0318 ss ren 110708rev

0318 ss ren 110708rev.pdf

NMFS Alaska Region Observer Providers

OMB: 0648-0318

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SUPPORTING STATEMENT
NMFS ALASKA REGION OBSERVER PROVIDERS
OMB CONTROL NO. 0648-0318

INTRODUCTION
The domestic groundfish fisheries of the Bering Sea and Aleutian Islands (BSAI) management
area and the Gulf of Alaska (GOA) are managed by the Secretary of Commerce under the
Fishery Management Plan for the Groundfish Fishery of the BSAI and the Fishery Management
Plan (FMP) for Groundfish of the GOA. The FMP was prepared by the North Pacific Fishery
Management Council under the Magnuson-Stevens Fishery Conservation and Management Act
16 U.S.C. 1801 et seq. (Magnuson-Stevens Act) as amended in 2006 and are implemented by
regulations at 50 CFR part 679.
The National Marine Fisheries Service (NMFS) North Pacific Groundfish Observer Program
(Observer Program) was implemented in early 1990. The Observer Program collects and
disseminates total catch, species composition, length frequency measurements, age structures
from targeted and prohibited species catch, bycatch, and biological data necessary to support inseason monitoring and stock assessment of Alaska fisheries, commensurate with the highest
level of data quality, data integrity, and professionalism. The Alaska Fisheries Science Center in
Seattle, Washington provides the operational oversight for the program, certification training,
definition of observer sampling duties and methods, debriefing of observers, and management of
the data.
This action is a renewal for the observer provider collection-of-information.
A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
The main focus of this information collection continues to be the documentation required by
NMFS from an observer provider. The data elements of the information collection listed below
generally are unchanged from those previously cleared under Office of Management and Budget
(OMB) Control No. 0648-0318. Observer providers are permitted by NMFS to hire and deploy
qualified individuals as observers in the groundfish fisheries of the BSAI and GOA. Observer
candidates are required to meet specified criteria in order to qualify as an observer and must
successfully complete an initial certification training course, as well as meet other criteria, prior
to being certified.
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.
Owners or operators of vessels that possess a Federal fisheries permit under § 679.4(b)(1) and
owners or managers of processors that possess a Federal processor permit under § 679.4(f)(1),
must have onboard or onshore observer coverage in accordance with § 679.50, which describes
1

the Observer Program. Owners of vessels, shoreside processors, and stationary floating
processors (SFP) required to carry observers must arrange for observer services from an observer
provider. Although the vessel and processor owners pay for the cost of the observers, the costs
associated with managing the Observer Program are paid by NMFS.
Observer training and briefings.
The NMFS Alaska Region Observer Program conducts training and briefing classes to obtain
observer endorsements in Seattle at the Alaska Fisheries Science Center and through the North
Pacific Fisheries Observer Training Center at the University of Alaska, Anchorage, Alaska.
Training class dates are posted quarterly; changes are posted as they occur. The observer
training schedule for briefings in Seattle, Washington, and Anchorage, Alaska, is posted by the
Observer Program at http://www.afsc.noaa.gov/FMA/training_schedule.htm.
A list of observer providers is available upon request from the Observer Program Office and
from the Observer Program’s home page at
http://www.afsc.noaa.gov/FMA/observer_providers.htm.
Responsibilities of observer providers.
Unless alternative arrangements are approved by NMFS, an observer provider must not:
♦ Deploy an observer on the same vessel or at the same shoreside processor or SFP for
more than 90 days in a 12-month period.
♦ Deploy an observer for more than 90 days in a single deployment.
♦ Include in a single deployment of an observer, assignments to more than four vessels,
including groundfish and all other vessels, and/or shoreside processors.
♦ Move an observer from a vessel or SFP or shoreside processor before that observer has
completed his or her sampling or data transmission duties.
Provisions by an observer provider include:
♦ Qualified candidates to serve as observers, who have successfully completed all NMFS
required training and briefing before deployment.
♦ Observers to vessels, shoreside processors, or SFP as requested to fulfill vessel and
processor requirements for observer coverage and ensure that observers complete duties
in a timely manner.
♦ Salaries and any other benefits and personnel services in accordance with the terms of
each observer’s contract.
♦ Transportation, including arrangements and logistics, for observers: to the initial location
of deployment, to all subsequent vessel, shoreside processor, or SFP assignments during
that deployment, and to the debriefing location when a deployment ends for any reason in
2

