Here's the Math
Since 2012 NC Catch has largely focused its efforts on educating consumers about the value of NC seafood....how to buy it, how to prepare it, how to support it and how to identify it correctly as opposed to imported, farm-raised products.We work with restaurants, chefs, packagers, fishermen, processors, grocers and retailers to try to bring additional value to NC seafood without increasing pressure on the resource.
We've worked hard to promote underutilized species like spiny dogfish (a/k/a cape shark) which is plentiful in NC waters between December and April yet commands about a whopping 14¢ per pound dockside due to lack of domestic demand. (The Brits love it and thus most of it is exported to the U.K. from northeast fisheries). If we can broaden the seafood consumer's palate beyond traditional favorites like flounder, then everyone wins from sea to table.
Prior to November 2016, our next area of focus was going to be heart health, a major problem in NC that wild-caught seafood could play an important and life-saving role in. That spiny dogfish we just referenced...turns out it has one of the highest totals of Omega-3 fatty acids, essential for good heart health, lagging only behind mackerel. The average American has an Omega-3 index of 2. Raising it to 6 decreases the risk of sudden cardiac death by 90%. So we have the ability through increased seafood consumption to alleviate a very costly and tragic problem in our state.
However, our plans to pursue that project were sidelined when a petition for rulemaking was filed seeking far-reaching changes to NC seafood access. The current petition is virtually identical to one filed in 2013 but because the earlier one was filed by an individual citizen, NC Catch did not actively engage in consumer education about the 2013 submission beyond sharing a few social media posts. Ultimately, the 2013 petition was unanimously voted against by every single NCMFC commissioner and the shrimp fisheries management plan was updated in 2015. That FMP called on shrimpers to seek further by-catch reductions by a targeted 40%. A three-year study got underway with on-board observers from NCDMF, NOAA and Sea Grant. In early January 2017, the preliminary results, presented at a public meeting in New Bern, showed a mean reduction of 45% and one more year of testing remains. That's something we believe all stakeholders should find encouraging and improved methods should be adopted based on proven research. (You can link to the researchers' presentations here; we have not edited any of the data).
The current petition for rulemaking is a virtual carbon copy of the 2013 petition but it has now been filed by a non-profit corporation represented by one of the southeast's largest law firms. After reading the 99-page petition for rulemaking more than once we noticed that these two formidable organizations with vast resources had failed to include any economic impact data as required by the NCDMF petition for rulemaking process. http://portal.ncdenr.org/web/mf/petitioning-for-rulemaking That struck us as odd given the financial and staffing resources of the petitioner and their legal counsel. In their press releases and media interviews the petitioners only focused on gear recommendations while avoiding any discussion of the 90-day ban, the prohibition on night-trawling, new tow time limits, etc.
So NC Catch asked two individuals with fisheries backgrounds to separately run the numbers based on annual landing values provided by the NCDMF. The results were, quite frankly, pretty shocking. We put the math into a slide show and posted it online for public viewing. When asked about economic impact at the public hearing in January the petitioners declined to address the math. They neither refuted nor confirmed it. Instead they suggested that the math was not relevant. Relevance is best determined by putting all the facts on the table, not obscuring them, especially in matters regarding a public trust resource and the livelihoods of so many hard-working people.
Things were simpler for NC Catch when we focused our educational efforts solely on how to buy, prepare and identify seafood from our coastal waters. But without access to the resource all of our educational efforts would be for naught. Therefore, we now understand that part of our educational efforts from this point forward must include issues related to access and making sure NC consumers are informed and educated and can therefore be engaged in the process as they so choose.
Here's the Math:
PETITIONER'S REQUEST #1: May 15- Aug 15 Closure Reduction
If you average the weekly catch over 2011-2015 between weeks 20-32 (May 15-Aug 15), and divide that number by the average of weekly landings for the entire year, it comes out to be a reduction of 50.52%.
• Average of weekly landings 2011-2015 (weeks 20-32) = 2,977,022 lbs.
• Average annual landings 2011-2015 = 5,892,368 lbs.
• 2,977,022 lbs. divided by 5,892,368 lbs. = 0.505233569 x 100 = 50.52%
If you take the total landings of 2011-2015 weeks 20-32 (May 15-Aug 15), and divide that number by the total landings for 2011-2015, it is a reduction of 56.47%.
• Total landings 2011-2015 (weeks 20-32) = 16,635,997 lbs.
• Total annual landings 2011-2015 = 29,461,841.24 lbs.
• 16,635,997 lbs. divided by 29,461,841 lbs. = 0.564662517 x 100 = 56.47%
It seems likely that a closure between these dates would equate to an approximate 50-57%, or between 2,977,022 and 3,327,199 lbs., reduction in annual landings. This would be expected to leave an average of between 2,565,169 lbs. and 2,915,346 lbs. to be harvested before any other reductions.
