The applicant compared 36 scallop trips two ways. The usual method counted 259.75 days at sea. A first-to-last-dredge method counted 217.3. The difference is 42.45 days, or 1.18 days per compared trip after rounding. NMFS reports those figures in the July 27 notice.
The comparison comes from an application for an exempted fishing permit, not from an approved change to the scallop fishery. Can the evidence support a different accounting boundary that separates fishing activity from transit?
The accounting boundary starts before fishing
Under the current method described in the notice, days-at-sea accounting begins when a vessel crosses the vessel-monitoring-system demarcation line. The proposed method would begin at the first dredge entry and end at the final dredge exit before the vessel returns to port. The Federal Register notice describes both boundaries.
That difference matters because transit and fishing are different operating states. A boat can leave port, cross the line, and spend time reaching the grounds before it sets gear. Days-at-sea accounting still includes that movement under the usual boundary. The proposal asks whether that time should remain in the same account as dredging when the vessel can show, after the trip, when dredge work actually began and ended.
The proposed method needs a joined activity record
The notice describes two deck cameras, winch sensors, GPS sampled every 10 seconds, selected still-image exports every 12 hours, electronic logs, and trip reports. It also says the applicant would determine fishing start and stop times within five days after each trip. Those elements are specified in the Federal Register notice.
The Coonamessett Farm Foundation, an applicant-controlled project source, describes a similar arrangement: two cameras, gear sensors, a wheelhouse interface, onboard storage, and GPS, with video triggered by dredge-winch sensors. It presents the paired records as a way to estimate when setting and hauling begin and end. That project description is background, not independent validation.
The proposed start and stop times depend on joining these records. Cameras show deck activity, winch sensors mark gear movement, GPS locates the sequence, and logs record the crew's account. The records must line up well enough to support one auditable start and stop time; separate recordings do not establish those times.
The current method uses a geographic line. The proposed method needs a reviewable record of what happened on deck and when. The notice says the applicant would reconcile those signals after the trip.
The proposal covers six unapproved vessels
The request covers six commercial scallop vessels and would allow them to transit closed scallop rotational areas with gear stowed while testing the proposed process. NMFS identifies the six-vessel scope and requested exemptions.
The notice says the application was complete enough for consideration and public comment. It does not approve the exemption, adopt a new days-at-sea rule, or establish that the comparison will hold outside the applicant's trips. The Coonamessett page is controlled by a project participant and has no stated publication date; it can describe the proposed architecture, but it cannot independently establish performance, cost recovery, savings, or adoption. The 1.18-day average is an applicant-reported comparison, not an independently verified operating result, and it does not establish a guaranteed time allowance or regulatory acceptance.
Evaluate the proposed accounting boundary
For a scallop operator or fleet association evaluating the proposal, the test is whether its joined records could justify excluding transit from days-at-sea accounting. Define the fishing boundary, collect the relevant signals, reconcile them after the trip, and show why the resulting time is trustworthy enough to replace a line crossing. Until a regulator approves that change, the current VMS-line accounting remains in force.