trawl monitoring SS_081610rev

SUPPORTING STATEMENT FOR
NORTHWEST REGION GROUNDFISH TRAWL FISHERY
MONITORING AND CATCH ACCOUNTING PROGRAM
OMB CONTROL NO. 0648-XXXX
INTRODUCTION
This is a new information collection request that will replace OMB Control No. 06480563.
Under the authority of the Magnuson-Stevens Conservation and Management Act (16
U.S.C. 1801 et seq), the Pacific coast groundfish fishery is managed under the Pacific
coast groundfish fishery management plan (FMP). Part of the groundfish fishery, the
sector that has limited entry permits endorsed for trawl gear, is transitioning to a trawl
rationalization program through Amendments 20 and 21 to the groundfish FMP (RIN
0648-AY68, Initial Issuance and Program Components). Amendment 20 would establish
the trawl rationalization program and would consist of an individual fishing quota (IFQ)
program for the shorebased trawl fleet; and co-operative (co-op) programs for the at-sea
mothership (MS) and catcher/processor (C/P) trawl fleets. The trawl rationalization
program is intended to increase net economic benefits, create individual economic
stability, provide full utilization of the trawl sector allocation, consider environmental
impacts, and achieve individual accountability of catch and bycatch. Amendment 21
would establish fixed allocations for limited entry trawl participants. These allocations
are intended to improve management under the rationalization program by streamlining
its administration, providing stability to the fishery, and addressing halibut bycatch.
The shorebased IFQ program differs from the previous management of the groundfish
trawl fishery, which was managed with 2-month cumulative trip limits and bycatch limits
that were shared among many fishermen. Because limits were shared among fishermen,
there was a risk of managers lowering trip limits or closing seasons early if the catch of
groundfish proceeded too quickly over the year. The shorebased IFQ program will
allocate amounts of groundfish to individual fishermen to fish at any time during the
year. This puts the individual fishermen in control of when they fish and reduces the risk
of early season closures due to the activities of other fishermen. Under trawl
rationalization, the at-sea MS and C/P fleets will primarily operate as co-ops and pool
their available harvest of whiting and certain overfished species. The MS fishery will
also have a non-co-op fishery option that would operate similar to recent management
strategies for this fishery where multiple vessels are competing for the same amount of
fish, risking early season closure.
While the at-sea whiting fishery (MS and C/P) targets whiting, the shorebased IFQ
program has different groundfish target strategies. The shorebased IFQ non-whiting
fishery targets any groundfish other than whiting and is required to sort their catch at sea;
it also tends use bottom trawl gear (large or small footrope or selective flatfish gear). In
addition, a gear switching provision for non-whiting fisheries in the shorebased IFQ
program allows fishermen to target groundfish with groundfish non-trawl gear (generally

1

longline or pot). The shorebased IFQ whiting fishery targets whiting and may either
operate as a maximized retention fishery or may sort at-sea.
In the Pacific whiting maximized retention fishery, vessels dump unsorted catch directly
into refrigerated salt water tanks. Allowing unsorted catch to be retained allows the
fishery to be prosecuted efficiently and the quality of Pacific whiting delivered to
shorebased processors maintained. Pacific whiting deteriorates rapidly and must be
handled quickly and immediately chilled to maintain product quality. Unsorted catch
landed by Pacific whiting shoreside vessels includes species in excess of the trip limits,
non-groundfish species, protected species, and prohibited species such as salmon. Some
Pacific salmon caught in groundfish fisheries have been listed under the Endangered
Species Act. An incidental take statement covers specific amounts of take of Chinook
salmon in both the at-sea and shorebased Pacific whiting fisheries.1
To maintain the integrity of the catch retention requirements in the shorebased IFQ
program, participating vessels must have an observer for the estimation of discards (for
the whiting and non-whiting fisheries that sort at sea and for the maximized retention
whiting fishery) and the verification of catch retention (maximized retention whiting
fishery). In addition, vessels will be required to land their catch at shorebased IFQ first
receivers that have a NMFS-approved catch monitoring plan and have employed the
services of a catch monitor to verify the landed catch.
To achieve individual accountability for catch and bycatch and track total catch (landed
catch and discards), the shorebased IFQ program will be subject to 100 percent
monitoring both at-sea (with observer coverage) and dockside (with catch monitors).
Groundfish caught under the shorebased IFQ program may only be landed at shorebased
first receivers with a first receiver site license. To obtain a first receiver site license from
NMFS, the first receiver must have a NMFS-approved catch monitoring plan, have been
subject to a site inspection, meet the required equipment requirements (including scales),
and report the landings through an electronic fish ticket system. The first receiver is
responsible for having a catch monitor available to monitor the landing of fish from
vessels participating in the IFQ program. The first receiver is also required to accurately
weigh the catch from each landing and report them on the Federal electronic fish ticket
system.
________________________________________________________________________
1