a timely manner such that the observer can complete his or her assigned duties.
♦ Appropriate lodging, per diem, and any other services necessary to observers assigned to
fishing vessels, shoreside processors, or SFP or between assignments. During all periods
an observer is housed on a vessel, the observer provider must ensure that the vessel
operator or at least one crew member is aboard.
♦ When an observer is deployed to a shoreside processor, provide individually assigned
communication equipment in working order, such as a cell phone or pager for notification
of upcoming deliveries or other necessary communication.
♦ Verify that a vessel has a valid United States Coast Guard (USCG) safety decal in
accordance with §679.50(g)(1)(ii)(B) before an observer may get underway aboard the
vessel. One of the following acceptable means of verification must be used to verify the
decal validity:
o An employee of the observer provider, including the observer, visually inspects
the decal aboard the vessel and confirms that the decal is valid according to the
decal date of issuance; or
o The observer provider receives a hard copy of the USCG documentation of the
decal issuance from the vessel owner or operator.
♦ Have an employee responsible for observer activities on call 24 hours a day to handle
emergencies involving observers or problems concerning observer logistics, whenever
observers are at sea, stationed at shoreside processor or SFP, in transit, or in port awaiting
vessel or processor reassignment.
♦ All required information to NMFS by electronic transmission (e-mail), fax, or other
method specified by NMFS.
a. Candidate college transcripts and statements, observer candidate [Removed]
The observer candidate’s time and cost in preparation of a resume and submittal of college
transcripts are excluded from the estimated burden of this collection-of-information because
resumes and transcripts routinely are required by most employers, including observer providers.
However, reviewing and handling of this candidate material by the observer provider and NMFS
is included below.

3

b. Candidate college transcripts and statements, observer provider
Candidate college transcripts and statements, Respondent
Total number of respondents
Total annual responses
Number of responses per year = 1
Total time burden (9 x 5)
Time per response to review = 8 hr
Time per response to submit to NMFS = 1 hr
Total personnel cost (45 x $25)
Cost per hr = $25
Total miscellaneous cost (2.70)
Cost to submit by mail ($2.50 x 1 = 2.50)
Cost to submit by e-mail (0.05 x 4 = 0.20)

5
5
45 hr

$1,125
$3

Candidates’ college transcripts and statements, Federal Government
Total annual responses
5
Total time burden
10 hr
Time per response = 2 hr
Total personnel cost
$250
Cost per hr = $25
Total miscellaneous cost
0

c. Observer training and briefing registration.
The observer provider must submit training registration information to NMFS at least 5 business
days prior to the beginning of a scheduled observer certification training or briefing session. A
schedule for observer training for late 2008/early 2009 may be viewed at
http://www.afsc.noaa.gov/FMA/training_schedule.htm. The list of requested date and names of
observer candidates ensures that sufficient class space will be reserved for the candidates during
the training session requested.
The observer training schedule shows that each class is presented at least twice each year, which
changes this analysis from 1 annual response to 2 annual responses.
Observer training registration
Date of requested training
A list of observer candidates, including each candidate’s full name, date of birth, and sex
A copy of each candidate’s academic transcripts and resume
A statement signed by the observer candidate which discloses the candidate’s criminal convictions (if any).
Observer training registration, Respondent
Total number of respondents
Total annual responses
Estimated responses per yr = 2
Total burden time
Time per response = 1 hr
Total personnel cost (10 x $25)
Cost per hour, in dollars = 25
Total miscellaneous cost (120.15)
Cost to submit by fax ($6 x 10 page x 2 = 120)
Cost to submit by email (0.05 x 3 = 0.15)

