0364 ss rev 082707

SUPPORTING STATEMENT
GEAR-MARKING REQUIREMENTS FOR ATLANTIC LARGE WHALE TAKE
REDUCTION PLAN
OMB CONTROL NO.: 0648-0364

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
The purpose of this collection of information is to enable the National Marine Fisheries Service
(NMFS) to finalize, via Final Rule RIN 0648-AS01, regulations to modify the Atlantic Large
Whale Take Reduction Plan (ALWTRP). The ALWTRP was developed under section 118 of
the Marine Mammal Protection Act (MMPA) to reduce the mortality and serious injury
(bycatch) of endangered North Atlantic right whales, humpback whales, and fin whales caught
incidentally in U.S. fishing gear. Multiple commercial fisheries throughout the ranges (Maine to
Florida) of these stocks are known to cause incidental mortality and serious injury at levels that
exceed these stock=s potential biological removal (PBR) levels. Under the MMPA, take
reduction plans (TRPs) are required to reduce, within six months of implementation, the
incidental mortality and serious injury of marine mammals taken in the course of commercial
fishing operations to levels below a stock=s PBR. Within five years of implementation, TRPs are
required to reduce incidental mortality and serious injury of marine mammals to insignificant
levels approaching a zero mortality and serious injury rate taking into account the economics of
the fishery, the availability of existing technology, and existing State or regional fishery
management plans. For Northern right whales (right whales) these goals are essentially the same
because PBR has been defined as zero.
In 1996, pursuant to section 118 of the MMPA, NMFS established and convened an Atlantic
Large Whale Take Reduction Team (ALWTRT) to assist in the development of the ALWTRP.
During this process, the ALWTRT provided NMFS with recommended measures designed to
reduce serious injury and mortality to right, humpback, and fin whales from incidental
interactions with commercial fishing gear. To address the continued entanglement of large
whales in commercial fishing gear, NMFS has reconvened the ALWTRT several times and is
now in the process of modifying the ALWTRP to include additional measures to reduce serious
injury and mortality from entanglement. One of these modifications would require marking
fishing gear to collect important information on the type of gear involved in the incidental
mortality and serious injury of entangled whales. Specifically, the final modifications to the
ALWTRP will require fishers to mark surface buoys to identify the vessel registration number,
vessel documentation number, Federal permit number, or whatever positive identification
marking is required by the vessel=s home port state. The final modifications will also extend the
current gear marking scheme of one 4" mark midway along the buoy line to all fishers regulated
under the ALWTRP. The Southeastern U.S. Atlantic shark gillnet fishery will mark only buoy
lines greater than 4 ft (1.2 m) in length. Existing ALWTRP regulations already require one mark
per line for a substantial number of lobster trap/pot and gillnet vessels. This submission includes
these previously regulated fisheries, along with newly regulated fisheries.

1

Under the MMPA, NMFS is required to publish in the Federal Register any proposed changes
with an explanation of these changes, and ultimately, promulgate regulations to implement
and/or modify the TRP. The most recent proposed changes to the ALWTRP were published on
June 21, 2005 (70 FR 35894).
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.
Gear-marking requirements will assist NMFS in obtaining detailed information about which
fisheries or specific parts of fishing gear are responsible for the incidental mortality and serious
injury of right, humpback, and fin whales. Generally, only a portion of gear is recovered from an
entangled whale and it is almost impossible to link that portion of gear to a particular fishery.
Therefore, requiring fishermen to mark surface buoys and the buoy line will provide NMFS with
an additional source of information, which could then be used to determine the gear responsible
for and the location of the entanglement event. Furthermore, information tracing incidental
mortality and serious injury of marine mammals back to specific gear types, gear parts, locations,
and fishermen will assist NMFS and the ALWTRT in focusing future management measures on
specific problem areas and issues, which may avoid unnecessarily regulating fisheries with
overly broad measures. Gear marking will not reduce bycatch in and of itself, but is expected to
facilitate monitoring of entanglement rates and assist in designing future bycatch reduction
measures. The frequency of information use will be primarily correlated with the occurrence of
entangled whales and/or the recovery of entangled gear.
NMFS seeks to implement the gear-marking requirements in as simple a manner as possible and
as compatibly with other state or federal fishery management plans and TRPs as possible.
NMFS developed the final gear-marking requirements with the assistance of its fishing industry
liaisons, feedback from ALWTRT members, and public comments received on a proposed rule.
Because fishery-related mortality has been difficult to determine and assess, gear-marking
requirements may not only assist in obtaining valuable gear interaction information from future
entanglement events, but may also be a useful tool for measuring compliance.
The information collected will be disseminated to the public or used to support publicly
disseminated information. As explained in the preceding paragraphs, the information gathered
has utility. NMFS will retain control over the information and safeguard it from improper
access, modification, and destruction, consistent with National Oceanic and Atmospheric
Administration (NOAA) standards for confidentiality, privacy, and electronic information. See
response #10 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. Prior to dissemination, the information will be subjected to quality control measures
and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.

