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Old 01-11-2017, 06:13 AM   #1
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Default An Open Letter to the MFC and ACs- NCWF Petition

January 10, 2017

Dear Chairman Corbett, Commission Members and Advisory Committee Members

As you know, public comment will be heard on January 17th regarding the Petition for Rulemaking filed by the North Carolina Wildlife Federation, (NCWF). I respectfully submit the following comments and a link to a PowerPoint presentation for your review. I ask that you support the NCWF in its endeavors to properly classify non-designated nursery areas and to reduce shrimp trawl bycatch, both are much needed measures.

It is clear that critically important nursery areas are not properly protected.
Noble and Monroe in their Classification of Pamlico Sound Nursery Areas: Recommendations for Critical Habitat Criteria- Project No. 89-09, Elizabeth B. Noble and Dr. Robert J. Monroe, NC Department of Environment, Health and Natural Resources, Division of Marine Fisheries, February 1991, clearly said
“Species which were present in very low numbers (spotted seatrout, weakfish and silver perch) in the riverine systems had their highest class means in the Pamlico Sound core group. So, differences in abiotic and biotic variables do exist in these “traditional” nursery area environments. Also, there are habitats in these areas that qualify for nursery area designation, but are not as yet protected.”
The Coastal Habitat Protection Plan acknowledges both the need to

Protect habitat from fishing gear effects through improved enforcement, establishment of protective buffers around habitats, modified rules, and further restriction of fishing gears, where necessary. Page 457, 2010

and to

Identify, designate, and protect Strategic Habitat Areas. Page vii, 2010.


The NC Marine Fisheries Commission has failed to protect important nursery areas and strategic habitats through proper designation.

North Carolina’s designated Primary Nursery Areas are the settlement areas for post-larvae of offshore winter spawners and were based on surveys in shallow waters less than 2 meters in depth. Those surveys today equate to the NCDMF P120 Estuarine Trawl Survey.

The DMF‘s estuarine trawl sampling program (Program 120) provides data to identify nursery areas. It also provides a long-term database of annual juvenile recruitment of economically important species as provided by the core stations. This database has been used for designation of new nursery areas in the past and continues to be the main source of data and information used to designate future potential nursery areas. North Carolina Shrimp Fishery Management Plan Draft Amendment 1, North Carolina Division of Marine Fisheries, page 169.

CHPP (2010) acknowledges that additional nursery area protection is needed.

The current MFC restrictions on trawling protect PNAs. However, there are productive shallow water areas of soft bottom that are not designated as primary or secondary nursery areas but still serve as important habitat to many juvenile fish and invertebrates. Shallow areas where trawling is currently allowed should be re-examined to determine if additional restrictions are necessary, (page382).

The Pamlico Sound is a weakfish nursery, a non-designated weakfish nursery area that must be protected.

It is important to recognize the distinction between the generic term “nursery area” and the specific regulatory designations of “Nursery Area”. For example, Pamlico Sound maintains a diversity of habitat functions. Its abundance of young finfish as well as shrimp and crabs is well documented and therefore is often termed a nursery area. North Carolina Shrimp Fishery Management Plan Draft Amendment 1, North Carolina Division of Marine Fisheries, page 170

Current designated nursery areas have failed to protect the deeper more open waters of the Pamlico Sound Complex and therefore have left unprotected the primary and secondary nursery areas for weakfish.

In addition to juvenile species present in lower salinity areas, spotted seatrout, weakfish, silver perch, and red drum are also abundant in these moderate-salinity estuaries (Noble and Monroe 1991). Young weakfish and silver perch tend to occupy deeper waters of the moderate and high-salinity zones, while young blue crabs and other demersal species prefer shallow areas (Epperly and Ross1986). Nursery habitats for North Carolina juvenile weakfish are reported to be in deeper portions of coastal rivers, bays, sounds and estuaries (Mercer 1989, DMF unpublished program 195 data). As they grow, juvenile weakfish have been found to be mostabundant in shallow bays or navigational channels that are characterized by moderate depths, slightly higher salinities, and areas with a sandy bottom (ASMFC 1996).CHPP, 2010, page 50.

Anne Deaton (NCDMF) in a personal email dated August 23rd, 2013 confirmed that our current designated nursery areas are not designed to protect the weakfish’s preference for the deeper more open water nursery areas.


