0338 ss ren 031808

SUPPORTING STATEMENT
IMPLANTATION AND RECOVERY OF ARCHIVAL TAGS
OMB CONTROL NO.: 0648-0338

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
The purpose of the collection of this information is to assist in compliance with the Atlantic
Tunas Convention Act of 1975 (ATCA, 16 U.S.C. 971), the Magnuson-Stevens Fisheries
Conservation and Management Act (Magnuson-Stevens Act, 16 U.S.C. 1812), and Federal
regulations at 50 CFR 635. ATCA authorizes the promulgation of regulations to implement
recommendations adopted by the International Commission for the Conservation of Atlantic
Tunas (ICCAT) and collect information to support these recommendations. Atlantic highly
migratory species (HMS) such as tuna, shark, swordfish, and billfish are also managed under the
authority of the Magnuson-Stevens Act, which gives NOAA Fisheries the authority to conduct
and promote fisheries research, and requires that the United States cooperate with those
international organizations involved in the conservation of HMS.
As a member of ICCAT, the United States takes part in the collection of HMS biological
statistics for research purposes. The collection of information through the U.S. HMS archival
tagging program provides essential stock assessment information for international and domestic
fishery management. The tagging program has provided and continues to provide vital
information regarding the movement and life history of bluefin tuna and billfish.
Archival tags are miniature data loggers that record the movements, geoposition, and behavior of
individually tagged highly migratory species. The tags are returned to the agency by fishermen
after a tagged fish is captured in a commercial or recreational fishery. Data from recovered tags
is used to ascertain HMS life history information such as migratory patterns and spawning site
fidelity. This information is vital for international and U.S. management of HMS fisheries. For
example, data from this tagging program was recently presented at an ICCAT intersessional
meeting reviewing bluefin tuna stock composition. Bluefin management has been based on a
two stock hypothesis (with spawning occurring in two discrete locations in the Mediterranean
and Gulf of Mexico); however, additional information collected through tags may help provide a
better understanding of the migratory nature and potential spawning areas for bluefin tuna. Data
from the archival tagging program will continue to be an integral part of this debate.
This Paperwork Reduction Act package renewal covers two reporting requirements associated
with the archival tag program. Current National Oceanic and Atmospheric Administration,
National Marine Fisheries Service (NOAA Fisheries) regulations (50 CFR '635.33) allow
fishermen to retain any HMS with an archival tag implanted or attached without regard to season
or size limits, under the condition that the fisherman report the landing to NOAA Fisheries along
with certain information about the catch, and make the fish available to NOAA Fisheries for
recovery of the tag.
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NOAA Fisheries regulations also require that researchers using archival tags for HMS notify
NOAA Fisheries in writing before and after project completion, including information such as
the type and number of tags used, the species and approximate size of the tagged fish, and the
location and method of capture of the tagged fish.
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.
As described above, there are two sets of reporting requirements. The information provided by
HMS fishermen will include the archival tag, location of capture, and captured fish. This
information will be used to analyze facets of the life history of tagged fish.
The information provided by researchers will include notification of project initiation, and a
summary of project results. This information is needed to assist the agency in assessing the
effectiveness of archival tag research and the impact of regulatory allowances for tag recovery,
and to ensure that archival tag research does not lead to undue mortality, in addition to the
information generated by the tagging program itself, as discussed above.
It is anticipated that 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. NOAA Fisheries will retain control over the information and
safeguard it from improper access, modification, and destruction, consistent with 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 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.
Archival tags have been specifically designed for use on fish, sea turtles, and marine mammals.
The archival tag stores environmental and behavioral data. Software provides graphical
representation of all the data. Tags currently on the market weigh 25g in air, have up to one
megabyte of memory, can retain data for 20 years, and have a lifetime of four to five years.
Archival tag information can be reported at the toll-free number (800) 437-3936, or by
contacting: National Marine Fisheries Service, Highly Migratory Species, 1315 East West
Highway, Silver Spring, MD 20910.

4. Describe efforts to identify duplication.
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Reports submitted to NOAA Fisheries from researchers planning an archival tagging program
for HMS will provide for coordination of tagging programs in order to ensure that duplication of
tagging programs will not take place. Given the expense of this research, relatively few parties
will be involved and a high level of coordination with the researchers will be maintained, which
will provide an avenue to avoid any duplication of reporting requirements within NOAA. Other
reporting within NOAA that could be required of researchers includes grant reports (if a NOAA
grant is issued) or interim and final exempted fishing permit reports. If these other reports
contain the necessary information and are available in the timeframe required under 50 CFR
'635.33, they may be submitted to satisfy the reporting requirements approved under this
collection.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
There will be no significant impact on small businesses or entities.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The tagging program could not be conducted without the reporting requirements, since collecting
tag returns is an integral part of a tagging program. If the tagging program were not conducted,
domestic and international management of HMS would be compromised, and could be rendered
ineffective because of the lack of necessary life history information.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The collection is consistent with the guidelines.
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 published on October 31, 2007 solicited public comment on this
renewal. No comments were received.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
A $1,000 reward is offered for the recovery of an archival tag. Given the high cost of each tag
and tag deployment, a reward to encourage recovery of the tags is warranted. Rewards in
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conventional tagging programs are common and have been found to enhance recovery numbers.
The high value of an individual giant tuna on the export market (thousands of dollars) also calls
for a reward as an incentive for reporting and providing the fish for sampling. Finally, tags may
be recovered by fishermen outside the waters of the United States in the eastern Atlantic or the
Mediterranean Sea, and a reward increases the likelihood that they will report.
10. Describe any assurance or confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Information submitted will be treated as confidential under the provisions of the MagnusonStevens Fishery Management and Conservation Act and 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.
No sensitive questions are asked.
12. Provide an estimate in hours of the burden of the collection of information.
Approximately 25 tags are recovered and reported on per year. The estimated time for reporting
on the fish is 30 minutes, which includes the time for making a toll-free call, making
arrangements for the fish to be examined by a fishery biologist or to remove the tag, and
processing fish samples as instructed. The burden for tag recovery is therefore:
25 respondents x 1 response x 30 minutes = 12.5 (13) hours
The total number of persons implanting archival tags is estimated at 5 researchers, each
providing a written notification and a written report.
5 respondents x 1 notification x 30 minutes/notification = 2.5 (3) hours
5 respondents x 1 report x 1 hr/report = 5 hours
Collection totals are 30 respondents, 35 responses, and 21 hours.

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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 #12
above).
There are no costs for those recovering tags, since the phone call is toll-free and a reward is
given. Other than paper and postage costs, which are estimated to be $20-$50 per year ($4-$10
per respondent or $2-$5 per response), no incremental costs to researchers are anticipated for
implantation reports.

14. Provide estimates of annualized cost to the Federal government.
The cost of the Archival Tagging Program is approximately $1 million in research grants over a
3-year period. About 75 tags (25 per year) will be returned over the 3 years, with a reward of
$1,000 a tag, for a cost of $75,000. The total Federal cost for 3 years is therefore approximately
$1,075,000, or $358,333 a year.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
The changes in total annual burden hours are adjustments reflecting a re-estimation of the
numbers of respondents and responses. Based on activities over the past three years, an
additional 6 respondents are expected to report landing information: 6 x 30 minutes = 3 hours.
With all hours subtotals being rounded up, total additional hours are actually 4.
The increase of $50 (not shown on the 83i) is an artifact: when the ICR was migrated to ROCIS,
the cost was rounded to zero.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
Results will not be published. The data obtained may be used in reports and articles, which may
be published.
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.
No exceptions are requested.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
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This collection will not employ statistical methods.

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