4

5
10
10 hr
$250
$120

Observer training registration, Federal Government
Total responses
Total burden time
Time per response = 1 hr
Total personnel cost (10 x $25)
Cost per hour, in dollars = 25
Total miscellaneous cost

10
10 hr
$250
0

Observer briefing registration
Date and type of requested briefing session and briefing location
List of observers to attend the briefing session, including each observer’s full name.
Observer Briefing Registration, Respondent
Total number of respondents
Total annual responses
Number of observers = 60
Types of observer briefing sessions
3-week training
12-day crab training
4-day annual briefing
2-day briefing
1-day pre-deployment briefing
5-day ‘level 2' briefing
1-day ‘level 2' briefing
Total time burden
Time per response (7 min/60 min=0.12)
Total personnel cost (36 hr x $25/hr)
Cost per hr = $25
Total miscellaneous costs (20.95)
Cost to submit by fax ($6 x 1 page x 1 = 6)
Cost to submit by email (0.05 x 299 = 14.95)
Observer Briefing Registration, Federal Government
Total annual responses
Total time burden
Time per response (3 min/60 min=0.05)
Total personnel cost (15 hr x $25/hr)
Cost per hr = $25
Total miscellaneous costs

5
300

36 hr
$900
$21

300
15 hr
$375
0

d. Projected observer assignments.
Prior to the observer or observer candidate's completion of the training or briefing session, the
observer provider must submit to NMFS a statement of projected observer assignments. The
projected assignments are used by the training or briefing instructor to adapt classroom
instruction to meet the specific needs of the individual(s) in each training or briefing class and to
assign “special projects” to students. Special project assignments are often dependent on the
projected vessel assignments and are often species or vessel-type specific.

5

Projected Observer Assignments
Observer's name
Vessel, shoreside processor, or SFP assignment
Gear type
Vessel/processor code
Port of embarkation
Target species
Area of fishing.
Projected observer assignment, Respondent
Total number of respondents
Total annual responses (60 x 3 x 5)
Number of observers = 60
Annual assignments per observer = 3
Total time burden (900 x 0.12 hr)
Time per response (7 min/60 min=0.12)
Total personnel cost (108 hr x $25/hr)
Cost per hr = $25
Total miscellaneous cost (50.95)
Cost to submit by fax ($6 x 1 page x 1 = 6)
Cost to submit by email (0.05 x 899 = 44.95)
Projected observer assignment, Federal Government
Total annual responses
Total time burden (900 x 0.17)
Time per response (10 min/60 min=0.17)
Total personnel cost (153 x 25)
Cost per hr = $25
Total miscellaneous cost

5
900

108 hr
$2700
$51

900
153 hr
$3825
0

e. Physical examination verification.
The observer provider must provide to NMFS a signed and dated statement from a licensed
physician that he or she has physically examined an observer or observer candidate. The
statement must confirm that, based on that physical examination, the observer or observer
candidate does not have any health problems or conditions that would jeopardize that individual's
safety or the safety of others while deployed, or prevent the observer or observer candidate from
performing his or her duties satisfactorily. The statement must declare that, prior to the
examination, the physician was made aware of the duties of the observer and the dangerous,
remote, and rigorous nature of the work by reading the NMFS-prepared pamphlet, provided to
the candidate by the observer provider in accordance with §679.50(i)(2)(i)(B)(1).
The physician's statement must be submitted to NMFS prior to certification of an observer. The
physical exam must have occurred during the 12 months prior to the observer’s or observer
candidate's deployment. The physician's statement will expire 12 months after the physical exam
occurred. A new physical exam must be performed, and accompanying statement submitted,
prior to any deployment occurring after the expiration of the statement.
Observer providers incur the costs associated with copying and submitting to NMFS the notice
of physical examination. They do not incur the costs of an observer or observer candidate’s time
and cost for the actual exam.