2

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.
There is no use of automated or electronic or other technological techniques associated with the
gear-marking scheme.
4. Describe efforts to identify duplication.
Presently, gear marking (lobster trap/pots, gillnets, and associated surface gear) is required under
several Federal and state fishery management plans. NMFS is implementing this requirement to
complement existing Federal or state fishery management plans and TRPs.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The most recent information collection (2005) affected the following fisheries: Cape Cod Bay
Restricted Area lobster and gillnet fisheries; Great South Channel lobster and gillnet fisheries;
Stellwagen Bank/Jeffreys Ledge Restricted Area lobster and gillnet fisheries; Northern
Nearshore lobster fisheries; Southern Nearshore lobster fisheries; Offshore lobster fisheries; and
Other Northeast gillnet fisheries. In addition to the fisheries listed above, this collection of
information will affect the following newly regulated fisheries: Northern Inshore and Lobster
Management Area (LMA) 6 lobster trap/pot fisheries; Atlantic blue crab trap/pot fisheries;
Atlantic mixed species trap/pot fisheries targeting crab (red, Jonah, and rock), hagfish, finfish
(black sea bass, scup, tautog, cod, haddock, pollock, redfish, and white hake), conch/whelk, and
shrimp; Northeast driftnet; Northeast anchored float gillnet; Mid/South-Atlantic gillnet; and
Southeast Atlantic gillnet. These fisheries are composed almost entirely of small businesses.
NMFS minimized the burden on fishermen by evaluating the existing state/federal gear-marking
requirements and developing new, non-duplicative regulations that will allow for the continued
use of the previous marking requirements without promulgating new requirements where they
previously existed. For example, the majority of fishermen already mark their buoys with their
vessel or permit number; therefore, NMFS assumes that this final action places no additional
burden on fishermen.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The final gear-marking requirements are designed to help NMFS improve the quality of
information concerning the taking of endangered right, humpback, and fin whales incidental to
commercial fishing operations. Specifically, information collected through gear marking will
help NMFS and the ALWTRT identify commercial fisheries that interact with federally
protected marine mammals and may result in mortality and serious injury. Accordingly, this
information will be used to tailor management measures to reduce the risk of mortality and
serious injury of marine mammals incidental to commercial fishing operations.
Without the information provided by the final gear-marking requirements regarding where
entanglements occur and what type of gear is involved, future management measures may be
overly broad and affect more individuals than necessary. Therefore, knowing which geographic
3

areas and fisheries pose the greatest risk to large whales will minimize the economic impact to
fishermen while maximizing the benefits for these species.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
There are no special circumstances associated with this final rule that would require the
collection of information to be conducted in a manner inconsistent with Office of Management
and Budget (OMB) guidelines.
8. Provide a copy of 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.
NMFS solicited public comments on both the Draft Environmental Impact Statement (DEIS) (70
FR 9306, February 25, 2005; 70 FR 15315, March 25, 2005) and proposed rule (70 FR 35894,
June 21, 2005; 70 FR 40301, July 13, 2005) through several different means including written
comment. The public also had the opportunity to provide oral comments at 13 public hearings
held in the states of Maine, Massachusetts, Rhode Island, New Jersey, Maryland, Virginia, North
Carolina, and Florida.
Many commenters expressed support for the marking of commercial fishing gear, as the action
would provide more information about entanglements, enhance mitigation efforts, and be useful
as a research and monitoring tool. However, they did not support the expanded gear marking
strategy for buoy lines as proposed by NMFS. Commenters were opposed to the proposed
scheme (e.g., one 4-inch mark every 10 fathoms) for various reasons and requested NMFS to
devise a better gear marking strategy. Some felt that marking buoy lines every 10 fathoms
would be too time-consuming and also excessive as buoys and traps are already marked under
current lobster fishing rules. Others stated that the proposed scheme would be burdensome and
potentially dangerous to implement while at sea, especially in unfavorable sea states or in deep
waters. Several commenters felt the strategy would be impracticable and costly as fishermen are
constantly replacing fouled lines and marks become less visible over time due to algal growth
and basic wear and tear. Many commenters noted the inadequacies of the proposed gear
marking scheme for buoy lines, stating that it did not require all parts of the gear to be marked,
would not identify specific regions or fisheries, and would provide limited information that could
be tracked and evaluated. Several commenters also noted that the gear marking strategy should
be more consistent with schemes implemented by other protected species’ Take Reduction Plans,
Regional Fishery Management Councils, or other NMFS Fishery Management Plans. Lastly,
gear marking provides no direct risk reduction to whales, thus some commenters felt that this,
coupled with the increase in marking increments, may cause reluctance among fisherman to
comply with the new regulations.
Based on these comments, NMFS is not finalizing the proposed scheme of marking buoy lines
with one, colored 4-inch mark every 10 fathoms. Instead, NMFS will require all previously and
4

