Industry-funded Monitoring Omnibus Amendment Supplement Discussion Document By Aja Szumylo Observer Policy Committee Meeting New England Council Meeting September 2015
Overview • Highlight of changes to EA • Monitoring Set-Aside Alternative • Possible revisions to Herring Alternative 2.4 (EM/Portside Sampling)
Changes to EA (p. 3) • Section 1.0 – Introduction and Background – Revised to Q & A Format • Included information on current Greater Atlantic Region industry-funded programs (p. 26 and 29) • Included information on monitoring costs in other regions (p. 37 and throughout Omnibus Alternative Descriptions) • Can accept funding from external groups to cover administrative costs? (p. 35) • Can there be a fully industry funded program? (p. 38) – Revised purpose and need consistent with July 1 Joint Herring/Observer Policy Committee motion
Changes to EA (continued) • Section 2.1 – Omnibus Alternative Description – Expanded description of current monitoring types in the Greater Atlantic Region (p.43) – Standardized cost responsibilities • Added NMFS cost estimates (p. 49) • Expanded descriptions of portside and EM • Included discussion of cost drivers for all programs (p. 62) – Monitoring Service Provider Requirements • Included discussion of education standards, FLSA/SCA requirements, and streamlining provider applications (p. 76- 79)
Changes to EA (continued) • Section 2.1 – Omnibus Alternative Description – Prioritization alternatives • Made weighting approach optional for Council-led prioritization • Made clear that portions of NMFS/Council-led prioritization would need to occur in a Joint MAFMC/NEFMC Committee meeting • Timing options – indefinitely until new program added, or every 3 years unless new programs added
Changes to EA (continued) • Section 2.2 – Herring Alternative Description – Service provider standards for herring (allow observer deployment on 2 consecutive days; education requirement) (p. 122) – Maintained Herring Alternative 2.1 (the Am 5 alternative – 100% NEFOP-level on Cat A+B) in the range – Range of changes from the July 1 Committee meeting (25% ASM option, fleet-based alternatives to considered but rejected, etc.)
Changes to EA (continued) • Revised Impacts analysis – Expanded economic analysis to include fixed costs for herring and mackerel vessels, based on recent industry survey – Revised and expanded herring alternative packages, based on July 1 Committee meeting (25% ASM option, fleet-based alternatives to considered but rejected, etc.)
Monitoring Set-Aside Alternative (p. 6) • Include general language to allow individual FMPs to establish a monitoring set-aside via framework adjustment • Example: – Reserve X% of ACL – If a vessel is selected to carry an observer, then vessel granted a certain amount of extra lbs to land above possession limit – Revenue from sale of extra fish helps offset cost of observer • If added, the IFM Omnibus WOULD NOT implement monitoring set-asides for individual FMPs
Framework process for Monitoring Set-Asides (p. 6) • Details for set-aside program would be developed in a subsequent framework or amendment to the FMP, and should include: 1. The basis for the monitoring set-aside; 2. The amount of the set-aside (e.g., quota, DAS, etc.); 3. How the set-aside is allocated to vessels paying for monitoring (e.g., an increased trip limit, differential DAS counting, additional trips, an allocation of the quota, etc.); 4. The process for vessel notification; 5. How funds are collected and administered from the industry; and 6. Any other necessary measures. Additional National Environmental Policy Act (NEPA) • analysis would be required.
Important considerations for Monitoring Set-Asides (p. 7) • Value of Resource • Management measures and fishery operations • ACL allocation within fishery • Shared Burden/Benefit • Availability of resources • Enforcement issues
Impacts of Monitoring Set-Aside Framework Process (p. 12) • No direct or indirect impact on biological resources, the physical environment, or fishery-related businesses • Any impacts associated with implementing a monitoring set-aside in a future framework adjustment would need to be fully analyzed in documents supporting documents
Possible Revisions to Herring Alternative 2.4 • Herring AP and Committee concern about the estimated costs of the EM/Portside sampling alternative • Developed options to reduce estimated costs Industry Cost per Seaday Year 1: $15,000 startup Electronic + $325 per seaday Monitoring Year 2: $325 $0.002/lb Portside ($5.12 per mt)
Discussion on cost estimates (p. 13) • Best available estimates • High-end estimates • EM cost estimate ($325 per seaday) – Based on 100 percent video review – Not clear how changing one aspect of program cost will affect other parts of estimate • Portside cost ($5.12 per mt; $0.002 per lb) – Based on MA DMF MWT portside sampling program – Includes administrative costs – Cannot isolate sampling costs due to data confidentiatlity – True cost is likely lower • We attempted to solicit estimates, but did not find willing providers
Options to revise EM/Portside program costs (p. 14) • Very limited information to show reductions in cost, however: 1. Used cost to review EM video footage only around haulback (Year 2+ = $248 per seaday) 100% review of EM video footage around haulback • Analysis used review time ratios from pacific whiting • fishery, may be different here 2. Reduced % of trips covered with EM to 50% Also reduced portside sampling to 50% • 3. Reduced portside sampling coverage to 75%, 50% and 25%. Maintained 100% review of EM video footage around • haulback
Percentage Percentage of trips EM Year 1 EM Per Amount of EM Video of trips covered Startup Seaday Footage Review covered with with Costs Costs EM Portside Sampling 100% Alternative 2.4 (camera running all the $325 100% 100% time, all video reviewed) Haulback Only (camera running only around Modification 1 $248 100% 100% haulback, 100% of haulback video reviewed) $15,000 Modification 2 100% $325 50% 50% Modification 3 Haulback Only $248 50% 50% Modification 4 Haulback Only $248 100% 75% Modification 5 Haulback Only $248 100% 50% Modification 6 Haulback Only $248 100% 25%
Discussion of results (p. 15 - 17) • The estimated reductions RTO for Alternative 2.4 are: – 44.3% in Year 1 and 35.1% for Year 2+ for paired MWT – 23.7% for Year 1 and 12.5% for Year 2+ for single MWT • Reducing EM review to only around haulback, and reducing the level of portside sampling coverage led to lower reductions in returns to owner for Year 2+. • All of the modifications have lower negative economic impacts on the average paired and single midwater trawl vessel than Alternatives 2.1 – 2.4 that are currently included in the Draft EA.
Modifications 4 -6: Reduced Portside Sampling • For modifications 4 – 6, per seaday coast for Year 2 in Table 2 should be considered an average seaday cost for the entire year. • Annual costs for portside sampling spread out over all of the trips that the vessel would take that year. • Practically, under modifications 4 – 6: – Vessels would pay the EM cost of $248 per seaday for each day at sea for all trips – Would then pay a cost for portside sampling for some trips (25 percent, 50 percent, or 75 percent) based on landings – Table 3 outlines the trip cost for portside sampling based on cost of $5.12/mt of herring, and frequency of certain landings levels ranging from 25 mt to 454 mt.
Example • If a 3-day single MWT trip is selected for portside sampling and lands 300,000 lb of herring: – Vessel pays $248 per day for EM and – $697 for portside sampling – Total of $1,441 for the entire trip ($248 x 3 + $697), or an average of $481 per seaday
Landing amount frequency (p. 18) • Table 3 on p. 18 • Portside sampling cost of $5.12/mt is the high end estimate of portside sampling costs. • The true portside sampling costs are likely lower • During 2014 fishing year: – 58% of paired MWT and 72% of single MWT trips landed less than 300,000 lb of herring per trip. – Using $5.12 per metric ton and assuming an average trip length of 3 days, a majority of trips can expect a portside sampling cost estimated at $232 per seaday.
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