6

Physical examination verification, Respondent
Total number of respondents
Total annual responses (60 x 5)
60 observers
1 response per year
Total burden time (300 x 0.08)
Time per response (5 min/60 min=0.08)
Total personnel cost (24 hr x $25/hr)
Cost per hr = $25
Total miscellaneous cost (20.95)
Cost to submit by fax ($6 x 1 page x 1 = 6)
Cost to submit by email (0.05 x 299 = 14.95)

5
300

24 hr
$600
$21

Physical Examination verification, Federal Government
Total annual responses
300
Total time burden (300 x 0.03)
9 hr
Time per response (2 min/60 min=0.03)
Total personnel cost (9 hr x $25/hr)
$225
Cost per hr = $25
Total miscellaneous cost
0

f. Observer deployment/logistics report.
A deployment/logistics report must be submitted by Wednesday, 4:30 pm, Pacific local time, of
each week with regard to each observer deployed by the observer provider during that week.
This report is used for routine record keeping in the NMFS observer database. Accurate and
timely observer deployment information is important for fisheries management. Knowing where
observers are at all times is also extremely important should emergencies arise while an observer
is deployed at sea.
The deployment/logistics report must include:
Observer deployment/logistics report
Observer’s name and cruise number
Current vessel, shoreside processor, or SFP assignment and vessel/ processor code
Embarkation date, and estimated or actual disembarkation dates
Observer’s location if the observer is currently not assigned.
Observer deployment/logistics report, Respondent
Total number respondents
Total annual responses (52 x 5 providers)
One response per week
Number of weekly reports/yr
Total time burden (31.2)
Time per response (7 min/60 min=0.12)
Total personnel cost (31 hr x $25/hr)
Cost per hr = $25
Total miscellaneous costs (18.95)
Cost to submit by fax ($6 x 1 page x 1 = 6)
Cost to submit by email (0.05 x 259 = 12.95)

7

5
260

31 hr
$775
$19

Observer deployment/logistics reports, Federal Government
Total annual responses
Total time burden (44.2)
Time per response (10 min/60 min=0.17)
Total personnel cost (44 x 25)
Cost per hr = $25
Total miscellaneous costs

260
44 hr
$1,100
0

g. Observer debriefing registration.
After an observer is certified by the Observer Program, he or she is sent to work on a catcher
vessel, a mothership, a catcher/processor, a shoreside processor, or an SFP. The observer
provider must contact NMFS within 5 business days after the completion of an observer’s
deployment to schedule a date, time and location for debriefing. Observer debriefing registration
information must be provided at the time of debriefing scheduling and must include the
following:
Observer debriefing registration.
Observer name and cruise number
Requested date of debriefing
Name and cruise number of observer
Name of vessel, shoreside processor, or SFP assignment name
Code of observer’s deployment.
Observer Debriefing Registration, Respondent
Total number respondents
Total annual responses (3 x 60 x 5)
Number of observers = 60
Number of assignments = 3
Total time burden (900 x 0.5 hr)
Time per response (30 min/60 min=0.5)
Total personnel cost (450 hr x $25/hr)
Cost per hr = $25
Total miscellaneous costs (50.95)
Cost to submit by fax ($6 x 1 page x 1 = 6)
Cost to submit by email (0.05 x 899 = 44.95)
Observer Debriefing Registration, Federal Government
Total annual responses
Total time burden (900 x 0.5)
Time per response (30 min/60 min=0.5)
Total personnel cost (450 hr x $25/hr)
Cost per hr = $25
Total miscellaneous costs

5
900

450 hr
$11250
$51

900
450 hr
$11250
0

h. Certificates of Insurance.
Copies of “certificates of insurance”, that name the NMFS Observer Program leader as the
“certificate holder”, must be submitted to NMFS by February 1 of each year. Insurance
certification allows NMFS to confirm that an observer provider is meeting the minimum
insurance coverage required. The certificates of insurance shall verify the following coverage
provisions and state that the insurance company will notify the certificate holder if insurance
coverage is changed or canceled.
8