newly regulated fisheries to mark gear with one, colored 4-inch mark mid-way on the buoy line
(i.e., status quo for previously regulated fisheries). Additionally, all surface buoys will be
required to identify the vessel registration number, vessel documentation number, Federal permit
number, or whatever positive identification marking is required by the vessel’s home-port state.
NMFS will continue to discuss gear marking strategies and whether any future changes are
needed with the ALWTRT at future meetings.
In addition to the comment period on the proposed rule and DEIS noted above, NMFS has
provided numerous other opportunities for the public to comment on the gear marking
requirements. In April 2003, NMFS convened the ALWTRT to provide management
recommendations to NMFS for reducing the risk of serious injury and mortality of right,
humpback, and fin whales incidental to commercial fishing operations. NMFS asked the
ALWTRT for feedback on gear marking. Subsequently, NMFS held several subgroup meetings
during the spring and summer of 2003 to solicit recommendations from ALWTRT members by
region or gear type. Additionally, NMFS held six public scoping meetings from Maine to
Florida to seek input from interested stakeholders on issues including gear marking in order to
develop alternatives for a DEIS that would analyze modifications to the ALWTRP. The public
also had the opportunity to submit written comments throughout the scoping period. NMFS
provided a scoping document to the public that included gear-marking options and asked for
comment from the public on these and any suggested management measures for modifying the
ALWTRP.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
There is no provision to provide any payment or gift to participants in the gear-marking scheme
contained in this final rule.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Information collected from the gear is considered confidential by NMFS, in accordance with
Confidentiality of Statistics of the Magnuson-Stevens Fishery Conservation and Management
Act; 50 CFR 229.11, Confidential fisheries data; and NOAA Administrative Order 216-100 Protection of Confidential Fisheries Statistics. The agency will not release this information in
any format that could allow the public to identify any fisherman individually. In general, the
information collected during this rulemaking action falls under the types of statistics covered
under 50 CFR 600.405. Specifically, the analysis of the final rule required information
regarding the types and quantity of fishing gear used, the areas in which fishing occurred, and
the time of fishing. Information and data, including statistics that may be considered as
confidential were used in the analysis of impacts associated with the final action. This
information was necessary to assess the biological, social, and economic impacts of the final
action as required under the National Environmental Protection Act (NEPA) and Regulatory
Flexibility Act (RFA). Under 50 CFR 229.11 and NOAA Administrative Order 216-100,
proprietary information collected, including information or data identifiable with an individual
fisherman, was not disclosed except as authorized by the enumerated exceptions provided under
sections 229.11(a)(1)-(5) and

5

600.415(b)(1)-(5). In addition, the information made available to the public was done so in
aggregate, summary, or other such form that does not disclose the identity or business of any
person in accordance with NOAA Administrative Order 216-100.
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.
Not applicable.
12. Provide an estimate in hours of the burden of the collection of information.
According to the information collection renewal request filed in 2005, the current number of
responses already employed by vessels is 257,216 annually. 1 In addition, the renewal request
estimated that vessels currently incur a burden of 2,572 hours per year to mark gear. It is
important to note that the methods and assumptions employed in the 2005 renewal request are
different than those employed for this supporting statement. A brief description of the
differences between the approaches is provided in #15.
This gear-marking scheme is presented in the Final Environmental Impact (FEIS) under
Alternative 6 Final (Preferred). The labor and materials burden associated with the gear marking
requirements is based on the number of marks each vessel would need to install.
To demonstrate the methodology used to estimate labor and material costs, we present the
following analysis of a typical hagfish pot vessel fishing in northern nearshore waters, as
regulated under Alternative 6 Final (Preferred). The burden hours and costs estimated in the
following example are immediate; i.e., incurred within six months of publication of the rule.
Average number of trawls per vessel = 25 trawls
Average number of buoy lines per trawl = 2 buoy lines
Average number of buoy lines per vessel = 25 * 2 = 50 buoy lines
Average number of marks per vessel = 50 marks
Time to install a single buoy line mark = 5 minutes
Hours burden per vessel = 5 minutes * 50 marks = 250 minutes = 4 hours and 10 minutes.
The process described above is repeated for each model vessel affected by Alternative 6 Final
(Preferred). These estimates of hourly burden and material costs are then multiplied by the
estimated number of vessels represented by each model vessel.
The resulting values for all vessel groups are then summed to estimate the total impact of the
new and current gear marking provisions of the ALWTRP. Under Alternative 6 Final
(Preferred), the estimated number of vessels newly affected by the gear marking provisions is
1