Since 1992, new evolutionarily significant units (a population of organisms that is considered distinct for purposes of
conservation) of Pacific salmon have been listed under the Endangered Species Act (ESA). In response to the new
listings, NMFS issued Biological Opinions under the ESA pertaining to the effects of the Pacific Coast groundfish FMP
fisheries on Chinook salmon on August 10, 1990, November 26, 1991, August 28, 1992, September 27, 1993, May 14,
1996, and December 15, 1999. The August, 1992 Biological Opinion included an analysis of the effects of the Pacific
whiting fishery on listed Chinook salmon. The analysis determined that there was a spatial/temporal overlap between
the Pacific whiting fishery and the distribution of ESA listed Chinook salmon such that it could result in incidental take
of ESA listed salmon. The incidental take statement authorized the take of 0.05 salmon per metric ton of Pacific
whiting and identified the need for continued monitoring of the fishery to evaluate impacts on salmon. The Biological
Opinion specifically emphasized the need to monitor the shoreside whiting fishery because fishing patterns and bycatch
rates were likely to differ from those observed on the at-sea processors.

This shorebased monitoring and catch accounting system is an expansion of the program
that has been conducted under exempted fisheries permits (EFPs) for the Pacific whiting

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shoreside fishery since 1992 (previously OMB Control No. 0648-0563). The new
collection of data would cover not only the Pacific whiting shoreside fishery but all
groundfish delivered shoreside by vessels participating in the shorebased IFQ program.
Thus, the use of shorebased catch monitors and electronic fish tickets will be broader
than under OMB Control No. 0648-0563. In addition, the new collection of data would
not use electronic monitoring systems (EMS) that had been used for at-sea monitoring of
the whiting fishery under OMB Control No. 0648-0563. The Pacific Fishery
Management Council, which makes management recommendations to NMFS,
recommended 100% observer coverage on vessels at-sea and no EMS. In addition to
100% observer coverage on vessels at-sea, mothership processors and C/Ps will be
subject to scale requirements that include daily testing, reporting, and an annual
inspection.
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
The trawl rationalization program requires NMFS to accurately monitor the use of all
quotas and allocations. A catch monitoring and accounting system are required in order
to: 1) track the total catch (retained and discarded) of groundfish species, including
Pacific halibut; and 2) adequately track the incidental take of Chinook salmon as required
in the ESA Section 7 Biological Opinion (1999) for Chinook salmon catch in the Pacific
whiting fishery. The primary tools for monitoring and accounting are:
1) The use of catch monitors at shorebased first receivers
2) First receivers’ possession of a first receiver site license and operation under a
NMFS-accepted catch monitoring plan
3) Weighing of all catch on certified scales for both shorebased and at-sea fisheries
4) Shorebased IFQ catch reported on electronic fish tickets.
First receivers who receive, buy, or accept deliveries if IFQ species must use a NMFSapproved electronic fish ticket software to send catch reports to the Pacific States Marine
Fisheries Commission (PSMFC) within 24 hours of when the catch is landed. Electronic
fish ticket reports are used to track the landed catch relative to allocations, quotas, and
prohibited species catch.
To support the trawl rationalization program, NMFS requests that OMB Control No.
0648-0563 be replaced by the following new data collection requirements:
For catch monitor service providers
• The preparation and submission of an application to be a certified catch
monitor service provider;
• Appeals submissions by businesses not issued certifications or decertified.
• The submission of qualification for catch monitors.