♦ Maritime Liability to cover “seamen’s” claims under the Merchant Marine Act (Jones
Act) and General Maritime Law ($1 million minimum)
♦ Coverage under the U.S. Longshore and Harbor Workers’ Compensation Act
($1 million minimum)
♦ States Worker’s Compensation as required
♦ Commercial General Liability.
Certificates of insurance, Respondent
Total number of respondents
Total annual responses
Number of responses per year = 1
Total time burden (5 x 1 x 0.2)
Time per response (12 min/60 min=0.2)
Total personnel cost (1 hr x $25/hr)
Cost per hr = $25
Total miscellaneous cost (12.40)
Cost to submit by fax ($6 x 2 pages x 1 = 12)
Cost to submit by email (0.05 x 2 pages x 4 = 0.40)
Certificate of insurance, Federal Government
Total annual responses
Total time burden (5 x 0.05)
Time per response (3 min/60 min=0.05)
Total personnel cost (1 hr x $25/hr)
Cost per hr = $25
Total miscellaneous cost

5
5
1
$25
$12

5
1 hr
$25
0

i. Observer provider contracts.
Observer providers must submit to NMFS a completed and unaltered copy of each type of signed
and valid contract (including all attachments, appendices, addendums, and exhibits incorporated
into the contract) between the observer provider and those entities requiring observer services.
Observer providers must also submit to NMFS upon request, a completed and unaltered copy of
the current or most recent signed and valid contract (including all attachments, appendices,
addendums, and exhibits incorporated into the contract and any agreements or policies with
regard to observer compensation or salary levels) between the observer provider and the
particular entity identified by the Observer Program or with specific observers. Said copies must
be submitted to NMFS by fax or mail within 5 business days of the request for the contract.
Signed and valid contracts include the contracts an observer provider has with:
♦ Vessels required to have observer coverage
♦ Shoreside processors or SFPs required to have observer coverage
♦ Observers.

9

Observer Provider Contracts, Respondent
Total number of respondents
Total annual responses
1 response per year
Total time burden (2.5)
Time per response (30 min/60 min = 0.50)
Total personnel cost (3 x $25)
Cost per hr = $25
Total miscellaneous cost
Cost to mail (5.00 x 5)
Observer Provider Contracts, Federal Government
Total annual responses
Total time burden (2 hr x 5)
Time requirement to review = 2 hr
Total personnel cost (10 hr x $25/hr)
Cost per hr = $25
Total miscellaneous cost

5
5
3 hr
$75
$25

5
10 hr
$250
0

j. Other Reports.
The observer providers must submit reports of incidents not pertaining to collection of data by
the observer to NMFS. The observer provider must submit these reports via fax or email within
24 hours after the observer provider becomes aware of the information, as follows:
♦ Information regarding possible observer harassment
♦ Information regarding any prohibited action
♦ Concerns about vessel safety, processor safety, or marine casualty under
46 CFR 4.05-1 (a)(1)-(7)
♦ Observer illness or injury that prevents the observer from completing any of his or her
duties described in the observer manual
♦ Any information, allegations, or reports regarding observer conflict of interest or breach
of the standards of behavior.
Other Reports, Respondent
Total number respondents
Total annual responses (5 providers x 10 reports)
Number of reports = 10
Total time burden
Time per response = 2 hr
Total personnel cost (100 hr x $25/hr)
Cost per hr = $25
Total miscellaneous cost (8.45)
Cost to submit by fax ($6 x 1 page x 1 = 6)
Cost to submit by email (0.05 x 49 = 2.45)

10

5
50
100 hr
$2,500
$8

Other Reports, Federal Government
Total annual responses
Total time burden
Time to review each report = 1 hr
Total personnel cost
Cost per hr = $25
Total miscellaneous cost

