Justification for Change for 0648-0202

Justification for Change
NORTHEAST REGION PERMIT FAMILY OF FORMS
OMB CONTROL NO. 0648-0202
National Marine Fisheries Services (NMFS) proposes to issue a permit ∗ that requires the
installation and operation of vessel monitoring systems (VMS) on up to 10 vessels that were not
included in past burden estimates. Approval of the change is requested within two weeks, as
the permit was to be issued 30 days after receipt of the application. The statutory deadline
was April 10. The requirements for VMS will not take effect until this change request is
approved by Office of Management and Budget (OMB)
.
For several years, NMFS has been issuing an annual permit for Canadian vessels that participate
in the Atlantic herring fishery of the Northeast Region, under section 204(d) of the MagnusonStevens Fishery Conservation and Management Act (MSA) and section 105(e) of Public Law
104-297, the Sustainable Fisheries Act. A new requirement for VMS will be added to the permit
based on input from the United States (U.S.).Coast Guard. Section 204(d) states that applicants
must comply with requirements described in section 201(c)(2) for the permit to be approved.
Section 201(c)(2) includes a provision that the owner or operator of any foreign fishing vessel
install and maintain in working order transponders, or such other appropriate position-fixing and
identification equipment as the U.S. Coast Guard is operating determines to be appropriate. The
U.S. Coast Guard found that VMS would be appropriate for the Canadian vessels and
subsequently NMFS added the requirement in the proposed permit. Operation of the VMS will
allow the monitoring of the vessels and their fishing effort.
Section 105(e) of Public Law 104-297 states that, within 30 days of receiving an application,
NMFS shall issue permits to up to fourteen Canadian transport vessels that are not equipped for
fish harvesting or processing, for the transshipment of Atlantic herring harvested by U.S.
fishermen and used solely in sardine processing. The Northeast Fisheries Management Council
established a border transfer specification for this herring transshipment in accordance with 50
CRF 648.200 (a).
The requirement will affect up to 10 Canadian vessels that currently do not have VMS onboard.
As these Canadian vessels participate in the Atlantic herring fishery, there would be only minor
changes to the total burden and cost for the herring fishery permit holders.
Currently 150 vessels have VMS units installed and operating. The additional affected vessels
will need to purchase and install a VMS unit at an average cost of $3,400 each, with yearly
maintenance costs of $200, for a 3-year total of $3,400 + 200 + 200, or $3,800, annualized to
$1,267, or $12,670 for all vessels. There would be two responses associated with installation:
Completion of OMB Control No. 0648-0202 VMS certification form and telephone call to notify
the Office of Law Enforcement of activation, and the average burden including installation
∗

Applications for this permit are covered under OMB Control No. 0648-0089

would be 1 hour and 20 minutes (total of 20 responses and 13 hours). The average cost of the
telephone call would be $1, for a total of $10.
Assuming a vessel trip from Canada to the U.S. will take an average of 24 hours, and the overall
total is 10 trips during the year, the total number of transmissions would be 240, based on hourly
VMS automatic reporting. Assuming each transmission costs $0.03, the total cost would be
$7.20.
For each trip, two email messages with information on the vessel, days and times of arrival into
and departure from the U.S. EEZ, and description of fishing activities, will need to be
transmitted via VMS. The estimated burden for each of the 20 email messages is 15 minutes per
message and the estimated cost is $2 per message (total of 300 minutes (10 trips x 2 messages x
15 minutes) or 5 hours and $40.
The total additional estimated maximum responses would be 40 (10 certifications, 10
activation telephone calls, and 20 arrival/departure emails).
The total additional hourly burden would be 18 (13 for installation, certification and
activation telephone call + 5 for arrival/departure emails).
The total additional cost would be $12,727.20 ($12,670 for purchase and installation + $10 for
telephone calls + $7.20 for transmissions and $40 for emails).