0349 ss ren 061008 rev

SUPPORTING STATEMENT
HIGH SEAS FISHING VESSEL REPORTING REQUIREMENTS
OMB CONTROL NO. 0648-0349

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
This information collection is necessary to comply with the High Seas Fishing Compliance Act
(HCSFA) (16 U.S.C. 5501 et seq). The collection of information regarding catch and effort on
the high seas by vessels holding HSFCA permits is provided for by Section 104(d)(2) of the
HSFCA. The requirements are contained in regulations at 50 CFR 300.17.
In some cases, regulations promulgated under the Magnuson-Stevens Fishery Conservation and
Management Act (MSFCMA) require that the reporting of catch and effort on the high seas (i.e.,
logbooks that must be used in the U.S. Exclusive Economic Zone (EEZ) must also be filled out
when the reporting vessel is fishing on the high seas. The HSFCA specifically calls upon
National Marine Fisheries Service (NMFS) at Section 105(d) to minimize reporting
requirements, and to the extent practicable, ensure that regulations promulgated under the
HSFCA are consistent with regulations promulgated under the MSFCMA.
To this end, NMFS considers those HSFCA-permitted vessels that already are reporting their
catches and effort on the high seas based on regulations promulgated under the MSFCMA to be
in compliance with HSFCA reporting requirements. This arrangement will avoid imposing any
duplicative reporting requirements on HSFCA permit holders.
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 applicable NOAA Information Quality Guidelines.
The information collected by the HSFCA family of logbooks will be integrated into the national
NMFS fishery statistics system to calculate the catch and effort of United States (U.S.) vessels
on the high seas. The data collected will be used in the management of fisheries. The United
States is also obligated to provide such data to the United Nations Food and Agriculture
Organization (FAO). Aggregated data relating to high seas catches, species composition, effort,
etc., will be compiled and made available to the international community through the FAO.
Each logbook sheet begins by collecting information related to the identity of the vessel and the
vessel operator, the time frame of the activity being reported, the sequential number of the
particular logsheet being filled out, the crew size (of interest from an economics/effort
perspective), and whether an observer is onboard (knowledge of observer presence vs. nonpresence is useful when examining any differences in data reported by observed vs. unobserved
fishing operations). Each logbook sheet also collects, if appropriate, information necessary to
identify specific characteristics of the type of gear used. Finally, each logsheet collects the
standard information items necessary to ascertain catch and effort for the gear type employed.
Note that this renewal cycle adds a new form to the HSFCA family of forms. The new form is
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the High Seas Squid Fishing Log. This form could potentially be used by up to four vessels
fishing in the Western Pacific for squid. However, the addition of this form does not change the
overall burden for this collection because the squid fishing vessels were previously required to
report on the High Seas Fishing Log, which is the general form to be used when a more specific
gear log is not available. It was determined to be worthwhile to develop a log specific to squid
fishing for inclusion with this renewal cycle.
It is anticipated that 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 to Question 10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed to yield data that meet
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.
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.
Long experience in using other logbooks, such as those that served as models for the high seas
logbooks, has revealed these logbooks to be the most practical, efficient and cost effective
method of collecting the needed information. Although not related to information technology, as
previously noted, total burden hours have been kept to a minimum by considering those HSFCA
permit-holders already reporting high seas catch and effort as meeting HSFCA reporting
requirements.
4. Describe efforts to identify duplication.
As noted in Questions 1 and 3 above, duplicative reporting requirements were identified and
eliminated.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The collection will not have a significant impact on small businesses, organizations or
governmental entities.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Failure to conduct the collection would make it impossible for the agency to carry out its
responsibilities under the HSFCA.

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7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Except for the frequency with which data are reported (recorded daily during a fishing period),
this collection is consistent 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.
A Federal Register Notice published on January 9, 2008 (73 FR 1600) solicited public comment
on this renewal.
Only one comment was received. The commenter suggested that respondents do not accurately
report their catch and effort on the high seas log forms and suggested “there should be
enforcement.” In fact, U.S. vessels are subject to random inspection by NMFS and U.S. Coast
Guard law enforcement personnel and inspections include examination of logs and the quantity
of fish onboard to ascertain if accurate data are being recorded in the high seas logs.
Additionally, some vessels are selected to carry scientific observers whose duties include
ensuring that accurate data are being reported.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts will be provided to respondents under this collection.
10. Describe any assurance or confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Data submitted pursuant to this information collection will be accorded confidentiality in
accordance with 50 CFR Part 600, Subpart E.
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 of a sensitive nature are included in this collection.
12. Provide an estimate in hours of the burden of the collection of information.
There will be an estimated 50 respondents (i.e., vessel operators) using one of the high seas
logbooks that are the subject of this collection to report fishing activities on the high seas
throughout the year. For purposes of this calculation, each affected vessel has been estimated to
spend 180 days per year fishing on the high seas (based on 15 days at sea for each of 12 months).
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An estimated average response time of 5 minutes a day for filling out a logbook form has been
estimated. Using these estimates results in an estimated annual burden of 750 hours:
50 vessels x 180 days = 9,000 responses x 5 min/60 min/day = 750 hours.
There will be an estimated 500 respondents using one of the high seas logbooks that are the
subject of this collection to submit negative reports throughout the year. To account for the time
necessary to submit negative reports, 100 hours can be added to the above burden estimate. The
100 hours for negative reports is calculated as follows:
500 respondents x 12 reports = 6,000 responses x 1 min/60/min/report = 100
hours.
The total estimated annual burden for this collection is 550 unduplicated respondents, 15,000
responses, and 850 hours.
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).
Mailing costs for vessels that fished are estimated as follows: $492 for 50 vessels reporting
monthly on 15 days of fishing per month (50 * 12 * $0.82). Mailing costs for vessels that did
not fish are estimated as follows: $2,520 for 500 vessels reporting no monthly fishing (500 * 12
* $0.42). Therefore, total costs are estimated at $3,012.
14. Provide estimates of annualized cost to the Federal government.
Aside from minimal costs associated with reproducing copies of the logsheets for permit holders,
there are only infinitesimal costs associated with this information collection for the Federal
government. No new personnel or equipment costs will be incurred by the Federal government;
data will be entered into the NMFS fisheries statistics system by existing staffers with time
available within their regular work schedules using existing data programs, procedures and
equipment.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
The increase in cost from $2,664 to $3,012 results from increased postage costs. In ROCIS, the
change shows as only a $12.00 increase, as the previous cost was rounded up to $3,000 when the
ICR was migrated to ROCIS.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The data collected will not be published per se. However, as noted in Question 2, the data will be
integrated into the NMFS fisheries statistics system, and will therefore ultimately be reflected in
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the U.S. catch section of the annual NMFS publication, "Fisheries Statistics of the United
States." In this sense, the results of the collection will be published annually.

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.
Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not use statistical methods.

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