50
50 hr
$1,250
0

k. Industry Request for Assistance in Improving Observer Data Quality Issues.
Vessel, shoreside processor, and SFP owners and operators, as well as observers and observer
providers, may contact NMFS in writing to request assistance in improving observer data quality
and resolving observer sampling issues in accordance with §679.50(e)(3). Issues may include:
♦ Vessel, shoreside processor, or SFP specific sampling issues
♦ Creating new sampling protocols
♦ Developing and implementing research projects
♦ Maintaining knowledge of current vessel, shoreside processor or SFP operations for
observer sampling purposes, and
♦ Providing on-site training for an observer(s) employed by an observer provider.
NMFS can address observer-related issues by placing staff or individuals authorized by NMFS in
actual working conditions experienced by observers. Such deployments increase the ability of
NMFS to work with industry, observers, and observer providers to resolve the issues that face
the stakeholders in the groundfish fisheries of the BSAI and GOA and foster a more cooperative
working relationship with better informed industry participants. Requests may be submitted to:
NMFS Observer Program Office, P.O. Box 15700, Seattle, Washington 98115-0070, or
transmitted by fax to (206) 526-4066.
Industry Request for Assistance, Respondent
Total number of respondents
Total annual responses
Number of responses per year = 1
Total time burden (10 x 0.5)
Time per response (30 min/60 min = 0.5)
Total personnel cost (5 x $25)
Cost per hour, in dollars = $25
Total miscellaneous cost (19.68)
Cost to fax ($6 x 1 page x 3 = 18)
Cost to email (0.05 x 7 = 1.68)
Industry Request for Assistance, Federal Government
Total annual responses
Total time burden
Time per response (150 min/60 min = 2.5 hr
Total personnel cost (25 x 25)
Cost per hour, in dollars = 25
Total miscellaneous cost

11

10
10
5
$125
$20

10
25 hr
$625
0

l. Observer Provider Permit Application.
Persons who seek to provide observer services under 50 CFR part 679.50(i) must obtain an
observer provider permit from NMFS. Applicants for an observer provider permit are requested
to provide information in narrative style rather than completing a form. NMFS uses the provided
information to evaluate the abilities of the prospective provider to perform the required
responsibilities and duties on a recurring basis. A NMFS-appointed observer provider
application review board reviews and evaluates each application for completeness against
evaluation criteria.
An observer provider permit is not transferable. An observer provider that experiences a change
in ownership that involves a new person must submit a new permit application and cannot
continue to operate until a new permit is issued. Except for ownership information, each
observer provider must submit to NMFS any changes or corrections to applicable contact
information. Observer providers must notify NMFS within 30 days of the effective date of such
change when any of the required permit elements change. This requirement will help facilitate
the communication between NMFS and observer providers. Any change to the information
submitted on the provider’s permit application must be submitted by FAX or mail.
The observer provider permit will expire after a period of 12 continuous months during which no
observers are deployed by the provider. NMFS will provide a written determination to an
observer provider if NMFS deployment records indicate that the permit has expired. An
observer provider who receives a written initial administrative determination (IAD) of permit
expiration may appeal under § 679.43. A permit holder who appeals the IAD will be issued an
extension of the expiration date of the permit until after the final resolution of that appeal.
NMFS-certified providers who deployed observers under the Observer Program in 2002 are
exempt from the requirement to re-apply for a permit, except that a change in ownership of an
existing observer provider requires a new permit application. NMFS does not anticipate any new
applications at this time, but will allow for one permit application for this analysis.
Observer Provider Permit application.
Identification of the management, organizational structure, and ownership structure of the applicant’s business
Identification by name and general function of all controlling management interests in the company
including but not limited to owners, board members, officers, authorized agents, and staff
Owner information. Permanent mailing address, telephone and fax numbers for each owner
Business information for each owner
Current physical location
Business mailing address, telephone and fax numbers, business e-mail address
Authorized agent. If ownership based outside the United States
Name of authorized agent
Mailing address, telephone number and fax number
Attachments
If a corporation, attach the articles of incorporation
If a partnership, attach the partnership agreement
Conflict of interest statement from each owner
Statement describing any criminal convictions, federal contracts held and the performance rating received on
each contract, and previous decertification action while working as an observer or observer provider
Description of any prior experience the applicant may have in placing individuals in remote field and/or marine
work environments, including recruiting, hiring, deployment, and personnel administration
Description of the applicant’s ability to carry out the responsibilities and duties of an observer provider in
accordance with §679.50(i)(2).

