Frequent Questions: Bering Sea Chinook Salmon Bycatch Electronic Monitoring
American Fisheries Act (AFA) and Community Development Quota (CDQ) Bering Sea and Aleutian Islands (BSAI) pollock fisheries electronic monitoring requirements aboard catcher/processors and motherships.
1. If a video system fails, does this end a fishing trip?
Catcher/processors and motherships are prohibited from catching or processing pollock if the video system is not working (50 CFR 679.7(d)(8)(ii)(C)(3) and 50 CFR 679.28(j)). If a video system fails, the vessel must stop the flow of fish past the sorting area until the system can be repaired. Vessels are encouraged to carry enough replacement parts to repair all components of the video system. If the system cannot be repaired, the vessel must cease fishing and contact the NOAA Office of Law Enforcement.
2. Is there a system in place for observers to give a notice of non-compliance to the captain when the video system fails?
Compliance with the requirements for the video system rests with the owner/operator of the vessel. The observers may not know that any particular aspect of the video system is not working. For example, the observer may see images on the screen but not know the system is failing to record and store the information.
If a fault in the system is obvious to the observer, such as no image visible on the monitor, the observer will point that out to vessel management personnel. Observers are responsible for monitoring the activities aboard the vessel, informing the captain of potential violations, and for documenting these potential violations in their logbook. Observers are instructed to inform the captain of potential violations when feasible or document why they did not inform the captain of a potential violation if they did not.
3. What areas of the factory should be covered by the video system? Are cameras required on the trawl deck?
NOAA Fisheries clarified in the final rule that the purpose of the video monitor is to enable the observer to view any area where crew could sort salmon and to view the salmon contained in the storage container. Vessels are required to ensure no salmon of any species pass the observer sample collection point that is identified in their sample station diagram (50 CFR 679.21(c)(2)(i)(D)). Vessels are also required to ensure no sorting of any species occurs prior to the flow scale (50 CFR 679.63(a)(1)). No sorting is allowed on deck; therefore, there is no need for a camera on deck.
4. What is the minimum number of cameras that must be in service at any one time?
There is no minimum or maximum number of cameras required for the video system. The number of cameras required depends on the design of each vessel’s factory. The cameras must be of sufficient number to ensure the video system can see each sorting area, the crew activities in these areas, and see the salmon in the storage container.
5. Do observers have to be able to operate the video system (for playback and general operations)?
No, observers do not need to independently operate the video system. However, if an observer requests to review video footage, they should be assisted in this task by the assigned crew member who is knowledgeable in the video system’s operation (50 CFR 679.28(j)(1)(ix)).
6. What is the role of the Fisheries Monitoring and Analysis (FMA) vessel inspection team in the implementation of Electronic Monitoring Systems (EMS)? Specifically, will they provide outreach and/or offer industry information briefings prior to the inspections?
Fisheries Monitoring and Analysis (FMA) staff will conduct the inspection of the EMS. The FMA staff typically conducts these inspections due to their proximity to the fleet in Seattle and Alaska. Request an inspection through the inspection request form.
Once an inspection is completed, the inspection staff will return to the office and NOAA Fisheries will issue an electronic monitoring system inspection report to the vessel owner if the electronic monitoring system meets the regulatory requirements. This report will be issued on NOAA Fisheries letterhead. If the vessel failed the inspection, a letter will be sent identifying the deficiencies that need to be remedied. We recommend vessels plan their inspections in advance to allow time for inspection reports to be completed and deficiencies, if identified, to be corrected.
Additionally, FMA staff provides courtesy pre-inspections of EMS to help vessels determine the best locations for camera coverage and the salmon storage container. To set up a pre-inspection, contact the FMA vessel inspection team at (206) 526-4007 or firstname.lastname@example.org. FMA staff conducts these pre-inspection activities to assist the industry in complying with the regulations. We have found they facilitate successful inspections. Staff conducting the pre-inspections has practical experience that can facilitate workable EMS and salmon storage container designs. However, as this is a new regulation, the FMA staff is unable to provide interpretive guidance on the regulations without first coordinating with NOAA Fisheries Alaska Region office staff and others. Staff has already conducted pre-inspections of several vessels that will be impacted by Amendment 91.
NOAA Fisheries has conducted outreach with the fishing industry as part of the development of the regulatory package. Our current outreach efforts are focused on the pre-inspection work being conducted by FMA.
7. Are there any other requirements for the container other than the specified volume of 1.5 m³?
Yes, the salmon storage container must be located adjacent to the observer sampling station, allow an observer free and unobstructed access to the salmon, and remain in view of the observer from the observer sampling station (50 CFR 679.21(c)(2)(i)(A)).
8. According to the final rule, the video system must provide sufficient resolution to discern individual fish in the salmon storage container. What is meant by the statement "discern individual fish?"
The cameras and monitor must provide sufficient resolution for a reviewer to recognize each fish inside the salmon storage container as separate and distinct. Thus, the system should have sufficient resolution to differentiate coarse species groups (e.g., a salmon versus a Pacific cod).
9. Will FMA inspectors cross-check the technical specifications of the actual video equipment with those listed on the inspection request form? Is it possible that alternative specifications may be found to be substantially equivalent to those in the final rule?
The FMA inspection team will verify that the technical specifications submitted on the electronic monitoring system inspection request form match the installed video equipment.
The video systems are required to meet the regulations found at 50 CFR 679.28(j)(1). Alternative specifications that do not meet these requirements will not be approved. The regulations allow a wide range of video equipment to be approved.
10. How should salmon be handled on each vessel? Is there any intended standard practice or best practice to allow observers the chance to sample every salmon from every haul? If so, will NOAA Fisheries provide any guidance on "best practice" salmon handling as part of the FMA inspections?
The guidance and standards for handling salmon aboard the catcher/processors and motherships can be found at 50 CFR 679.21(c)(2)(i). These regulations detail how salmon should be handled to ensure that all salmon from every haul can be counted. NOAA Fisheries expects that vessels may meet these requirements in various ways.