrange for a CM to be on location during offloading. In some ports, particularly in California, CMs must travel hundreds of miles and are often unavailable to make that trip or arrive at the time of anticipated offload. This has proven to be a serious logistical challenge in certain southern ports. Industry and NGO partners developed a report on the problem and potential solutions and presented it to PFMC. NMFS agreed to let their contracted observers (separate from the third-party accountability observers) work as CMs, and fishing associations have worked to recruit new CMs in their communities. However, this remains an issue and perhaps presents an opportunity for shore-side tech solutions to help serve the function of CM. New EM programs will need to carefully consider the role of dockside monitoring, how the transition to EM may impact their availability, and the effect that can have on program function and accountability.
New England
In New England, as in many fleets, roughly 20% of the boats land nearly 80% of the catch. Initial EM program design efforts focused on the 80% of fishermen who typically operate boats with smaller discard volumes out of smaller ports where dockside monitoring would prove very costly. The first EM model developed by industry and NGO partners is called the ‘audit model’ and was designed to have the crew do additional handling of discards to facilitate the collection of length information, so additional monitoring ashore would not be needed. This model uses EM to validate reported discards under a ‘trust-but-verify’ approach. Captains record the weights of each discarded groundfish species on each trip, and report those in their electronic vessel trip report. The weights calculated from the EM video review data are then compared to the self reported weights.
A second EM program was developed called the “maximized retention” program, or MREM for short. This program was designed to suit vessels with larger catch volumes who usually sail multi-day trips. The EM system is used to confirm that all quota managed groundfish species are retained, while allowing discards of non-quota managed species like skates and dogfish at sea. This program requires a dockside monitor to observe the offload, account for sub-legal sized fish, and conduct a hold inspection after the offload is complete. This program was also approved for use in 2023 by Amendment 23, but due to low enrollment will be suspended in fishing year 2024. Here’s a comparison of the two programs, and here’s a deep dive.
Video reviewer
Pacific
When the EM program was first taking shape in the Pacific, the NGO and fishermen coalition advocated that a variety of EM service providers should be approved to conduct video review. The belief was that if fishermen could choose between providers, it would encourage price competition and innovation. However, after an analysis by PSMFC, it became clear that the overall fleet size was too low to economically support multiple reviewers. The lack of sufficient business for each would equate to prohibitively high review costs. Additionally, PSMFC was already in the position of a main data manager for the fishery with existing relationships, protocols, and communication channels with NMFS. PSMFC also does not have the profit goals of a private company, so should be more cost-effective. As a result, the coalition changed course and advocated to make PSMFC the sole reviewer. However, there were barriers to this without changing federal regulations. NMFS proposed having PSMFC apply to be a third-party provider, however, PSMFC had concerns about being paid directly by industry and still maintaining its integrity as an independent institution. This was partially addressed by PSMFC, who proposed an industry billing framework involving an escrow provider. Additionally, the GEMPAC drafted a revised version of the EM Provider Manual to streamline the program guidelines provided to third-party EM providers and ensure they were aligned with the kind of skills, capacities, and experience that PSMFC had demonstrated during the EFPs.
New England
In New England, nine third-party service providers are currently approved by NMFS to provide both EM hardware and to deliver video review data back to NMFS, although not all providers currently have contracts with vessels. This creates ample competition in the EM marketplace, which could help drive down costs in the long term, but also reduces economies of scale for each EM company, and adds some complexity for regulators who are working with the systems and practices of multiple providers. Other EM programs will want to carefully consider program design decisions, including choosing options on the spectrum between services provided by third-party providers versus services provided by the government.
Video review rates
Pacific
During the EFPs, 100% of the video from each trip was reviewed by PSMFC. This helped provide accountability assurance during testing but also drove up program costs. To reduce costs while maintaining accountability, the industry and NGO coalition advocated for (and got PFMC to recommend) a more efficient approach to video review. Depending on the sector and the vessel’s retention plan, program guidelines set video review rates at a random selection of 10% of hauls of each trip. This makes a critical difference for bottom trawl vessels, reducing the review cost from $246 per day (when the review was at 100%) to $47 per day.