“Here is a table with the acreage and percent of estuarine waters. It is important to note that the nursery designations don’t represent all nursery areas for all species. They were targeting the offshore winter spawning estuarine dependent species. ”

Deaton has also acknowledged the critical importance of taking action to properly identify strategic habit areas, which include nursery areas necessary for productivity and viability.

The CHPP recommends that some areas of fish habitat be designated as “Strategic Habitat Areas” (SHAs). Strategic Habitat Areas are defined as specific locations of individual fish habitat or systems of habitat that have been identified to provide critical habitat functions or that are particularly at risk due to imminent threats, vulnerability or rarity. While all fish habitats are necessary for sustaining viable fish populations, some areas may be especially important to fish viability and productivity. Protection of these areas would therefore be a high priority (Deaton et al. 2010). North Carolina Shrimp Fishery Management Plan Draft Amendment 1, North Carolina Division of Marine Fisheries, page 171.

For almost four years I have been working on a project to identify those strategic habitats for weakfish in the Pamlico Sound estuarine complex. Just as the NCDMF used its shallow water surveys to identify current designated primary and secondary nursery areas, I have used the NCDMF P195 Pamlico Sound Annual Survey to identify potential weakfish primary and secondary nursery areas used during the critical annual recruitment period.


The case can be made that the complete P195 survey area should be closed to all bottom disturbing gear as a primary nursery area. The NC Wildlife Federation’s request to classify the area as a special secondary nursery area should be seen as a generous compromise to the commercial shrimping industry. The North Carolina Wildlife Federation’s request for additional gear, size, season and time restrictions are necessary to mitigate the effects of bycatch within this strategic habitat.


I respectfully ask that you review my work at the following link:


https://1drv.ms/p/s!ArHvxdSx-xlqggCT_gwDP-zDDEUt


[COLOR=rgb0,120,215] NCWF Nursery-Weakfish Presentation-2017 Public Comments.pptx[/COLOR]
[COLOR=rgb102,102,102] Shared via OneDrive[/COLOR]


What you will find is that North Carolina’s nursery areas are designed and designated to protect its most coveted demersal species, the shrimp. Even the economically important demersal spot was completely eliminated as a species from the survey studies used to classify our designated primary nursery areas. Juvenile spot were once so ubiquitous in the Pamlico Sound Complex that all waters should be considered nursery areas. Forty years later, spot landings are at historical lows and the stock status is listed as concern.


What happened in those forty years?


Contrary to what the NCDMF will tell you, shrimp trawl effort remained constant over the last forty years producing on average slightly over 6-million pounds landed annually. The NCDMF measures effort by trips and they are right, trips are down. What the NCDMF acknowledges but discounts when discussing the effects of trawling is the following.

“Technological advances in the shrimping industry have increased the catching efficiency of larger boats, particularly in Pamlico Sound. In the 1940s and early 1950s, a 45 to 60 foot vessel pulled a single trawl with a headrope length of 60 to 65 feet. Now, with “four-barreled rigs” the same vessel can pull four nets with a combined headrope length of up to 200 feet. Four barreled rigs allow fishermen to pull two nets from each outrigger. Conventional two-seam otter trawls are used for the bottom-hugging pink and brown shrimp, while four - seam and tongue trawls with floats on the headrope are used for the white shrimp which have the ability to jump over two-seam trawls when disturbed. In Pamlico Sound, these large vessels stay out four or five days and tow from one to three hours, often working day and night.”North Carolina Shrimp Fishery Management Plan Draft Amendment 1, North Carolina Division of Marine Fisheries, page 48.


Boats are larger, gear is larger and on-board refrigeration and insulated holds allow boats to leave the dock on Sunday afternoon and return on Friday afternoon after trawling day and night, which is considered “one” trip. Obviously trips are down with improved efficiencies. Landings are not down, in fact 2015 was the top eighth landing year in the last forty-four years, over 9-million pounds, certainly not the typical 6 million pound landing year. In fact it was 50% higher.


Landings are a function of Catch. Bycatch is a function of Catch.


What has changed significantly in the past forty years is that brown shrimp landings from the Pamlico Sound have more than doubled during that time. Given that 58% of all shrimp landings come from the Pamlico Sound and that brown shrimp now account for 59% of all shrimp landings (up from 28% in 1970s), one can surmise that properly measured Pamlico Sound trawling effort has increased over the last forty years.






That increased trawl effort has certainly impacted spot, Atlantic croaker and weakfish bycatch, the predominate and economically important finfish species.