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For catch monitors
• The preparation and submission of an application to be a certified catch
monitor (submitted to the service provider only and not counted as burden for
this information collection);
• Appeals submissions by individuals not issued certifications or decertified.
For first receivers
• The preparation and submission of an application for a first receiver site
license, including a catch monitoring plan whose burden is part of this
Shorebased Monitoring and Catch Accounting information collection. [The
first received site license is included in a separate PRA submission, OMB
Control No. 0648-XXXX, Trawl Rationalization Program Permit and License
Information Collection, to be submitted concurrently with this request].
• The requirement to have an approved scale for weighing landings, and a
printed record or report for each delivery.
• The preparation and submission of the electronic fish ticket for each landing.
For at-sea processors (MS and C/P)
• The requirement to have an approved scale for weighing catch at-sea, a
printed record of catch weight and cumulative weights, and a printed record of
daily scale tests.
2. Explain how, by whom, how frequently, and for what purpose the information
will be used. If the information collected will be disseminated to the public or used
to support information that will be disseminated to the public, then explain how the
collection complies with all applicable Information Quality Guidelines.
•

A catch monitor service provider application is a narrative application submitted
to NMFS by businesses interested in being certified to provide catch monitor
services. This is a one-time application process. NMFS will use the application
to determine if a business can provide adequate services to support the catch
monitor needs and that there is no apparent conflict of interest. Information
provided includes contact and business information, prior related experience and
description of ability to carry out a catch monitor provider’s responsibilities. As
an interim measure to ensure that providers are available at the start of the
program, catch monitor providers previously certified in 2010 who deployed
catch monitors in a NMFS-managed West Coast groundfish fishery or observers
under the North Pacific Groundfish Program, are exempt from the requirement to
apply for a permit in 2011 and will be issued a catch monitor provider permit
effective through December 31, 2011.

•

Catch monitor provider appeals submissions are narratives that may be received
from businesses that were not issued catch monitor service provider certifications
or business that have been decertified. The purpose of an appeals submission is to
provide NMFS with information that may result in the business receiving a

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certification or not being decertified. Fewer than two appeals letters are expected
to be submitted annually.
•

Catch monitor qualifications are copies of application materials submitted by the
catch monitor applicants to catch monitor service providers. The catch monitor
service provider then submits the qualifications to NMFS when an individual is
initially hired to be a catch monitor. Each applicant must submit their
qualifications prior to their initial training session and certification as a catch
monitor. NMFS will use the documents to verify that candidates are qualified and
do not have an apparent conflict of interest or obvious past experiences that may
impair their objectivity as a catch monitor.

•

Catch monitor appeals submissions are narratives that may be received from catch
monitors that have been denied certifications or have been decertified. The
purpose of an appeals submission is to provide NMFS with information that may
result in an individual receiving a certification or not being decertified.

•

Catch monitoring plans are prepared by the shorebased IFQ first receivers and are
narrative responses to specific information requested in the proposed regulations.
The catch monitoring plan is submitted to NMFS as part of the first receiver site
license application but is considered a part of this information collection. The
first receiver site license is addressed under the separate information collection
request, Trawl Rationalization Program Permit and License Information
Collection. The catch monitor plans are submitted annually with the first receiver
site license renewal and are resubmitted if substantial changes are made in how
fish are received, sorted or weighed. An onsite inspection is conducted before the
plans are accepted. An acceptable catch monitor plan describes how landings can
be monitored effectively by a catch monitor, that scales are certified and used
appropriately, how adequate facilities will be made available for catch monitors,
and how the first receiver will provide accurate landed catch data. NMFS will use
the information to aid catch monitors in the completion of their duties and to
determine if particular first receivers are capable of providing accurate landed
catch data from both sorted and unsorted deliveries.
Information to be required in the catch monitoring plan, as specified in the
proposed regulations at 50 CFR 660.140 (f)(3)(iii)(C), as outlined in Proposed
Rule 0648-AY68:
(1) Catch sorting. Describe the amount and location of all space
used for sorting catch, the number of staff assigned to catch sorting, and
the maximum rate that catch will flow through the sorting area.
(2) Monitoring for complete sorting. Detail how IFQ first receiver
staff will ensure that sorting is complete; what steps will be taken to
prevent unsorted catch from entering the factory or other areas beyond the
location where catch sorting and weighing can be monitored from the
observation area; and what steps will be taken if unsorted catch enters the

