0371 ss ren 071408 part b

SUPPORTING STATEMENT
HIGHLY MIGRATORY SPECIES VESSEL LOGBOOKS
AND COST-EARNINGS DATA REPORTS
OMB CONTROL NO. 0648-0371

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

1. Describe (including a numerical estimate) the potential respondent universe and any
sampling or other respondent selection method to be used. Data on the number of entities
(e.g. establishments, State and local governmental units, households, or persons) in the
universe and the corresponding sample are to be provided in tabular form. The tabulation
must also include expected response rates for the collection as a whole. If the collection has
been conducted before, provide the actual response rate achieved.
This collection of information will employ statistical methods to reduce the respondent burden
and the data processing cost to the government. As indicated in the response to #12 in Section
A, certain fisheries would be subject to a census while others would have a sample drawn at
random. The selection rates apply both to the logbook in general (set forms and trip forms) and
to the cost-earnings form (attached to trip summary forms).
As indicated in Response # 12 in Section A, all swordfish, shark, charter/headboat, and
dolphin/wahoo permit holders would be selected for logbooks while only 10 percent of Atlantic
Tunas and HMS Angling permit holders would be selected for logbooks. The larger population
of tuna vessels (recreational and commercial combined) affords a representative sample at a 10
percent selection rate for each. In response to comments from fishermen, NMFS is proposing a
20 percent selection rate for the cost-earnings and annual expenditures forms in the commercial
shark, commercial swordfish, and charter/headboat fisheries (not required for dolphin/wahoo
permit holders). This rate should provide NMFS with a representative sample of the fishery as a
whole. The stratified random selection process for Atlantic Tuna and HMS Angling permit
holders and for the cost-earnings forms is based on information reported in logbooks the
previous year, as described in Question 2.
Table 1 in Part A indicates the affected universe. Out of almost 30,000 permit holders, under
this program, 7,451 would be required to submit logbooks and 1,207 would be required to submit
the cost-earnings and annual expenditure forms. Compliance with the catch reports or logbooks
is high because they are linked to permit renewal. That is, permits cannot be renewed until
logbooks and/or cost-earnings reports are submitted for the year. Often these reports are not
submitted in a timely manner but are submitted prior to renewing the permit.

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2. Describe the procedures for the collection, including: the statistical methodology for
stratification and sample selection; the estimation procedure; the degree of accuracy
needed for the purpose described in the justification; any unusual problems requiring
specialized sampling procedures; and any use of periodic (less frequent than annual) data
collection cycles to reduce burden.
The sample universes are the fleet for tuna, shark, swordfish, and charter/headboat permit
holders, for which we have the entire population or universe of vessels from the HMS permit
data file from which to choose. The sample universe also includes any dolphin/wahoo permit
holder that does not hold another Federal permit.
The random sample for selection from the tuna fishery is stratified according to the following
criteria:(1) state of homeport and (2) level of landings (high-liner vs. not active). The HMS
logbook form contains sufficient information to determine whether or not a vessel harvested
beyond or within the Exclusive Economic Zone, i.e. U.S. offshore or on the high seas. Sampling
designs for other commercial fishery surveys suggests that overall vessel length provides a
reliable indicator of whether a vessel is capable of fishing on the high seas. A vessel’s homeport
state is recorded in the HMS permit database. The sample size for selection for tuna vessels is
designed to achieve a 95 percent level of precision (significance). For any strata with less than
three vessels, the vessel numbers in these strata is increased to three since NMFS’ policy is not to
disclose information for anything less than three vessels. The stratified random sample is
determined using the Neyman Allocation Method with a finite population correction. This
method is being used by Dale Squires (NMFS) in the following collection: “Economic
Performance Data Surveys For West Coast Commercial Fisheries Programmatic Clearance
(OMB Control Number 0648-0369) for the Cost and Earnings Survey of the Troll Albacore and
Swordfish Fisheries.”
The random sample for the collection of cost-earnings data from the shark, swordfish, and
charter/headboat fleet would be stratified according to: (1) location of fishing in the previous
year within designated statistical areas and (2) level of activity (landings versus no landings/held
a permit or did not hold a permit). The HMS logbook form contains sufficient information to
determine where a vessel was fishing and the level of activity in the previous year. Numerous
analyses of logbook data have already designated the statistical areas. These same areas would
be used in the random sample. Sample size for selection of these vessels would be designed to
ensure adequate representation across the fleet and across all areas. For areas where few HMS
vessels fish (e.g., Sargasso or Northeast Distant areas), areas would be combined to ensure a
large enough sample so data can be disclosed. Sample fleet for selection of the cost-earnings
data would then be averaged to produce information representative of the group. There are not
expected to be any unusual problems requiring sampling procedures more specialized than those
indicated above.

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3. Describe the methods used to maximize response rates and to deal with nonresponse.
The accuracy and reliability of the information collected must be shown to be adequate for
the intended uses. For collections based on sampling, a special justification must be
provided if they will not yield "reliable" data that can be generalized to the universe
studied.
In order to maximize the response rate, brochures have been developed and circulated to educate
fishermen in various sectors about reporting requirements. NMFS has also published
compliance guides to remind fishermen of their obligations. Non-responders are typically
contacted first by phone and then are notified by the NMFS Office of Law Enforcement of their
delinquency and issued a written warning (“fix-it” notice). If there continues to be no response,
citations could be issued. For the censused population, a small percentage of non-responders is
not likely to decrease the reliability of the data given the number of vessels and trips. For the
sampled population, however, the reliability of the data could suffer if delinquency rates prove to
be high. In such a case, data between years could be combined to provide biennial estimates.
4. Describe any tests of procedures or methods to be undertaken. Tests are encouraged as
effective means to refine collections, but if ten or more test respondents are involved OMB
must give prior approval.
Logbooks have been used in this fishery since the 1980s and have proven an effective method of
collecting data when used with observers. Before implementation mandatory collection, NMFS
tested a voluntary program. The voluntary program was ineffective for meeting management
needs.
5. Provide the name and telephone number of individuals consulted on the statistical
aspects of the design, and the name of the agency unit, contractor(s), grantee(s), or other
person(s) who will actually collect and/or analyze the information for the agency.
NMFS, Office of Science and Technology (sampling design/analysis):
Dr. Rita Curtis (301) 713-2328
NMFS, Southeast Fishery Science Center (data collection):
Dr. Victor G. Restrepo (305) 361-4000
NMFS, Office of Science and Technology (data analysis)
Dr. Guillermo Diaz (301) 713-2367

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