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MFC Meeting: Thursday, May 20th. Public Comment

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Rick View Drop Down

Joined: 16 July 2003
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    Posted: 18 May 2021 at 2:48pm
Deadline for sending public written comment is today at 5:00 PM

Deadline to sign-up to speak via webinar is today at 5:00 PM. You will be allowed to speak for 3-minutes on Thursday morning scheduled to start at 9:15. You can speak using WebEx or by dial in on your cell phone.

Links are below for both-

Provide Comments to the Commission

Members of the public who wish to submit comments to the Marine Fisheries Commission may register to speak during the commission meeting or may provide written comment via electronic form or U.S. mail.

Register to Speak

Complete Online Comment Form

Submit Comments by mail:
NC Division of Marine Fisheries
3441 Arendell St.
Morehead City, NC 28557
Attn: MFC Commission Office

Public comment period, including speaker registration, closes Tuesday, May 18, 2021 at 5pm.

Below are my written public comments which I will use part to make 3-minutes of verbal comment on Thursday.

This is the WNCT video referenced in my written comments-


My written comment:

Rules- We hear the commercial industry has too many, at least according to Commissioner Cross’s interview on WNCT-TV last week. Commercial Rules- NC has 336 pages. The reason…no other state from Maine to Texas allows the commercial gears that NC allows spatially or temporally. These are mostly highly destructive gears, all at over-capacity, and unsustainable- estuarine effort using gillnets, long-haul seines, mechanical kicking, dredging, and otter trawls.

You will hear no argument from the recreational sector against reducing the commercial regulation burden by adopting SC, GA, Florida, Alabama, Mississippi, Louisiana, or Texas Rules here in NC.

Estuarine gillnets keep our long-lived species like red drum and striped bass stocks depressed. The occasional good year class of fish, intended to carry the stock for years, disappears when that age class reaches the size and “recruits” to harvest and discards in the large mesh gillnet fisheries. Unsustainable and highly destructive bottom disturbing gears have destroyed SAV and shell bottoms while continued use prevents re-establishment of those critical habitats.

Pick any state from SC to Texas, please, give us those rules. Doing so will help Commissioner Cross reduce the NC Rule Book to a fraction of its current size. The resource will thank you.

You have an opportunity to address shrimp trawling in the current FMP amendment that is underway. This commission must honestly address bycatch. Past commissions have recently promised to do so at least twice. The first promise failed. The 2015 Shrimp FMP Amendment 1 directing the industry to find gear modifications that produced a 40% bycatch reduction did not. The second promise was made at the end of the NCWF Petition for Rulemaking when the division promised to address the issues during the next FMP process- that time is here.

The stocks of Atlantic croaker, spot, weakfish, blue crab, flounders, and many other economically important fin and forage species cannot afford for this commission to kick the can down the road one more time.

The division has certainly provided reasons and excuses in the draft FMP to kick the can- lack of data, fallacies of the ratio method versus CPUE method, unknown effort, etc. The division included that “Gear testing studies should not be used to estimate bycatch”. That comment is specifically aimed at Citizen Science analysis clearly showing the industry bycatch reduction trials failed to accomplish a 40% bycatch reduction as mandated in the 2015 Shrimp FMP Amendment 1. The industry not only did not meet the 40% reduction, but it failed to produce any measurable reduction- zero. The “successful” test gear had a 3.6-to-1 bycatch ratio. Kevin Brown in his 2009 Pamlico Sound shrimp bycatch characterization study found a 3.3-to-1 bycatch ratio. There was no reduction in the industry led trials.

The late Steve Parrish, the gear specialist on the industry workgroup, cautioned the group that bycatch reductions were overstated because the industry was already using 1-3/4 inch mesh tail bags and some of the industry was using 1-7/8 inch mesh tail bags. Parrish clearly told the group that it was unrealistic to use a 1-1/2 inch tail bag mesh size as a control net.

The industry “dumbed down” the control net to a 1-1/2” tail bag increasing the bycatch ratio to 6.3-to-1, thereby allowing the “test” net using a 1-3/4” tail bag, gear the industry was already using, to reduce bycatch back to 3.6-to-1. The second BRD (federal fisheye) does nothing to reduce juvenile bycatch. It was never independently tested as a variable. There was no reduction. The trials were a smoke and mirrors delaying tactic.

The recent Atlantic croaker and spot stock assessments found that shrimp trawl bycatch is the #1 source of total mortality for both stocks. The croaker stock assessment found that “shrimp trawl bycatch accounted for 81 - 99% of annual removals and averaged 91.6% of all removals”.

Weakfish have natal homing. Just like salmon return to their native river to spawn, weakfish return to their native NC inlet to spawn. When we kill juvenile weakfish in the Pamlico Sound shrimp trawl fishery, we are killing our future spawning stock. Like Atlantic croaker and spot, shrimp trawl bycatch accounts for the vast majority of total annual removals for weakfish.

The division has provided Hotspot data for the Pamlico Sound using the P-195 trawl survey. The weakfish data correlates very well with my own analysis using 27-years of data from 1987 – 2013. NC allows extensive trawling in the epicenter of our weakfish nursery areas- undesignated nursery areas. The same can be said for Atlantic croaker, spot, blue crab, kingfishes, flounders, and other species.