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factory or other areas beyond the location where catch sorting and
weighing can be monitored from the observation area.
(3) Scales used for weighing IFQ landings. Identify each scale that
will be used to weigh IFQ landings by the type and capacity and describe
where it is located and what it will be used for. Each scale must be
appropriate for its intended use.
(4) Printed record. Identify all scales that will be used to weigh
IFQ landings that cannot produce a complete printed record as specified at
§ 660.15(c), subpart C. State how the scale will be used, and how the plant
intends to produce a complete and accurate record of the total weight of
each delivery.
(5) Weight monitoring. Detail how the IFQ first receiver will
ensure that all catch is weighed and the process used to meet the catch
weighing requirements specified at paragraph (k) of this section. If a
catch monitoring plan proposes the use of totes in which IFQ species will
be weighed, or a deduction for the weight of ice, the catch monitoring plan
must detail how the process will accurately account for the weight of ice
and/or totes.
(6) Delivery points. Identify specific delivery points where catch is
removed from an IFQ vessel. The delivery point is the first location where
fish removed from a delivering catcher vessel can be sorted or diverted to
more than one location. If the catch is pumped from the hold of a catcher
vessel or a codend, the delivery point will be the location where the pump
first discharges the catch. If catch is removed from a vessel by brailing,
the delivery point normally will be the bin or belt where the brailer
discharges the catch.
(7) Observation area. Designate and describe the observation area.
The observation area is a location where a catch monitor may monitor the
flow of fish during a delivery, including: access to the observation area,
the flow of fish, and lighting used during periods of limited visibility.
Standards for the observation area are specified at paragraph (j)(4)(ii) of
this section.
(8) Lockable cabinet. Identify the location of a secure, dry, and
lockable cabinet or locker with the minimum interior dimensions of two
feet wide by two feet tall by two feet deep for the exclusive use of the
catch monitor, NMFS staff, or authorized officers.
(9) Plant liaison. Identify the designated plant liaison. The plant
liaison responsibilities are specified at paragraph (j)(6) of this section.
(10) First receiver diagram. The catch monitoring plan must be
accompanied by a diagram of the plant showing:
(i) The delivery point(s);
(ii) The observation area;
(iii) The lockable cabinet;
(iv) The location of each scale used to weigh catch; and
(v) Each location where catch is sorted.

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•

Shorebased scales - printed scale reports are records made available to the catch
monitor and, upon request, to NMFS. For scales used to weigh catch at IFQ first
receivers, all scales identified in a catch monitoring plan must produce a printed
record for each delivery, or portion of a delivery, weighed on that scale, unless
specifically exempted by NMFS [Scales not designed for automatic bulk
weighing may be exempted from part or all of the printed record requirements].
A first receiver must maintain printed scale reports on site until the end of the
fishing year during which the printouts were made and make them available upon
request by NMFS for 3 years after the end of the fishing year during which the
printout was made. The printed record must include:
(A) The IFQ first receiver’s name;
(B) The weight of each load in the weighing cycle;
(C) The total weight of fish in each landing, or portion of the landing that
was weighed on that scale;
(D) The date the information is printed; and
(E) The name and vessel registration or documentation number of the
vessel making the delivery. The scale operator may write this information
on the scale printout in ink at the time of printing.

