Change justification for 0648-0583

JUSTIFICATION STATEMENT: Changes to Pacific Whiting Vessel License Application Form
We are requesting minor changes to the Pacific Whiting Vessel License Application form. This
form was included in a Paperwork Reduction Act (PRA) package that recently was pre approved
(OMB Control Number 0648-0583, expiration date 01/31/2012). On the revised form, we have
highlighted in red those items that have been added. All of the changes are found in Section C.
In Section C, the applicant is asked to provide information that demonstrates that the vessel
named in Section A meets the qualification standards for one or more of the four whiting fishery
sectors (catcher vessels delivering to a shoreside facilities, mothership, catcher vessel delivering
to mothership or catcher-processor vessel). For each of the applicable sectors, the applicant was
previously requested to provide the following information:
Year of landing
Total Amount of whiting landed/delivered/received/processed/caught for the year
The applicant was requested to provide supplemental documents (i.e.; fish ticket, observer report,
delivery report) to verify the above information.
The revised version of the form asks for the following:
Total amount of whiting landed/delivered/received/processed/caught for one landing
The specific date (including year) of the landing/delivery/receipt/catch/processing
The name/vessel registration number of the vessel delivering to the mothership
In the case of catcher vessels delivering to shoreside facility, the name of the company
and its location and the fish ticket number and state of issuance
In the case of motherships, the name and vessel documentation number for the vessel
delivering whiting
There are two reasons for asking for these changes. First, in reconsidering the information
requested and the qualification standard, we realized that only one legal
landing/delivery/receipt/catch or process instance involving any amount of whiting in a
qualifying year is sufficient to meet the qualifying requirement. We realized that asking for total
amounts of whiting caught/delivered/caught or processed in a year and supplemental
documentation supporting that total was excessive.
Second, after further review of the application form, we realized that certain key information on
the supplemental document may not be represented on the form. We believe it is important to
have key document information printed by the applicant on the application form to help staff
verify exactly what is on the actual supplemental document. We anticipate that some of the
supplemental documents may be copies of originals and hand written and as such, may be
difficult to read. More importantly, the printed information on the form provided by the
applicant becomes a certified statement of how the vessel specifically met the qualifying criteria.
The applicant will be required to take the additional information required from the supplemental
document (i.e. fish ticket) and print it on the application form. The respondent will not be
required to spend extra time to research or do additional calculation.

The fact that the applicant does not have to calculate the amount of whiting that was caught,
delivered or processed in one year should reduce the amount of time required by the applicant to
fill out the form. We estimate that with this change, the form will now take 45 minutes, rather
than one hour, to complete. With an annualized number of 40 permit applications, this will save
a total of 10 burden hours (40 x 45 minutes/60 minutes = 30 hours).
In order for fishermen to comply with this new requirement, approval is needed no later than March 17.