We used 53% in our Catch Math: Shrimp Subtraction video because we wanted to be conservative about the numbers
PETITIONER'S ORIGINAL REQUEST #2: Reduction in fishing days of 56% in ocean waters and 40% in inshore waters
We used 20% in our video based on the original request. Of course, we also made the optimistic assumption that the fishery would be opened back up on August 16 which is obviously not a given. The petitioner later modified the petition to align the reduction request to 40% across the board. Here is the new math.
If looked at as a straight 40% (reduction 3 divided by 5), then the range of additional reduction would be between 1,026,067 lbs. to 1,166,138 lbs. This would be expected to leave an average of between 1,539,101 lbs. and 1,749,207 lbs. to be harvested before any further reductions.
Were we to remake the video we would drop the 20% down to 18%. While the petitioner presented no math, they are quick to make the point that recoupment would occur boosting the initial opening day catch. We would be glad to include their math in our calculations if presented.
PETITIONER'S REQUEST #3: Restriction to harvest only during daylight hours
This part of the math gets more complicated. Pink and brown shrimp are nocturnal. White shrimp are not. Brown shrimp are a summer shrimp and most of their landing reductions would fall under the 90-day ban. The exact definition of the restriction that the petitioner is seeking is also unclear since they didn't define "night." However, sunlight hours listed for Morehead City NC (as a central location) that provide the maximum number of hours (5:23 am to 8:24 pm) = provides a maximum of 15 hours and 1 minute of fishing time. While estimates of harvest occurring only during non-daylight hours vary, many larger vessels continue until approximately 12 am to 1 pm, although a few depending on many variables may choose to work into the night. In the nearshore fishery, vessels predominately work through the night, choosing to avoid the heat, as well as conflicts with recreational fishermen, and other boaters. Normally this might be expected to provide a reduction of approximately 20%; however, the previous reductions would motivate shrimp harvesters to work much later into the night than normal to make up for lost production. The lost potential to work into the night could potentially be looked at as another 50% reduction. Using these very rough approximations results in a range of from the highest of reduction 50% to the lowest remaining harvest of 1,539,101 lbs., leaving approximately 769,550 lbs., and the lowest reduction of 20% to the highest level of remaining harvest of 1,749,207 lbs. to harvest, leaving approximately 1,399,366 lbs. to harvest. Although approximate, this 20%-50 % reduction would range from 307,820 lbs. to 874,603 lbs., and leave between 769,550 lbs. and 1,399,366 lbs. to harvest.
Of the total annual landings that equated to between 5% and 14% of the total but we purposely chose to use 7% to be as conservative as possible.
PETITIONER'S REQUEST #4: Reduction from a 45-minute trawl limit
For this reduction, we will assume the gear is fishing efficiently once in close proximity of the bottom. Take into account that the time it takes between contact with the water and this close proximity will vary, but could average 3 minutes: and the time it takes to haul back and break the surface of the water, which could also vary, but let's use 7 minutes. This allows for approximately 35 minutes of effective fishing time per tow. Considering the previous reductions, but with an unrestricted tow time and returning the gear to the water as soon as the catch is released to cull and there are no problems or interruptions, you have a 15-hour working day, using an average tow time of two hours plus gear drop/haul, you might be expected to make a maximum of 7 tows with 14 hours of effective fishing time.
Assuming you have a 15-hour working day, and are under a 45-minute tow time limit, using the average tow time of 35 minutes plus gear drop/haul from above, you might be expected to make a maximum of 20 tows with 11.67 hours of effective fishing time.
This reduction could provide an approximate 16.80% reduction. With a range of 769,550 lbs. and 1,399,366 lbs. available, this reduction could be expected to further reduce landings between 129,284 lbs. and 235,093 lbs., leaving between 640,266 lbs. and 1,164,272 lbs.
Of the total annual landings that equated to 2% to 3.9% of the total so we purposely chose to use 2% to be as conservative as possible and in the video combined Requests 3 and 4 to arrive at 9% total.
PETITIONER'S REQUEST #5: Reduction from a 60/ct per pound limitation
The petitioner has requested that NCDMF officials continuously sample shrimp count in the Pamlico Sound to determine opening and closure of the shrimp fishery statewide (outside of the 90-day ban from May to August) and not allow the fishery to be open except when the shrimp count is at 60/ct per pound, heads on.
No sufficient literature or data exists to make an estimation so we did not include in the video.
If we had used "worst case scenario" data we could easily have ended up with a 90%-plus reduction but we were not trying to achieve a particular outcome via the math. We just wanted to have all the cards on the table for public examination. Thus the conservative estimate of 82% in the video. The math would have to be recalculated were any one or more of the petitioner's requests to be modified or withdrawn.
This is the very reason why the NCMFC petition for rulemaking process requires economic impact/cost data be included in petition submissions. We would welcome that data from the petitioner.
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