•

At-sea scales - printed scale reports for catch weight and cumulative weight, as
well as, records of daily scale tests are records made available to NMFS staff or
authorized officers.
1) For scales used to weigh catch at-sea, belt scales and platform scales must
produce a printed record for the catch weight and cumulative weight at least once
every 24 hours. [Note: A platform scale used for observer sampling at-sea is not
required to produce a printed record]. Printed scale reports must be maintained on
board the vessel until the end of the fishing year during which the printouts were
made and the vessel owner must make them available upon request by NMFS for
3 years after the end of the fishing year during which the printout was made. The
printed report must be provided to the authorized scale inspector at each scale
inspection. Reports must also be printed before any information stored in the
scale computer memory is replaced. Scale weights must not be adjusted by the
scale operator to account for the perceived weight of water, slime, mud, debris, or
other materials. Scale printouts must show:
(A) The vessel name and Federal vessel permit number;
(B) The date and time the information was printed;
(C) The haul number;
(D) The total weight of the haul; and
(E) The total cumulative weight of all fish and other material weighed
on the scale since the last annual inspection.
2) For scales used to weigh catch at-sea, belt scales and platform scales must have
a record to show they have complied with daily scale test requirements, specified
at 50 CFR 660.15(b)(4). Printed scale reports must be maintained on board the
vessel until the end of the fishing year during which the printouts were made and

7

the report forms must be made available to observers, NMFS staff, or authorized
officers upon request. In addition, the vessel owner must retain the scale test
report forms for 3 years after the end of the fishing year during which the tests
were performed. Each scale test report form must be signed by the vessel
operator immediately following completion of each scale test. The vessel owner
must ensure that the vessel operator maintains the scale in proper operating
condition throughout its use, that adjustments made to the scale are made so as to
bring the performance errors as close as practicable to a zero value, and that no
adjustment is made that will cause the scale to weigh inaccurately. The vessel
operator must ensure that vessel crew notify the observer at least 15 minutes
before the time that the test will be conducted, and conduct the test while the
observer is present. The vessel operator must also ensure that vessel crew conduct
the scale test and record the following information on the at-sea scale test report
form:
(1) Vessel name;
(2) Month, day, and year of test;
(3) Time test started to the nearest minute;
(4) Known weight of test weights;
(5) Weight of test weights recorded by scale;
(6) Percent error as determined by subtracting the known weight of the test
weights from the weight recorded on the scale, dividing that amount by the known
weight of the test weights, and multiplying by 100; and
(7) Sea conditions at the time of the scale test.
•

Electronic fish tickets are submissions of IFQ landings data from the first receiver
to NMFS. Specific computer hardware and software, including internet access,
are required for the electronic fish ticket system. These requirements include:
(1) Hardware and software requirements.
(i) A personal computer with Pentium 75–MHz or higher. Random Access
Memory (RAM) must have sufficient megabyte (MB) space to run the
operating system, plus an additional 8 MB for the software application and
available hard disk space of 217 MB or greater. A CD-ROM drive with a
Video Graphics Adapter (VGA) or higher resolution monitor (super VGA
is recommended).
(ii) Microsoft Windows 2000 (64 MB or greater RAM required),
Windows XP (128 MB or greater RAM required) or later operating
system.
(iii) Microsoft Access 2003 or newer.
(2) NMFS approved software standards and internet access. The IFQ first
receiver is responsible for obtaining, installing, and updating electronic
fish tickets software either provided by PSMFC, or compatible with the
data export specifications specified by PSMFC and for maintaining
internet access sufficient to transmit data files via email.

As explained in the preceding paragraphs, the information gathered has utility. NMFS
will retain control over the information and safeguard it from improper access,

