0441 SS 120210rev

SUPPORTING STATEMENT
VESSEL MONITORING SYSTEM REQUIREMENTS IN THE WESTERN PACIFIC
PELAGIC LONGLINE FISHERY, AMERICAN SAMOA LONGLINE AND
COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS (CNMI)
BOTTOMFISH FISHERIES
OMB CONTROL NO. 0648-0441
INTRODUCTION
This request is for renewal of this information collection, and a merging of OMB Control No.
0648-0519 and the portion of OMB Control No. 0648-0584 pertaining to vessel monitoring
systems (VMS) into it. Once this request is approved, OMB Control No. 0648-0519 will be
discontinued, and we will submit a request to adjust the burden for 0648-0584 to reflect this
partial merger.
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
The Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act)
established regional fishery management councils, such as the Western Pacific Fishery
Management Council (Council), to develop fishery ecosystem plans (FEP) for fisheries in the
United States (U.S.) Exclusive Economic Zone (EEZ). These plans, if approved by the Secretary
of Commerce (Secretary), are implemented by National Oceanic and Atmospheric
Administration (NOAA) National Marine Fisheries Service (NMFS) via Federal regulations that
are enforced by the NOAA Office for Law Enforcement (NOAA OLE) and U.S. Coast Guard
(USCG), in cooperation with State agencies to the extent possible. The FEPs ensure the longterm productivity and optimum yield of the resources for the benefit of the U.S.
The Council has management jurisdiction over fisheries in the Pacific Ocean in the EEZ around
American Samoa, Guam, Hawaii, Northern Mariana Islands, and certain other remote U.S.
Pacific island possessions 1. The Council prepared, and the Secretary approved and
implemented through regulations, FEPs for pelagic fisheries and archipelagic (island-based)
fisheries in the western Pacific. The regulations include, but are not limited to, permit
requirements, gear restrictions, temporal and spatial closures, harvest guidelines, reporting
requirements, and protected species mitigation measures.
Regulations at 50 CFR Part 665, implementing the Fishery Ecosystem Plan for Pelagic
Fisheries of the Western Pacific Region (Pelagics FEP) and the Fishery Ecosystem Plan for the
Marianas Archipelago (Marianas FEP) require all vessels registered for use with Hawaii longline
limited access permits, all large vessels (greater than 50 ft in overall length) registered for use
with American Samoa longline limited access permits, and all medium and large vessels (40 ft or
greater in overall length) registered to Northern Mariana Islands bottomfish permits to maintain
and operate vessel monitoring systems (VMS) on their vessels, after they have been advised by
NOAA OLE of a requirement to carry such units. NOAA OLE provides the units and installs
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Howland, Baker, Jarvis, Wake and Palmyra Islands, Johnston Atoll and Kingman Reef.

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them for the permit holders. NOAA OLE arranges installation at times when the vessel is in port
between trips to ensure minimal disruption of other activities by the vessel.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used.
On a broad level, the VMS vessel location reports are used to facilitate enforcement regarding
prohibited or restricted fishing areas around American Samoa, Guam, Hawaii, Northern Mariana
Islands, and Pacific Remote Island Areas, including Marine National Monuments closed to
commercial fishing. The reports provide NOAA OLE and USCG real-time vessel location and
activity information. The VMS reports also can be used to check the accuracy of vessel position
information reported by the vessel operator in the daily fishing logbooks required by the
regulations. This information is important in determining or verifying locations of catch by
species and time as well as locations in which there were interactions with protected species,
such as endangered and threatened sea turtles. The information provides a basis for determining
whether changes in management are needed to protect sensitive species or to address fishery
interaction problems and for evaluating the impacts of potential changes.
The information collected will be used internally by authorized users (NOAA OLE, USCG,
NMFS and others per NMFS Policy Directive PD 06-101, June 17, 2006, VMS Data Access and
Dissemination Policy, and NOAA Administrative Order NAO 0216-0100, Protection of
Confidential Fisheries Statistics). The information would not be disseminated to the public
except in non-confidential or aggregate form in summary and analytical reports. See response to
Question 10 of this Supporting Statement for more information on confidentiality and privacy.
Prior to dissemination, the information will be subjected to quality control measures and a predissemination 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.
The VMS is an automated, satellite-based system that assists NOAA OLE and the USCG in
monitoring compliance with closed areas in a reliable and cost-effective manner. Electronic
VMS shipboard equipment installed permanently on board a vessel provides information about
the vessel’s position and activity. That information is communicated between the shipboard
VMS unit and the monitoring agency’s fishery monitoring center, where the identity and location
of the vessels are shown on a map display, comparing vessel positions with features of interest,
such as closed area boundaries.
4. Describe efforts to identify duplication.
There are no similar comparable programs to collect real-time vessel location information.
Requiring vessel operators to make at-sea reports of vessel locations is much more costly and
difficult, and would impose a direct reporting burden on the vessel operator. The VMS unit is
passive and automatic, requiring no reporting burden on the vessel operator.