A response or mark, in this instance, is a four inch mark midway along the length of each buoy line. The
majority of fishermen already mark their buoys with the vessel number or permit number; therefore, we assume this
provision places no additional costs on fishermen.

6

2,699. The estimated number of vessels currently affected by the gear marking provisions is
1,571, resulting a combined total of 4,270 vessels.
Averaged over the first three years after the publication of the final rule, the newly affected
vessels will employ 162,837 responses annually, while currently affected vessels will employ
40,908 responses annually, resulting in a total of 203,745 responses per year. The average
annual burden over the first three years will be 13,567 hours for newly affected vessels and
3,408 for currently affected vessels, resulting in a total of 16,975 burden hours per year.
Attachment A provides hours burden estimates for the newly and currently affected model vessel
groups by year.
13. Provide an estimate of the total annual cost burden to the respondents or record-keepers
resulting from the collection (excluding the value of the burden hours in #12 above).
Exhibit 1 presents the average annual cost burden per vessel for the first three years after the
publication of the final rule, under Alternative 6 Final (Preferred). The immediate average cost
burden (for materials) for newly affected vessels is approximately $6.61 per vessel, with the cost
of a single buoy line mark being $0.055. Over the first three years, the average reporting cost
burden for newly affected vessels is $3.32 per vessel. For currently affected vessels, the
average reporting cost burden is $1.43 per year.
Exhibit 1
Estimated Annual Change in Costs Per Vessel Alternative 6
Final (Preferred) for Newly and Currently Affected Vessels
Costs (2007$) for
Costs (2007$) for
Year
Newly Affected
Currently Affected
Vessels
Vessels
Year 1a
$6.61
$1.43
Year 2b
$1.67
$1.43
b
Year 3
$1.67
$1.43
Per Vessel Averagec
$3.32
$1.43
Notes:
a
The Year 1 cost burden represents the immediate cost of marking
all buoy lines, which is required within six months of publication of
the rule.
b
Years 2 and 3 represent the second and third years after the
publication of the final rule.
c
See consolidated burden table for calculations employed during this
analysis.

The annual cost burden over the first three years after publication of the final rule is estimated to
be $8,954 for newly affected vessels and $2,249 for currently affected vessels, resulting in a total
cost burden of $11,203 per year. The consolidated burden table (see below) provides cost burden
estimates for the newly affected model vessel groups by year.
14. Provide estimates of annualized cost to the Federal government.
Neither the current, ongoing gear-marking requirements nor the gear-marking requirement
contained in this final rule are expected to have any annualized costs to the Federal government.
7

15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
The changes in Item 13 and Item 14 of the OMB 83-I form are the result of adjustments to the
estimates provided in the Information Collection Request (ICR) renewal filed in 2005, and the
new requirements (program changes) being finalized under Alternative 6 Final (Preferred) of the
FEIS and final rule.
As stated in questions 12 of this supporting statement, the methods and assumptions employed in
the 2005 ICR renewal are different than those employed for this supporting statement. These
adjustments include:
•

The 2005 renewal request estimates that approximately 4,500 vessels are affected
by the information collection. This information collection, based on data
employed during FEIS economic analysis, estimates that 1,571 vessels are
currently affected by ALWTRP gear marking requirements.

•

The 2005 renewal request assumed that all fishermen mark all of their buoy lines
on an annual basis. For this information collection, we assume fisherman that are
currently required to mark their gear will only mark new buoy lines employed to
replace those that have been worn out. Consistent with the FEIS economic
analysis, we assume the replacement schedule for buoy line ranges from every
three to four years based on the type of buoy line employed and geographic area
fished.

