0352 ss ren 062508

SUPPORTING STATEMENT
NORTHWEST REGION GEAR IDENTIFICATION REQUIREMENTS
OMB CONTROL NO. 0648-0352

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
This submission requests renewal of Office of Management and Budget (OMB) approval for
gear-marking requirements in the Pacific Coast Groundfish Fishery.
Gear identification requirements are necessary to help ensure the success of fisheries
management programs by facilitating fisheries law enforcement efforts. Gear marking is also
valuable in actions concerning gear damage, loss, and civil proceedings. The ability to link
fishing gear to the vessel owner or operator is crucial to enforcement of regulations issued under
the authority of the Magnuson Fishery Conservation and Management Act. Fixed-gear marking
requirements are set forth in the regulations implementing the Pacific Coast Groundfish Fisheries
Management Plan at 50 CFR 660.382(b)(2) and 660.383(b)(2). Gear-marking requirements
specify that each type of fixed-gear must be marked with the owner's identifying number.
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.
The regulations specify that fishing gear must be marked with the vessel's official number,
federal permit or tag number, or some other specified form of identification. Law enforcement
personnel rely on this information to assure compliance with fisheries management regulations.
Gear that is not properly identified is considered a violation of Federal regulations and is
confiscated. The identifying marks on fishing gear is used by the National Marine Fisheries
Service (NMFS), United States Coast Guard (USCG), and other marine agencies in issuing
violations, prosecutions, and other enforcement actions. Gear marking also helps ensure that a
vessel harvests fish only from its own traps/pots/other gear and that traps/pots/other gears are not
illegally placed. Properly marked fishing gear facilitates prosecution of gear violations, and
enhances cost-effective enforcement. Cooperating fishers also use the gear markings to report
placement or occurrence of gear in unauthorized areas. Regulation-compliant fishermen
ultimately benefit, as unauthorized and illegal fishing is deterred and more burdensome
regulations are avoided. The information collected will not be disseminated to the public; as it
consists solely of identification on gear, it is not submitted to NMFS.
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 requirement that fixed gear be marked with an identifying number does not lend itself to
technology.
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4. Describe efforts to identify duplication.
Existing Federal and State requirements have been reviewed to ensure that there is no duplication
of requirements.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Although nearly all vessels in the respective fisheries are categorized as small businesses, the
collection of information will not have a significant economic impact or burden on small
businesses in terms of time and resources. Therefore, no special modifications of the
requirements were considered necessary.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The NMFS and USCG would not be able to enforce the fishery management measures if the
collection is not conducted or is conducted less frequently. The numbers must periodically be
maintained to remain legible.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
This collection is consistent with the OMB 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 was published, on February 4, 2008 (73 FR 6483), to solicit public
comments. No comments were received.
Consultation outside the agency is assured by the Pacific Coast Groundfish regulatory process,
set forth in the Magnuson-Stevens Fishery Conservation and Management Act and implementing
regulations (Pacific Coast Groundfish Fishery Management Plan and 50 CFR 660, Subpart G).
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided to respondents.

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10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
There is no assurance of confidentiality as this is public information.
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 is no information of a sensitive nature in this collection.
12. Provide an estimate in hours of the burden of the collection of information.
The estimated total number of vessels affected is 548. There are three types of groundfish
vessels, which use the types of gear (line, pot, set-net) that must be marked. Each vessel has a
unique number of markings required because of variation in the gear. Estimating the total
number of marks in the fleet as 7,127 (please refer to Table 1 for details) and 15 minutes per
marking, the burden is estimated to be 1,782 hours.
Labor costs are estimated at $12 per hour. Twelve dollars per hour multiplied by 1,782 burden
hours equals approximately $21,384.
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).
The materials needed are paint and a paintbrush, or permanent ink applicator, and possibly a
stencil. With most traps or pots, marking is done by means of a commercially available plastic
tag that is fastened to the trap/pot by thin strands of wire and this tag number identifies the owner
of the trap/pot. The total number of marks in the fleet is estimated at 7,127. The average cost per
marking is approximately $0.25. Therefore, the total annual cost burden is $1,782.
14. Provide estimates of annualized cost to the Federal government.
There would be no Federal cost associated with this collection because marking verification
would be included as part of other enforcement actions and no information is received to process.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
Not applicable. However, there is an apparent decrease of $218 due to the cost in the last
submission having been rounded up to the nearest thousand when migrated to ROCIS.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
No results are published.
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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 to the certification statement.

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

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Table 1. Estimates for Fixed-Gear Marking Burden in the Pacific Coast Groundfish
Fishery
2003

OPEN ACCESS

LIMITED ENTRY

TOTAL FLEET

Line

Pot

Set Net

Longline

Pot

Line

Pot

Set Net

# Vessels

270

102

37

112

27

382

129

37

# Strings *

5-10**

5

3

10

5

5-10**

5

3

# Buoys per
string

1-2

2

2

2

2

1-2

2

2

# Markings
per Vessel
(Strings x
buoys)

5-20**

10

6

20

10

5-20**

10

6

# Markings
per fleet

3,375

1,020

222

2,240

270

5,615

1,290

222

Total individual markings for the total groundfish fleet =
7,127 x 0.25 hrs per marking = 1,782 burden hrs ***
* Assumes a string of pots is set by these smaller vessels, though pots may also be individually set.
** To calculate the burden, the average of each of these ranges is used, as it most accurately reflects the total
burden.
*** As some vessels may participate in both limited entry and open access, the burden may be slightly
overestimated.

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