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5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Vessels in the western Pacific fisheries generally range in size from 20 feet to 100 feet. Those
who participate in the fisheries are categorized as “small businesses” which are affected in a
similar manner by the VMS requirement. In all cases, NOAA OLE notifies the vessel owner
when the requirement would take effect and arranges appointments for installation and
maintenance inspections with the vessel owner and operator, to minimize time burden and
business disruption by these activities. There is no reporting burden on vessel owners to arrange
for VMS installation.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Without VMS, NOAA OLE and USCG would be tasked with monitoring closed areas via air and
surface patrols. The annual cost of relying on traditional surveillance methods using air and
surface patrols for time and area coverage is estimated at more than $25 million. Comparatively,
VMS provides 95 to 98 percent coverage at an estimated annual cost of $300,000.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The collection is consistent with OMB guidelines except that the VMS reports more frequently
than quarterly (multiple times per day). This interval is necessary for enforcing regulations.
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 Federal Register Notice describing this renewal was published on July 26, 2010 (75 FR
43487). One positive comment was received, supporting the cost-effectiveness of VMS for
ensuring compliance with area-based management and its use by NOAA.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided.

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10. Describe any assurance or confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Efforts were made in the design of the VMS program to ensure the security of all individual
vessel location data, including analysis and storage. The system includes measures to minimize
the risk of direct or inadvertent disclosure of fishing location information. Vessel operators
consider these data proprietary, and NOAA OLE and USCG have taken steps to secure this
information as “official use only” throughout the program design. Information submitted is
confidential under the Magnuson-Stevens Act and NOAA regulations, except under certain
circumstances as outlined in the Magnuson-Stevens Act.
Additional protections: Records are stored in computerized databases or CDs in locked rooms;
paper records are stored in file folders in locked metal cabinets and/or locked rooms. Records are
stored in buildings with doors that are locked during and after business hours. Visitors must
register with security guards and must be accompanied by Federal personnel at all times.
Records are organized and retrieved by NOAA internal identification number, name of entity,
permit number, vessel name, or vessel identification number. Electronic records are protected by
a user identification/password. The user identification/password is issued to individuals as
authorized by authorized personnel.
All electronic information disseminated by NOAA adheres to the standards set out in Appendix
III, Security of Automated Information Resources, OMB Circular A-130; the Computer Security
Act; and the Government Information Security Reform Act, and follows NIST SP 800-18, Guide
for Developing Security Plans for Federal Information Systems; NIST SP 800-53,
Recommended Security Controls for Federal Information Systems and NIST SP 800-53A, Guide
for Assessing the Security Controls in Federal Information Systems and Organizations, Building
Effective Security Assessment Plans.
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.
No questions are asked of a sensitive nature.
12. Provide an estimate in hours of the burden of the collection of information.
Under the Hawaii longline limited entry program, 128 (164 maximum) vessels are currently
registered, 39 large vessels are registered in the American Samoa longline limited entry program,
and 5 medium-large vessels are registered to Northern Mariana Islands bottomfish permits. If all
164 Hawaii permits were registered, the total number of vessels requiring VMS would be 208.
The estimated time per response is 4 hours to install a VMS unit, 2 hours to replace a VMS unit,
and 1.5 hours to maintain or repair a VMS unit.

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The vessel owner or representative generally observes the initial installation, which involves a
total of about 40 hours annually (estimated initial installations on 10 replacement vessels x 4
hours per vessel). The vessel owner or representative may also observe any replacement,
estimated at 70 hours per year annually (35 vessels x 2 hours per vessel) or maintenance and
repair at 60 hours annually (40 vessels x 1.5 hours per vessel). Thus, the annual burden is 170
hours.
Annual Estimates:
10 vessels x 4 hours per vessel to install unit = 40 hours
35 vessels x 2 hours per year replacement = 70 hours
40 vessels x 1.5 hours per year maintenance and repair = 60 hours
Total estimated burden hours = 170 hrs
Total estimated responses = 85.
NOAA OLE Pacific Islands Division was consulted to develop these estimates.
Note: The number of VMS units maintained, repaired or replaced annually reflects current
records. Annual maintenance/repair is not performed routinely, but only as clearly needed, due
to budget constraints.
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection.
No direct or indirect costs are imposed on vessel operators by the VMS requirement. The initial
installation and maintenance costs for VMS are sustained by NOAA OLE. The actual position
report airtime costs are paid by NOAA OLE.
14. Provide estimates of annualized cost to the Federal government.
The estimated cost of the total program is $300,000 per year, primarily for messaging costs.
15. Explain the reasons for any program changes or adjustments.
Current OMB inventory of 399 hours included automated transmissions from the Western
Pacific pelagic longline VMS units. These transmissions from the VMS units are no longer
counted in the total annual responses or burden hours because they require no action on the part
of vessel owners or operators.
Adjustments were also made to the number of respondents for American Samoa longline and
CNMI bottomfish fisheries. The revised responses and burden hours provided are estimates of
the number of respondents needing initial installation, replacement, or maintenance and repair of
VMS units.

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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. NMFS and
the Council will use the data for management reports and fishery management plan amendments
and evaluations. However, subsequent use of the data collected over a series of years may
include scientific papers and publications.
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.

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