New England
As in the Pacific, the EM service providers initially reviewed 100% of the video. However, to reduce costs, industry and NGOs worked with the agency and their statisticians to develop a pathway for strategically reducing review rates. Now, the target review rate for a vessel new to the program is 50% of the trips. Once the vessel has been in the program for two years and has a compliance record, the review rate is reduced to 35% of trips. In 2019 a detailed look at current and projected EM costs was presented to the Council which highlighted the cost implications of video review rates. The Pacific example shows that there may be room to further reduce video review rates for additional cost savings. Additionally EM providers and NGOs in the region are working to make use of A.I. to speed video review and bring down costs further.
As other EM programs are initiated, it’s critical to identify management objectives, set clear data requirements, and use those to determine how much review is necessary and reasonable to meet those objectives. Developing a clear pathway to responsibly reducing cost should also be identified early on as an essential element of program design.
Secondary review
Pacific
To ensure that video review is carried out properly by PSMFC, NMFS concluded it needed to audit a portion of the EM video PSMFC reviews. This secondary review has the potential to significantly increase program costs depending on the extent and efficiency of that review. These costs should normally be the agency’s responsibility under the EM Cost Allocation Policy Directive, however, in a catch share program, the agency has determined that it may charge some of these costs to the industry. The secondary review rate is not specified in regulation or the Pacific’s EM Program Manual. Over the long term, it is unclear what percentage of the video will be reviewed and what that will cost. Additionally, when the agency conducts video review itself, the video becomes a federal record pursuant to a 2022 policy directive, which triggers longer archival storage requirements and incurs further costs. NGO and industry partners are advocating for NMFS to develop national guidelines regarding secondary review to help ensure that it is used consistently across programs and in a way that does not incur unnecessary storage and program costs.
New England
NMFS has conducted secondary review in New England since the EFP days to ensure third-party EM providers are adequately reviewing videos. For many years, NMFS conducted secondary review on nearly 100% of the video reviewed by EM providers to learn what EM could and could not reliably do. That rate has reduced over time but is still approximately 50%. It is difficult to quantify the cost of secondary review, but it may be as high or higher than the primary review costs. However, since fishermen do not pay for these Agency costs (as they do in the Pacific under cost recovery), there is little visibility on the NMFS cost breakdown.
Catch handling
Pacific
How catch is handled on deck can facilitate review and reduce costs. At the same time, catch handling requirements also have the potential to significantly increase sorting times in a multi-species fishery and can mean more work for the crew. Balancing these competing needs is essential and requires some flexibility to account for differences in catch across regions and target species. In the Pacific, fishermen can choose different retention schemes based on what works best for their operation. Industry and NGO partners collaborated to develop catch handling protocols that meet review requirements and reduce video review time. The work carried out during the EFP phase was instrumental in shaping these protocols described in the Vessel Monitoring Plan Guidelines.
New England
In New England, catch handling has been a more significant challenge. A principal issue during EFP testing was the need to modify catch handling on vessels with higher discards at particular times. In short, putting every fish on a measuring strip was too time-consuming for many fishermen. NGO and academic researchers were able to develop and pilot a subsampling scheme with the agency. Now, vessels measure the first 20 individual fish of each species in each tow/haul and then just count the remainder. The average length of the 20 is then applied to the overall count. There has been work to enable the use of a volumetric approach where discard amounts can be estimated by the basket (a common observer method), but that is still in the testing phase. The complete protocols for EM video reviewers and tech specs for data delivery are here.
What is known as ‘operational discards’ have also been a challenge. With EM, NMFS could see things happen on deck that human observers either could not see, or did not record, such as fish accidentally falling off the back of the boat, or out of the gear. The Agency initially concluded that every fish should be counted even if the fisherman took no action to cause the discards. In time there was a reconsideration of this approach and EM reviewers spent far less time counting operational discards, which helped reduce video review costs. Additionally, fishermen were initially required to perform EM catch handling protocols on trips when a biological observer was on the boat collecting all the required discard data so the video would never be reviewed. This was sufficiently frustrating that some fishermen left the EM program. The agency has now dropped that requirement.
