Here's the Math, according to NC Catch: 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.