12

Observer provider permit application, Respondent
Total number of respondents
Total annual responses
Number of responses per year = 1
Total Time burden
Time per response = 60 hr
Total personnel cost (60 x $25)
Cost per hour, in dollars = $25
Total miscellaneous cost (0.42)
Cost to mail (0.42 x 1 = 0.42)

1
1
60 hr
$1,500
$1

Observer provider permit application, Federal Government
Total annual responses
1
Total time burden
30 hr
Total personnel cost (30 hr x $25/hr)
$750
Total miscellaneous cost
0

m. Appeals for Denial of Observer Certification, Certification Suspension or
Decertification [Removed]
An appeal by an observer or observer candidate for denial of observer certification, certification
suspension, or decertification is removed from this collection-of-information because these
procedures would be conducted by the observer rather than by the observer provider.
n. Appeals for Observer Provider Permit Expiration or Denial of Permit
The observer provider permit will expire after a period of 12 continuous months during which no
observers are deployed by the provider to the groundfish industry. The Regional Administrator
will provide a written determination to an observer provider if NMFS deployment records
indicate that the permit has expired. An observer provider who receives an IAD of permit
expiration may appeal. The appeals process provides the observer providers a method to provide
evidence and to argue in opposition to a denial of a permit. In addition, the process provides
NMFS a tool to ascertain if observer providers are fulfilling their responsibilities and duties as
prescribed by NMFS. An observer provider who appeals the IAD will be issued an extension of
the expiration date of the permit until after the final resolution of that appeal.
An observer provider application will be denied if the Regional Administrator determines that
the information provided in the application was not complete or all the evaluation criteria were
not met. The Regional Administrator will prepare and send an IAD to the applicant upon
evaluation of a completed application. The IAD will identify any deficiencies in the application
or any information submitted in support of the application. An applicant who receives an IAD
that denies his or her application may appeal. An applicant who appeals the IAD will not be
issued an interim observer provider permit and will not receive a permit until after the final
resolution of that appeal in favor of the applicant.
This analysis adjusts the time for legal advice from 8 hr to 4 hr to be more in line with other
appeals analyses. Also, the NMFS legal handling of the appeal is adjusted to 4 hr from 8 hr,
again to be in line with other analyses.

13

Appeals for Observer Provider Permit, Respondent
Total number of respondents
Total annual responses (one appeal/5 years)
Total burden hours (0.2 x 4 hr = 0.8)
Time per response = 4 hr
Total personnel cost
Cost per hour = $25
Total miscellaneous cost (500.84)
Annual cost for legal advice (4 hr x $125/ = 500)
Cost to submit by mail ($0.84 x 1 oz = 0.84)
*Rounded up so hours would register in ROCIS

1
1*
1 hr
$25
$501

Appeals for Observer Provider Permit Expiration or Denial of
Permit, Federal Government
Total annual responses
1*
Total time burden (0.2 x 4 hr = 0.8)
1 hr
Time per response = 4
Total personnel cost (1 x $125)
$125
Cost per hr = $125
Total miscellaneous cost
0
*Rounded up to be consistent with respondent data

o. Update to provider information
Observer providers are required to notify the Observer Program within 30 days of the effective
date when any of the required elements change. This requirement facilitates the communication
between NMFS and observer providers. Any change to the information submitted on the
provider’s permit application must be submitted by email.
Update to provider information, Respondent
Total respondents
Total annual responses
Number of responses per year = 1
Total Time burden (0.75)
Time per response (15 min/60 min = 0.25)
Total personnel cost (1 x $25)
Cost per hour, in dollars = 25
Total miscellaneous cost
Cost to e-mail (0.05 x 3 = 0.15)