•

The 2005 renewal request assumed that all vessels within a fishery operate using
the same gear configuration, whereas the current analysis assigns different gear
configurations (and thus a different number of buoy line marks) by model vessel.
Each model vessel represents a group of vessels that face similar regulatory
requirements and operate with a similar quantity and configuration of gear.

•

The 2005 renewal request assumed that fisherman would install a buoy line mark
by painting a four-inch mark mid-way along the buoy line, which was estimated
to take 0.6 minutes (36 seconds) per mark. However, this information collection
assumes, based on recommendations of NMFS gear specialist, that fisherman will
thread a colored “whip” mid-way along the buoy line to create the mark, and it is
estimated to take 5 minutes to install each whip. The latter approach is a more
conservative estimate that is consistent with the assumptions employed in the
FEIS economic analysis.

Exhibit 2, below, presents the changes in burdens resulting from adjustments to the methodology
and changes to the program being finalized under Alternative 6 Final (Preferred) of the FEIS and
final rule. The number of annualized responses will decrease from 257,216 to 203,746.
Currently affected vessels will employ 40,908 responses annually, which represents a decrease
of 216,308 responses from the previous estimate found in the 2005 renewal request. Newly
affected vessels will employ 162,837 responses annually. The annualized burden hours will
8

increase from 2,572 hours to 16,975 hours. Currently affected vessels will incur an annual
burden of 3,408 hours, which represents an increase of 836 hours from the estimate found in the
2005 renewal request. Newly affected vessels will incur an annual burden of 13,567 hours. The
annualized cost burden will decrease from $15,433 to $11,204. Currently affected vessels will
incur a cost burden $2,249, which represents a decrease in cost burden of $13,184 from the
estimate found in the 2005 ICR renewal. Newly affected vessels will incur an annual cost
burden of $8,954.
Exhibit 2
Changes to Burden Estimates Resulting from Adjustments to Methodology and Changes to ALWTRP Gear
Marking Program
Newly Affected
Difference
Estimate
Estimate Using
Vessels
Between 2005
Methodology
According to
Resulting from
Total Burden
ICR Renewal
2005 ICR
Employed in
Program
and FEIS
Renewal
the FEIS
Changes
Methodology
Calculation
(A)
(B)
(B-A)
(C)
(B+C)
Annualized
257,216
40,908
-203,745
162,837
203,745
Number of
Responses
Annualized
2,572
3,408
836
13,567
16,975
Hours Burden
(hours)
Annualized
$15,433
$2,249
-13,184
$8,954
$11,203
Cost Burden
(dollars)

16. For collections whose results will be published, outline the plans for tabulation and
publication.
There are no plans to publish the results of this collection per se. Information about gear and
areas involved in entanglements might be published as part of some broader report or analysis,
such as regularly published Marine Mammal Stock Assessment Reports. No information on the
identity of individual fishers, if available, will be published. Any such broader report or analysis
will be subject to quality control measures and pre-dissemination review pursuant to Section 515
of Public Law 106-554 prior to dissemination.
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 identified in Item 19 of the
OMB 83-I.
There are no exceptions.

9

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information does not employ statistical methods.

10

ATTACHMENT A: CONSOLIDATED BURDEN TABLE - GEAR-MARKING REQUIREMENTS FOR THE ATLANTIC LARGE WHALE TAKE REDUCTION PLAN (ALWTRP)
A

B

C

D

Responses in
Years 2 & 3
Combined

F

TOTAL
Responses Years
1-3 Combined

G

H

I

J

K

L

M

N

TOTAL Time
Annual Time Time Burden in Burden in
Years 1-3
Burden in
Annual Cost
Cost Burden in
TOTAL Cost
Years 2 & 3
Combined
Years 2 & 3
Burden in Years Years 2 & 3 Burden in Years1-3 Year 1 Time
Combined
(hours)
(hours)
2&3
Combined
(hours)
Combined
Burden (hours)