The division tells you that “closing the entire Pamlico Sound to shrimp trawling would be a severe management measure”. Yet, the division’s own Hotspot analysis identifying undesignated critical habitat nursery areas shows, per the division’s own words, that “no single area closure encompasses the range for all species, except a complete closure”.

The science, data, facts, photos, satellite images and GIS tracks clearly show that NC has failed to protect its nursery areas. During the 2013 Hergenrader Petition for Rule Making asking to close NC at the Colregs Lines to trawling, Connell Purvis, former Director of the NCDMF, clearly stated that “Shrimp is King.”  Current nursery area designations were delineated to protect shrimp trawling. The end results are evident with our decline in croaker, spot, weakfish, blue crab, and flounder.

Shrimp trawl effort is not down. The division and industry will falsely claim that effort is down as much as 80%, therefore bycatch has been equally reduced. Neither is true. Catch equals landings plus discards including bycatch discards. Landings are at a historical high as much as 2.5-times the long-term average. Landings are a function of catch. Bycatch is a function of catch. There is no gear capable of sorting a three-to-five-inch shrimp from a three-to-five-inch juvenile finfish allowing the fish to escape unharmed that does not produce an unacceptable shrimp loss to the industry. To protect our economically important fin and forge fish, we must protect all of our nursery areas- designated and undesignated.

I had hoped to assist the Shrimp Advisory Committee with years of citizen science research and data. But, after being named to the committee, fisheries management in NC being a political science, politics removed me from the AC prior to the first meeting. I did virtually attend the workshops as a viewer.

If I can assist you in better understanding the issues and facts, please do not hesitate to ask.

I ask that this commission have the courage to follow and use the best available science. Use your common sense. Please come to the table in good faith. If our resources are to recover, we must properly identify and delineate critical habitat with priority given to nursery area protection.

Edited by Rick - 18 May 2021 at 4:41pm
NC Fisheries Management- Motto: Too Little, Too Late, Too Bad   Slogan: Shrimp On! Mission Statement: Enable Commercial Fishing At Any and All Cost, Regardless of Impact to the Resource.
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Rick View Drop Down

Joined: 16 July 2003
Location: United States
Status: Offline
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Post Options Post Options   Thanks (0) Thanks(0)   Quote Rick Quote  Post ReplyReply Direct Link To This Post Posted: 08 June 2021 at 12:41pm

Send your public comment to the ACs and/or sign up to speak via webinar-

Division of Marine Fisheries public comment period open on Shrimp Fishery Management


The N.C. Division of Marine Fisheries is accepting public comment on proposed management changes to further reduce bycatch of non-target species and minimize ecosystem impacts. 

Draft Amendment 2 to the Shrimp Fishery Management Plan contains a suite of management options that range broadly from status quo to a complete closure of all inside waters, including Pamlico Sound, to shrimp trawling. They include:

  • Area closures to protect submerged aquatic vegetation or oyster beds;
  • Shrimp management of Special Secondary Nursery Areas;
  • Creating permanent or seasonal closures in the Pamlico Sound region;
  • Shrimp trawl gear modifications; and
  • Shrimp trawl effort limitations.

Draft Shrimp Amendment 2 also includes a shrimp trawl bycatch information paper which discusses data needs to estimate the amount of bycatch from the shrimp trawl fishery, methods for estimating bycatch reduction and impacts on common bycatch species. Additionally, one objective of the plan is to evaluate and address nursery area designations through the Coastal Habitat Protection Plan.

The public may comment on Draft Shrimp Amendment 2 in three ways:

  1. Sign Up to Speak at an Advisory Committee Meeting – Public comment will be accepted at the three Marine Fisheries Commission Advisory Committee meetings listed below. Those who wish to speak at the meetings must register by 5 p.m. the day before the meeting.
  2. Submit Online Comments – Public comments will be accepted through an online form until 5 p.m. on June 30. Click here to submit comments online.
  3. Mail Comments – Written comments may be mailed to Draft Shrimp FMP Amendment 2 Comments, P.O Box 769, Morehead City, N.C. 28557. Comments must be received by the division 5 p.m. on June 30.

Emailed comments will not be accepted.

Five Marine Fisheries Commission Advisory Committees are scheduled to review and accept public comment on Draft Shrimp Amendment 2. The committees will meet by web conference as follows:

Joint Northern and Southern Regional Advisory Committees
June 15 at 6 p.m.

Register to speak by 5 p.m. June 14

Joint Shellfish/Crustacean and Finfish Advisory Committees
June 16 at 6 p.m.

Register to speak by 5 p.m. June 15 

Habitat and Water Quality Advisory Committee
June 17 at 6 p.m.

Register to speak by 5 p.m. June 16 

Meeting links and agendas are available on the Marine Fisheries Commission Advisory Committees Meetings webpage.

More specifics on the Draft Shrimp Amendment 2 can be found on the Shrimp Fishery Management Plan Amendment 2 Information webpage
The Marine Fisheries Commission is scheduled to consider public comment and advisory committee input and select its preferred management measures for departmental and legislative review at its August business meeting and give final approval of the amendment in November 2021.
For more information contact division biologists Chris Stewart at 910-796-7291, Jason Rock at 252-808-8091, or Daniel Zapf at 252-946-6481.

NC Fisheries Management- Motto: Too Little, Too Late, Too Bad   Slogan: Shrimp On! Mission Statement: Enable Commercial Fishing At Any and All Cost, Regardless of Impact to the Resource.
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