3
3
1
$25
$1

Update to provider information, Federal Government
Total number of responses
3
Total time burden (1.5)
2 hr
Time per response (30/60=0.5)
Total personnel cost (2 x 25)
$50
Cost per hour = 25
Total miscellaneous cost
0

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. 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
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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.
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 periodic reports and information submitted by observer providers consist of extractions of
the required data from their existing database systems into a report form that is then submitted by
fax or e-mail to NMFS. Observer provider applications are submitted by mail, along with
requested documentation.
4. Describe efforts to identify duplication.
The application processes and information submissions for the observer provider are unique to
this program, and direct duplication with other collections does not exist.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
This collection of information does not impose a significant impact on small entities. All
businesses involved are small businesses.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
All information is required for the efficient operation of the Observer Program and must be
submitted in the time frames requested. Collecting this information less frequently would
jeopardize the goals and objectives of the Observer Program and the effective management of the
Alaska groundfish fisheries.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
No special circumstances exist that would require information collection to be conducted in a
manner inconsistent with OMB Guidelines except for the weekly reports.

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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 July 2, 2008 (73 FR 37932) requested comments on
renewal of the Observer Provider Program. No comments were received.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift to respondents is provided under this program for observer providers who
choose to apply.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
The information collected is confidential under section 402(b) of the Magnuson-Stevens Act (16
U.S.C. 1881a, et seq.). The information is also confidential under NOAA Administrative Order
216-100, which sets forth procedures to protect confidentiality of fishery statistics. Respondents
are informed of this when contacting NMFS.
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.
This information collection does not involve information of a sensitive nature.
12. Provide an estimate in hours of the burden of the collection of information.
Estimated total respondents: 15, decreased from 205. Estimated total responses: 2,749,
decreased from 2,995. Total estimated burden hours: 875, decreased from 1,959. Estimated
total personnel cost: $21,875, decreased from $48,975.
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 Question
12 above).
Estimated total miscellaneous costs: $854, decreased from $83,126.
14. Provide estimates of annualized cost to the Federal government.
Estimated total burden hours: 810, decreased from 1,977. Estimated total personnel cost:
$20,350, decreased from $150,225. No miscellaneous costs.

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15. Explain the reasons for any program changes or adjustments.
In some parts of the previous analysis, large respondent numbers were used instead of the 5, for
observer providers. The large numbers inaccurately described the number of reports or the
number of observers. This analysis is revised to correct those errors. In addition, this analysis
uses the number 60 as the number of observers per observer provider when appropriate; the
estimated total number of observers is 300. The following adjustments also occurred in this
action:
The total number of respondents is corrected to read 15 (10 industry requests, 5 observer
providers) in place of 205.
The total number of responses is corrected to read 2,750 in place of 2,995. This reduction is
caused in part by removing items that describe observer requirements, because it is inappropriate
to have them in this collection which describes observer providers. These items are: college
transcript submission by observer candidates, observer physical examinations; and observer
appeals for certification, decertification, or suspension.
The total number of burden hours is revised from 1,959 to 875, due to removal of items
described above.
The total personnel costs are revised from $48,975 to $21,875, due to removal of items
described above.
The total miscellaneous costs are revised to $854 to replace $83,126, a net decrease of
$82,272 (note: as ROCIS rounded down the previously requested costs to $83,000, the difference
in ROCIS appears to be $82,146). A decrease of $82,432 was due to: 1) removal of items
described above and 2) the change of report submittal to email in place of fax for almost all
responses, because email is almost always used for this purpose. An increase of $160 was due to
the correction of cost for submitting a fax from $1 to $6 and increase in the postage rate from
$0.37 to $0.42.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
NMFS has no plans to publish the results of this information collection.
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.
No forms are available in this collection. The information is collected through a written
narrative.
18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
N/A.

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

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