Estimated
Number of
Affected Vessels

Number of
Marks Per
Model Vessel

5

160

776

4

93

343

86

171

514

$18.86

$4.71

$9.43

$28.29

28.6

7.1

14.3

42.9

74

300

22,194

5,548

11,097

33,291

$1,220.66

$305.16

$610.33

$1,830.98

1,849.5

462.4

924.7

2,774.2

Year 1
Responses

Annual
Responses in
Years 2 & 3

E

Year 1 Cost
Burden

Estimated Burden for Vessels Newly Required to Mark Gear Under the ALWTRP

Lobster

Gillnet

OTP

SUBTOTAL
Per Vessel Average

194

388

1,165

$42.71

$10.68

$21.35

$64.06

64.7

16.2

32.4

97.1

74

60

4,439

1,110

2,219

6,658

$244.13

$61.03

$122.07

$366.20

369.9

92.5

184.9

554.8

75

300

22,369

5,592

11,184

33,553

$1,230.28

$307.57

$615.14

$1,845.43

1,864.1

466.0

932.0

2,796.1

75

60

4,474

1,118

2,237

6,711

$246.06

$61.51

$123.03

$369.09

372.8

93.2

186.4

559.2

2

60

140

47

93

233

$7.70

$2.57

$5.13

$12.83

11.7

3.9

7.8

4

60

247

82

165

412

$13.58

$4.53

$9.06

$22.64

20.6

6.9

13.7

34.3

552

300

165,590

41,398

82,795

248,386

$9,107.47

$2,276.87

$4,553.74

$13,661.21

13,799.2

3,449.8

6,899.6

20,698.8

552

60

33,118

8,280

16,559

49,677

$1,821.49

$455.37

$910.75

$2,732.24

2,759.8

690.0

1,379.9

4,139.8

78
78

300
60

23,373
4,675

5,843
1,169

11,686
2,337

35,059
7,012

$1,285.49
$257.10

$321.37
$64.27

$642.75
$128.55

$1,928.24
$385.65

1,947.7

486.9

973.9

2,921.6

389.5

97.4

194.8

584.3

564

12

6,510

2,170

4,340

10,850

$358.06

$119.35

$238.71

$596.77

542.5

180.8

361.7

904.2

42

12

486

162

324

810

$26.75

$8.92

$17.83

$44.58

40.5

13.5

27.0

1

12

6

2

4

10

$0.32

$0.11

$0.21

$0.53

0.5

0.2

0.3

0.8

77

9

683

228

455

1,138

$37.57

$12.52

$25.04

$62.61

56.9

19.0

37.9

94.9

9

12

102

34

68

169

$2.80

$0.93

$1.86

$4.66

4.2

1.4

2.8

7.1

19.4

67.5

3
1

4
4

12
4

4
1

8
3

20
7

$0.66
$0.22

$0.22
$0.07

$0.44
$0.15

$1.10
$0.37

1.0

0.3

0.7

0.3

0.1

0.2

0.6

2

50

110

28

55

166

$6.07

$1.52

$3.04

$9.11

9.2

2.3

4.6

13.8

<1

150

50

13

25

75

$2.75

$0.69

$1.38

$4.13

4.2

1.0

2.1

6.3

1.7

2

25

42

11

21

64

$2.33

$0.58

$1.17

$3.50

3.5

0.9

1.8

<1

75

25

6

13

38

$1.38

$0.34

$0.69

$2.06

2.1

0.5

1.0

3.1

2

50

116

29

58

174

$6.36

$1.59

$3.18

$9.55

9.6

2.4

4.8

14.5

2

83

190

48

95

286

$10.48

$2.62

$5.24

$15.71

15.9

4.0

7.9

23.8

$5.24

5.3

4

50

190

48

95

286

$10.48

$2.62

$15.71

15.9

24

100

2,362

590

1,181

3,543

$129.90

$32.48

$64.95

$194.86

196.8

49.2

98.4

295.2

133

50

6,639

1,660

3,319

9,958

$365.14

$91.29

$182.57

$547.71

553.2

138.3

276.6

829.9

53

4.0

7.9

23.8

150

8,008

2,002

4,004

12,011

$440.41

$110.10

$220.21

$660.62

667.3

166.8

333.6

1,000.9

26

50

1,294

324

647

1,941

$71.18

$17.79

$35.59

$106.77

107.8

27.0

53.9

161.8

1

50

33

8

17

50

$1.83

$0.46

$0.92

$2.75

2.8

0.7

1.4

1

83

42

10

21

63

$2.29

$0.57

$1.15

$3.44

3.5

0.9

1.7

5.2

8

25

195

49

98

293

$10.74

$2.69

$5.37

$16.11

16.3

4.1