As other EM programs are developed it is essential to include sufficient opportunity for field testing with fishermen to design catch handling protocols that are workable on deck and work with available technology. Additionally, as catch-handling protocols and discarding species often need to be refined over time, they should be included in program guidance documents instead of in regulation to preserve flexibility as management needs and technological capabilities change over time.
How much detail to include in regulations
EM design efforts in both regions have demonstrated the importance of preserving sufficient regulation flexibility. Taking a standards-based approach is critical to allow for technological innovation. Additionally, many implementation details (such as catch handling as discussed above) will likely evolve and need to be refined over time. Including details like these in a program implementation manual that is endorsed by the agency – rather than regulations – provides both clarity and flexibility. The development of these details is also an opportunity to work closely with fishermen on a workable program design. In addition to details on catch handling, program manuals and guidance documents can describe specifics on technical support requirements, timelines for providing feedback to vessels on the quality of their EM data, and provider data retention requirements. Designers of new EM programs in other fisheries should review the guidance documents in the Pacific and New England early in their conception and testing phase to understand the granularity of issues that will arise during implementation and to begin to consider what should be trialed at sea and explored with partners and managers.
Incentives to participate
Pacific
Fishermen frequently see the largest EM benefit when they are already struggling under the cost burden of 100% industry-funded human observer coverage. The number of federal fisheries where these conditions exist is very limited. In the absence of new monitoring mandates or alternative incentives for EM, national uptake of EM will be slow. For greater national and regional uptake of EM, there should be continued focus on lowering the costs of implementing EM, identifying and creating additional incentives for EM, and directed review and potential revision of NMFS’s EM Cost Allocation Policy.
New England
The percentage of the fleet participating in EM is a key metric for success in New England, but currently, less than 20% of the fleet uses it. It is inefficient for the Agency to run both an at-sea observer program and EM because the administrative costs of supporting both programs are substantial. In addition to the lack of underlying cost drivers in New England, if a vessel chooses to use EM in New England, they are monitored on 100% of their trips. However, if a vessel chooses observers, they currently have about 80% of their trips monitored due to a lack of available observers and a variety of waivers issued by NMFS. Vessels can obtain observer waivers for various reasons, including being on observer companies’ ‘Do Not Sail list’ for being unsafe. If a vessel is on that list, vessels get a waiver and go fishing without accountability. Waivers have a place, but there is a concern that they are currently being used too liberally. These factors make it much harder to enlist fishermen in the EM program.
One of the greatest challenges EM faces is that outside of meeting regulatory requirements, fishermen have limited incentives to use it. The seafood value chain, including certifiers like MSC and Seafood Watch, do not value EM directly, although the new MSC standards may change that. Industry and NGO partners continue to push for for using EM data in assessments and highlighting it as part of marketing efforts that recognize the value of 100% monitoring. It’s true that EM helps support sustainable management, which benefits fishermen over the longer term. However, other EM programs will want to consider how to incentivize using EM through parallel and perhaps more immediate benefits such as increased spatial access, gear options, or market premiums.
Conclusion
If current EM programs are not successful, other fisheries in the US will be reluctant to adopt EM. Because while it’s possible to create enabling policies at the national level, it’s very hard to mandate broader use of EM without regional success and organic interest. Regulatory implementation in both the Pacific and New England is still in the early stages, and much remains to be seen in how well the programs perform over time. Nevertheless, they offer a decade of design and field experience demonstrating how EM can be a cost-effective means of ensuring accountability, even in challenging multi-species trawl fisheries. Additionally, the design processes in both regions illustrate the power of long-term NGO, government, and industry collaboration to identify workable solutions and advance them through the decision-making process. However, both programs also underscore the fundamental need for the right incentives and the reality that there are only a few fisheries in the U.S. where they are currently in place. The cost will continue to come down, but to catalyze greater uptake of EM, there may need to be a greater emphasis on accountability in fisheries management. With a push for accountability and the right incentives in place, regional success stories and clear national policies can make EM a powerful and widespread monitoring tool.
Huff McGonigal is Principal at Fathom Consulting. Chris McGuire is Ocean Program Director in Massachusetts with The Nature Conservancy.