8

modification, and destruction, consistent with NOAA standards for confidentiality,
privacy, and electronic information. See response to Question10 of this Supporting
Statement for more information on confidentiality and privacy. The information
collection is designed to yield data that meet all applicable information quality
guidelines. Although the information collected is not expected to be disseminated directly
to the public, results may be used in scientific, management, technical or general
informational publications. Should NMFS decide to disseminate the information, it will
be subject to the quality control measures and pre-dissemination review pursuant to
Section 515 of Public Law 106-554.
3. Describe whether, and to what extent, the collection of information involves the
use of automated, electronic, mechanical, or other technological techniques or other
forms of information technology.
Catch monitor qualifications: The catch monitor qualification material could be
submitted as electronic copies of original documents if the catch monitor provider
chooses to do so.
All other information: may be emailed, but must be followed by mailed originals.
Electronic fish tickets: The electronic fish tickets are based on information currently
required by the states on paper fish receiving tickets or landing receipts (fish tickets).
First receivers will provide the computer hardware and software necessary to support the
electronic fish ticket program. The electronic fish ticket software will be free and runs on
Microsoft Access, 2003 or newer. Data will be transmitted daily via email.
4. Describe efforts to identify duplication.
For the electronic fish tickets, measures were taken to minimize duplication of the catch
accounting requirements by providing fish ticket software that is based on the existing
state systems and does not require additional data gathering. When state law allows, the
electronic fish ticket can be used to print a paper copy for submission to the state. In
Oregon, specified information may be submitted either on a paper fish ticket provided by
the state or on a computer generated ticket provided specified data fields are included.
However, in the States of California and Washington standard paper forms provided by
the states must be used.
For the scale requirements, measures were taken to minimize duplication of the scale
requirements and reports by matching these to similar requirements for Alaska fisheries,
where possible, and based on public comments concerning current scale printer
capabilities during public and industry meetings. For the shorebased scales, the required
printout format is programmed into each scale. Complying with NMFS’ requirements is
either automatic when the scale operator changes memories or requires only the print
command on the scale display. For the at-sea scales, to minimize costs and duplication,
the required scales on motherships and catcher/processors are the same as those required
for the Alaska fisheries that these vessels participate in. Therefore, there are no

9

additional capital costs for these motion-compensating belt and platform scales, which
can be costly. In addition, the annual inspection requirement for the at-sea scales is
fulfilled through the Alaska requirements at § 679.28(b) and authorized under OMB
Control No. 0648-0330. For the daily test reports the estimate of burden is included in
this supporting statement; however, the actual form used will be Alaska’s form, which is
covered under OMB Control No. 0648-0330.
Similarly, the catch monitor provider certification and decertification requirements are
similar to those used for Alaska and West Coast Groundfish Observer Program.
5. If the collection of information involves small businesses or other small entities,
describe the methods used to minimize burden.
Some applicants are individuals or small companies and as such are considered small
businesses. 1 Given the relatively small numbers of applicants, separate requirements
based on size of business have not been developed. Only the minimum data required to
meet the objectives of the overall monitoring program are requested from all applicants.
•

Catch monitoring plans: To minimize the burden, only essential information
needed to assure adequate catch accounting is being requested.

•

Electronic fish tickets: Measures were taken to minimize the costs of the catch
accounting requirements by providing: 1) fish ticket software at no cost; 2) fish
ticket software that used a standard operating system and common software
already owned by most businesses; 3) fish ticket software that is compatible with
the existing fish ticket requirements in each of the three states; and, 4) a software
that can be used to print a paper copy for submission to the state, when state law
allows. Because the information is already being gathered by the processors there
is no requirement that additional data be gathered.

1

From NMFS RIR/IRFA titled, “Rationalization of the Pacific Coast Groundfish Limited Entry Trawl
Fishery AND Allocation of Harvest Opportunity BETWEEN Sectors of the Pacific Coast Groundfish
Fishery” (May 2010):
For the trawl sector, there are 177 permit holders. Nine limited entry trawl permits are associated
with the catcher-processing vessels which are considered “large” companies. Of the remaining 168
limited entry permits, 25 limited entry trawl permits are either owned or closely associated with a
“large” shore-based processing company or with a non-profit organization who considers itself a
“large” organization. Nine other permit owners indicated that they were large “companies.” Almost
all of these companies are associated with the shorebased and mothership whiting fisheries. The
remaining 134 limited entry trawl permits are projected to be held “small” companies. Three of the
six mothership processors are “large” companies. Within the 14 shorebased whiting first
receivers/processors, there are four “large” companies. Including the shorebased whiting first
receivers, in 2008, there were 75 first receivers that purchased limited entry trawl groundfish. There
were 36 small purchasers (less than $150,000); 26 medium purchasers (purchases greater than
$150,000 but less than $1,000,000); and 13 large purchasers (purchases greater than $1.0 million).
Because of the costs of obtaining a “processor site license”, procuring and scheduling a catch
monitor, and installing and using the electronic fish ticket software, these “small” purchasers will
likely opt out of buying groundfish, or make arrangements to purchase fish from another company
that has obtained a processing site license.