8.1

24.4

2

75

156

39

78

234

$8.59

$2.15

$4.30

$12.89

13.0

3.3

6.5

19.5

2

50

75

19

38

113

$6.23

6.3

1.6

3.1

9.4

2

42

83

21

42

125

$4.58

$1.15

$2.29

$6.88

6.9

1.7

3.5

10.4

2

25

58

15

29

88

$3.21

$0.80

$1.60

$4.81

4.9

1.2

2.4

7.3

4

50

200

50

100

300

$11.00

$2.75

$5.50

$16.50

16.7

4.2

8.3

25.0

<1

50

7

2

4

11

$0.39

$0.10

$0.20

$0.59

0.6

0.1

0.3

0.9

1

50

33

8

17

50

$1.83

$0.46

$0.92

$2.75

2.8

0.7

1.4

4.2

1

100

50

13

25

75

$2.75

$0.69

$1.38

$4.13

4.2

1.0

2.1

6.3

<1

50

17

6

11

28

$0.93

$0.31

$0.62

$1.56

1.4

0.5

0.9

2.4

<1

22

8

3

5

13

$0.41

$0.14

$0.28

$0.69

0.6

0.2

0.4

1.0

<1

22

4

1

2

7

$0.24

$0.06

$0.12

$0.36

0.4

0.1

0.2

<1

22

8

2

4

11

$0.41

$0.10

$0.21

$0.62

0.6

0.2

0.3

0.9

6

50

289

96

192

481

$15.88

$5.29

$10.58

$26.46

24.1

8.0

16.0

40.1

3

150

488

163

325

813

$26.81

$8.94

$17.88

$44.69

40.6

13.5

27.1

67.7

2

22

41

14

27

68

$2.23

$0.74

$1.49

$3.72

3.4

1.1

2.3

5.6

2

83

167

56

111

278

$9.17

$3.06

$6.11

$15.28

13.9

4.6

9.3

23.1

2

8

12

4

8

20

$0.66

$0.22

$0.44

$1.10

1.0

0.3

0.7

1.7

1

50

42

14

28

69

$2.29

$0.76

$1.53

$3.82

3.5

1.2

2.3

5.8

2

8

12

4

8

20

$0.66

$0.22

$0.44

$1.10

1.0

0.3

0.7

1.7

<1

25

4

1

3

7

$0.23

$0.08

$0.16

$0.39

0.4

0.1

0.2

0.6

<1

22

3

1

2

5

$0.17

$0.06

$0.12

$0.29

0.3

0.1

0.2

<1

22

3

1

2

5

$0.17

$0.06

$0.12

$0.29

0.3

0.1

0.2

0.4

2

50

100

33

67

167

$5.50

$1.83

$3.67

$9.17

8.3

2.8

5.6

13.9

<1

50

51

13

25

76

$2.80

$0.70

$1.40

$4.20

4.2

1.1

2.1

<1

150

38

9

19

56

$2.06

$0.52

$1.03

$3.09

3.1

0.8

1.6

4.7

1

83

83

21

42

125

$4.58

$1.15

$2.29

$6.88

6.9

1.7

3.5

10.4

46

50

2,300

575

1,150

3,450

$126.50

$31.63

$63.25

$189.75

191.7

47.9

95.8

287.5

46

110

5,059

1,265

2,529

7,588

$278.24

$69.56

$139.12

$417.36

421.6

105.4

210.8

632.4

39

150

5,775

1,444

2,888

8,663

$317.63

$79.41

$158.81

$476.44

481.3

120.3

240.6

721.9

5
2

103
50

543
88

136
22

271
44

814
131

$29.84
$4.81

$7.46
$1.20

$14.92
$2.41

$44.76
$7.22

45.2

11.3

22.6

7.3

1.8

3.6

10.9

324,633
120

81,939
30

163,879
61

488,512
181

$17,852.01
$6.61

$4,505.73
$1.67

$9,011.47
$3.34

$26,863.48
$9.95

27,048.5

6,826.9

13,653.7

40,702.2

10.0

2.5

5.1

15.1

$78.61

39.7

39.7

79.4

119.1

2,699

$4.15

$1.04

$2.08

4.2

0.6

0.4

6.4

67.8

Estimated Burden for Vessels Currently Required to Mark Gear under the ALWTRP

Lobster Current

Gillnet Current

20

93

476
146

476
146

953
292

1,429
439

$26.20
$8.04

$26.20
$8.04

$52.40

6

93

10

93

227

227

454

681

$12.49

$12.49

$24.97

$37.46

18.9

18.9

37.8

56.8

200

93

4,676

4,676

9,353

14,029

$257.21

$257.21

$514.41

$16.08

$771.62

$24.12

389.7

389.7

779.4

1,169.1

4

93

83

83

166

249

$4.57

$4.57

$9.15

$13.72

6.9

6.9

13.9

20.8

12.2

12.2

24.4

36.5

395

93

9,216

9,216

18,432

27,648

$506.88