“Although many species are caught as bycatch in the estuarine shrimp trawl fishery, four species, blue crab, weakfish, Atlantic croaker, and spot have, since the first studies were conducted in the 1950s and continuing to the present, accounted for the bulk of the bycatch.”North Carolina Shrimp Fishery Management Plan Draft Amendment 1, North Carolina Division of Marine Fisheries, page 22.

Jess Hawkins understood the problem at one time while conducting nursery area studies as a NCDMF biologist.

“Juvenile (weakfish) were captured only in the northern and central region, with tributaries of Pamlico Sound serving as the major nursery areas.”

"The sounds and bays of North and South Carolina, Virginia, and Maryland serve-as nursery grounds for young juveniles along the Atlantic coast (Merriner 1973). Growth is rapid once the weakfish enter the estuaries (Pearson 1941, Massman et al. 1938, Merriner 1973). The juveniles remain in the estuaries until late fall or really winter, when they migrate to deeper, more open waters (Hildebrand and Cable 1934, Massman et al. 1958, Merriner 1973)."

"Weakfish are exploited by many fisheries in North Carolina. Long haul seines and pound nets are two major gears used to harvest weakfish in Pamlico Sound and its tributaries. Wolff (1972) stated that substantial numbers of small weakfish were taken incidentally with shrimp trawls, long haul seines, and pound nets. In recent years, a large offshore winter trawl fishery for weakfish has developed along the North Carolina coast."

"Juvenile weakfish were first noted during June at a size range of 19-99 mmTL (Figures 14 and 15). Recruitment times in Pamlico Sound indicated that spawning occurred earlier than previously reported by Spitsbergen and Wolff (1974) and Purvis (1976). Recruitment times substantiated Merriner's (1976) conclusion that the weakfish spawning peak occurred from late April/early May through June in North Carolina. Peak weakfish numbers were observed during July, when large quantities of young-of-the-year were present in the estuaries, agreeing with the findings of former Pamlico Sound investigations (Purvis 1976; Ross 1980, in press)."


Today, as a former NCDMF Deputy Director (retired) and Jerry Schill’s and the NCFA’s hired gun fighting the NCWF petition, Hawkins seems to have lost the opinions that paid his working salary and fund his retirement.



The following two slides are from the presentation linked above.


Below is a very conservative plotting of strata that juvenile weakfish prefer based on twenty-seven years of P195 Survey data.




The following slide shows the F/V Capt. Ralph trawling right in the epicenter of the weakfish nursery area during the 2016 shrimp season.

Red dots connected by light blue lines show the ship’s path and green dots are overlaid from the weakfish nursery area plot in the prior figure.





North Carolina is allowing trawling in the primary and/or secondary nursery areas for weakfish. These are undesignated nursery areas that need to be protected.

Weakfish is only one species of many that has a stock status listed as “concern” or “depleted”. Spot and Atlantic croaker are the #1 and #2 species landed in the P195 trawl survey, respectively. As mentioned previously, spot was so ubiquitous in the Pamlico Sound thirty years ago that it was eliminated as a target species for nursery classification. Today, spot stocks are listed as concern and recent harvest has been at historical lows as is the Atlantic croaker stock. Southern flounder stock status is listed by default as concern (no current stock assessment), but is truly depleted. Summer flounder is listed as concern. Blue crab is listed as concern with current landings below historic levels with both decreased abundance and adult recruitment. All of those economically important species are affected by Pamlico Sound shrimp trawl bycatch.

Please support sustainable fisheries management by supporting the NC Wildlife Federation's Petition for Rule Making.
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Old 01-12-2017, 07:32 AM   #2
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Great job as always Rick! The frustrating part is no matter what data is presented, what scientific facts are offered, certain members of the commission have his/her mind already made up when they walk in the door.
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Old 01-12-2017, 08:05 AM   #3
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That is true, BUT we only need five votes out of nine commissioners!

Please submit your personal comments to the MFC and the ACs. Below is an easy cut & paste list of the proper recipients.

Call a commissioner to discuss the petition and share your opinion. The phone numbers can be found here-

http://portal.ncdenr.org/web/mf/nort...ies-commission

Thanks

[email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected];
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Old 01-12-2017, 10:10 PM   #4
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Great work on compiling very valuable information Rick. If folks want change they have to act. Please contact the people listed and do it often.
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