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6. Describe the consequences to the Federal program or policy activities if the
collection is not conducted or is conducted less frequently.
The intent of this program is to provide permits to harvest and/or receive fish or fish
products managed under the trawl rationalization program. This program is expected to
reduce the race for fish and provide industry with the ability to schedule their activities to
allow more efficient fishing and a better quality of fish products. Without the specific
permitting scheme described in this supporting statement, the program would be
jeopardized. Furthermore, indirect biological impacts could result if catch data were
inaccurate or delayed such that fishing could not be stopped before one of the
specifications were exceeded, including: IFQs, halibut individual bycatch quotas,
allocations, optimum yields (OYs), and biological opinion thresholds.
If quotas of the most constraining overfished species were greatly exceeded due to
delayed catch reporting, the risk of exceeding rebuilding-based OYs is increased. This is
a particular concern for canary rockfish which is one of the most constraining species in
the groundfish fisheries and whose rebuilding trajectory is very sensitive to changes in
harvest levels. Although there are many variables that affect the time it takes a stock to
rebuild, exceeding the rebuilding based OY could result in an extended rebuilding period
for overfished species. Exceeding Chinook salmon take thresholds could increase the
risk to some more vulnerable Evolutionarily Significant Units (ESUs). Exceeding the
Pacific halibut Individual Bycatch Quotas (IBQs) or trawl fishery allocations could affect
future opportunity for both the trawl fishery and the directed commercial and recreational
halibut fisheries (non-trawl).
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Not Applicable.
8. Provide information on the PRA Federal Register Notice that solicited public
comments on the information collection prior to this submission. Summarize the
public comments received in response to that notice and describe the actions taken
by the agency in response to those comments. Describe the efforts to consult with
persons outside the agency to obtain their views on the availability of data,
frequency of collection, the clarity of instructions and recordkeeping, disclosure, or
reporting format (if any), and on the data elements to be recorded, disclosed, or
reported.
A proposed rule, RIN 0648-AY68 (scheduled to publish in August 2010), will solicit
public comments on this revision to the collection.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided.

11

10. Describe any assurance or confidentiality provided to respondents and the basis
for assurance in statute, regulation, or agency policy.
As stated on the forms, Section 303(d) of the Magnuson-Stevens Act sets forth
procedures for confidentiality of fisheries statistics, including statistics collected by
observers and NMFS staff. NOAA Administrative Order 216-100, Protection of
Confidential Fisheries Statistics, further establishes procedures for confidentiality of
collected and submitted data.
Electronic fish ticket data will be submitted to PSMFC. The electronic fish ticket data is
considered confidential under NOAA Administrative Order 216-100, Protection of
Confidential Fisheries Statistics. The PSMFC currently receives and stores fish ticket
data from the states. These data are maintained on the Pacific Fisheries Information
Network (PacFIN) data base.
11. Provide additional justification for any questions of a sensitive nature, such as
sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private.
There are no questions of a sensitive nature being asked.
12. Provide an estimate in hours of the burden of the collection of information.
Total burden hours and annual capital/recordkeeping/reporting and labor costs for the
collection are presented in Table A below. Total unduplicated respondents (3 catch
monitor provider applicants, 50 catch monitors, 80 first receivers, 6 mothership
processors, and 10 catcher/processors) are 149. Annual responses are 6,059 and
hours are 1,784.
13. Provide an estimate of the total annual cost burden to the respondents or
recordkeepers resulting from the collection (excluding the value of the burden hours
in Question 12 above).
Table B below shows miscellaneous costs for the collection. Capital costs annualized
over three years are $11,700. Annualized reporting/recordkeeping costs are
$$380,836. Total costs are $392,541.
The estimates of costs to first receivers of the catch monitor program are included in the
Regulatory Impact Review and Initial Regulatory Flexibility Analysis for the
Rationalization of the Pacific Coast Groundfish Limited Entry Trawl Fishery, dated May
2010 (attached as a supplementary document in ROCIS). First receivers will have to
obtain a first receiver site license that includes requirements to submit electronic fish
tickets, provide a catch monitoring plan, and schedule a catch monitor. Assuming that a
catch monitor costs $350 per day and that there will be 2,400 landings, the cost to all first
receivers would be less than $840,000. The cost would be less than this because a catch
monitor may record more than one of those landings in a day or multiple first receivers