$506.88

$1,013.76

$1,520.64

768.0

768.0

1,536.0

2,304.0

68

300

5,126

5,126

10,252

15,379

$281.94

$281.94

$563.89

$845.83

427.2

427.2

854.4

1,281.6

170.9

256.3

68

60

1,025

1,025

2,050

3,076

$56.39

$56.39

$112.78

$169.17

85.4

85.4

52

300

3,907

3,907

7,814

11,721

$214.89

$214.89

$429.78

$644.67

325.6

325.6

651.2

976.8

52

60

781

781

1,563

2,344

$42.98

$42.98

$85.96

$128.93

65.1

65.1

130.2

195.4

2

60

36

36

71

107

$1.96

$1.96

$3.92

$5.89

3.0

3.0

5.9

8.9

<1

60

8

8

16

25

$0.45

$0.45

$0.91

$1.36

0.7

0.7

1.4

2.1

4

60

83

83

167

250

$4.59

$4.59

$9.18

$13.77

7.0

7.0

13.9

20.9

146

60

2,921

2,921

5,843

8,764

$160.68

$160.68

$321.36

$482.03

243.5

243.5

486.9

730.4

83

93

1,929

1,929

3,858

5,787

$106.09

$106.09

$212.19

$318.28

160.7

160.7

321.5

482.2

5

300

341

341

682

1,023

$18.76

$18.76

$37.52

$56.29

28.4

28.4

56.9

5

60

68

68

136

205

$3.75

$3.75

$7.50

$11.26

5.7

5.7

11.4

17.1

98
98

300
60

7,387
1,477

7,387
1,477

14,775
2,955

22,162
4,432

$406.31
$81.26

$406.31
$81.26

$812.62
$162.52

$1,218.93
$243.79

615.6

615.6

1,231.2

1,846.9

123.1

123.1

246.2

369.4

1

12

2

2

5

7

$0.13

$0.13

$0.27

$0.40

0.2

0.2

0.4

0.6

3

12

10

10

20

29

$0.54

$0.54

$1.08

$1.62

0.8

0.8

1.6

2.5

9

12

36

36

71

107

$1.96

$1.96

$3.93

$5.89

3.0

3.0

5.9

8.9

4

12

15

15

30

45

$0.82

$0.82

$1.64

$2.45

1.2

1.2

2.5

3.7

6

12

25

25

50

76

$1.39

$1.39

$2.78

$4.17

2.1

2.1

4.2

4

12

15

15

30

45

$0.83

$0.83

$1.66

$2.50

1.3

1.3

2.5

3.8

168

12

655

655

1,311

1,966

$36.05

$36.05

$72.10

$108.16

54.6

54.6

109.2

163.9

9

12

34

34

68

102

$0.93

$0.93

$1.86

$2.80

1.4

1.4

2.8

4.2

51
<1

12
12

SUBTOTAL
Per Vessel Average

1,571

TOTAL

4,270

Per Vessel Average

85.3

6.3

198
1

198
1

395
2

593
3

$10.86
$0.05

$10.86
$0.05

$21.73
$0.11

$32.59
$0.16

16.5
0.1

0.1

0.2

0.2

40,908
26

40,908
26

81,817
52

122,725
78

$2,249.02
$1.43

$2,249.02
$1.43

$4,498.05
$2.86

$6,747.07
$4.30

3,408

3,408

6,815

10,223

2.2

2.2

4.3

6.5

365,541

122,848

245,695

611,237

$20,101.04

$6,754.76

$13,509.52

$33,610.56

30,456.1

10,234.5

20,469.0

50,925.1

86

29

58

143

$4.71

$1.58

$3.16

$7.87

7.1

2.4

4.8

11.9

Notes:
Sums and products may not total due to rounding.
The Year 1 cost burden represents the immediate cost of marking all buoy lines, which is required within six months of publication of the rule.
Years 2 and 3 represent the second and third years after the publication of the final rule.

Newly Affected
Currently
Vessels
Affected Vessels

Total Affected
Vessels

Annualized number of responses over first three years (Column F divided by 3)
162,837

40,908

13,567

3,408

203,745
16,975

$8,954

$2,249

$11,203

Annualized number of rule-related hours over first three years (Column N total divided by 3)
Annualized number of rule-related recordkeeping costs over first three years (Column J total divided by 3)

16.5

32.9

49.4