12

may share the cost of a catch monitor on a given day. [Note that, in the first few years,
the costs of catch monitors will be subsidized in part by NMFS. Eventually the first
receivers will pay the full cost of catch monitors. The details of this subsidy have not yet
been developed, but the cost of catch monitors that will be covered by NMFS for the first
3 years of the program is estimated to be 90%, 50%, and 25%].
14. Provide estimates of annualized cost to the Federal government.
The estimates of annualized costs to the Federal government are included in Attachment
1 to the Regulatory Impact Review and Initial Regulatory Flexibility Analysis for the
Rationalization of the Pacific Coast Groundfish Limited Entry Trawl Fishery, dated May
2010. Costs of the catch monitor program, including electronic fish tickets, are estimated
to be approximately $300,000 - $400,000.
15. Explain the reasons for any program changes or adjustments reported.
This is a new program.
16. For collections whose results will be published, outline the plans for tabulation
and publication.
No formal scientific publications based on these collections are planned at this time. The
data will be used for management reports and fishery management plan amendments and
evaluations by the NMFS and the Council.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
Not Applicable.
18. Explain each exception to the certification statement.
Not Applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL
METHODS
No statistical methods are employed.

13

Table A - Total Annual Burden Hours, Labor, and Related Costs

Catch monitor providers
Application preparation & submission
Appeals – written response & submission
Catch monitors
Qualifications
Appeals- written response & submission
Catch monitoring plans 2/
Preparation & submission
Inspection
Shorebased scales
Inseason testing
Reports
Electronic fish tickets
Submissions
At-sea scales (MS, C/P)
Daily testing reports
Weight reports

Number of
respondents 1/

Frequency of
annual
responses
per entity

Total annual
responses

Estimated
hours per
response

Total
annual
burden
hours

Total labor
cost ($25/hr)

3
1

1
1

3
1

10
4

30
4

$750
$100

50
5

1
1

50
5

1
4

50
20

$1,250
$500

80
80

1
1

80
80

4
2

320
160

$8,000
$4,000

80
80

1
Variable

80
2400 3/

1
10 min.

80
400

$2,000
$10,000

80

Variable

2400 3/

10 min.

400

$10,000

16
16

30
30

480
480

30 min.
10 min.

240
80

$6,000
$2,000

1,784

$44,600

Total for collection

6,059

1/ The collection assumes the following participation levels annually:
120 shorebased catcher vessels, 80 first receivers, 3 catch monitor providers, 50 catch monitors, 6 MS, and 10 C/Ps.
2/ First Receiver Site License is included in a separate PRA request, OMB Control No. 0648-XXXX,
Trawl Rationalization Program Permit and License Information Collection.
3/ Estimate based on 120 vessels making 20 landings each per year.

14

Table B - Total Annual Miscellaneous Costs
Total Annual Responses

Misc. costs per
response

Total Misc. costs for all
respondents

Mail
Appeals- fax or mail written response & submission

3
1

$5
$3

$15
$3

Catch monitors
Appeals- mail written response & submission

5

$3

$15

Computer hardware

50 b/

$700 annualized
over 3 years = $234

$11,700

Catch monitor costs a/

2,400

$157.50

$378,000

Scale report printing

2,400

$0.05

$120

80

$3

$240

Catch monitor providers

First Receiver

Catch monitoring plans c/
Mail
Mothership/Catcher Processor daily test and scale
report printing

960

$0.05

2,400

$1

$48

Electronic fish tickets
Send via email

$2,400

Total for collection
$392,541
a/ Based on average of potential NMFS subsidies of 90%, 50% and 25% of $350 for first, second and third years, respectively (industry
estimated to pay $35 + $175 + $262.50 = $472.50/3 = $157.50)
b/ Assumes that the 12 first receivers that were part of the previous shoreside whiting EFP and that 18 first receivers
already have a computer.
c/ First Receiver Site License which the plan accompanies is included in a separate PRA request, OMB Control No. 0648-XXXX,
Trawl Rationalization Program Permit and License Information Collection.

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