0229 ss rev 092208rev

SUPPORTING STATEMENT
NORTHEAST REGION DEALER PURCHASE REPORTS
OMB CONTROL NO.: 0648-0229

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
Executive Summary
This collection of information revises a currently approved requirement set forth by the National
Marine Fisheries Service (NMFS) and approved under OMB Control No. 0648-0229. That
requirement was extended in 2005 and later revised in 2007 to include an additional sector of the
Federal dealer population (hagfish dealers). This collection of information revises the universe
of affected Federal dealers to include the 148 Federal lobster dealers currently not subject to
Federal dealer reporting requirements. The burdens associated with this information collection
are added to the current burdens as previously evaluated for Federal fishery dealer reporting
under OMB Control No. 0648-0229.
NMFS is revising this data collection in response to the recommendations of the Atlantic States
Marine Fisheries Commission (Commission) in Addendum X to Amendment 3 of the Interstate
Fishery Management Plan (ISFMP) for American Lobster. The addendum addresses the
concerns of the 2005 Lobster Stock Assessment Peer Review Report regarding the lack of
sufficient data for lobster fishery management and stock assessments. The report recommended,
in part, that improvements be implemented in the level of fishery dependent data collected on a
coastwide basis. This revised data collection is implemented under the Atlantic Coastal
Fisheries Cooperative Management Act (Atlantic Coastal Act/ACA) and the data collection
parameters are consistent with the current requirements for Federal dealers under the authority of
the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens
Act/MSA).
Initial Basis for Dealer Reporting as Authorized by the MSA
NMFS is responsible for the stewardship of the Nation=s living marine resources and their
habitats within the United States Exclusive Economic Zone (EEZ). NMFS works to conserve,
protect, and manage these resources to ensure their continuation as functioning components of
ecosystems, while also affording economic opportunities and enhancing the quality of life for the
American public. NMFS’s mandates and authorities are derived from numerous statutes, most
significantly the MSA, the Endangered Species Act (ESA), the Marine Mammal Protection Act
(MMPA), and the ACA.
In an effort to achieve the goals of the MSA, several fisheries are now managed by harvest limits
including quotas, annual target total allowable catches (TAC) and domestic annual harvest
(DAH) limits. These fisheries often have short fishing seasons and require in-season
management measures, such as closures and trip limits, to ensure that harvest levels established
in each FMP are not exceeded. Therefore, as more fisheries are being managed by harvest
1

limits, the timely collection of data from dealers and vessel owners and operators is, and will
continue to be, a necessary component of most management regimes, as evidenced in several
FMPs.
All Federally-permitted dealers of Atlantic mackerel, squid, butterfish, Atlantic sea scallop,
Atlantic surf clam, ocean quahog, Northeast multispecies, monkfish, summer flounder, scup,
black sea bass, Atlantic bluefish, spiny dogfish, Atlantic herring, skates, tilefish, Atlantic deepsea red crab and hagfish must have been issued, and have in their possession, a federal dealer
permit in order to purchase such species from fishing vessels. Federally-permitted dealers in the
above fisheries are required to submit certain information regarding their fish purchases to
NMFS. The reporting requirement currently includes Federal lobster dealers who have also been
issued a dealer permit for one or more of the aforementioned species. Trip-level reports provide
the comprehensive data necessary for successful long-term management of each fishery. The
continuing need for this information is explicit in the management goals and objectives
established by the Mid-Atlantic Fisheries Management Council (MAFMC), the New England
Fisheries Management Council (NEFMC) and the Commission, as well as in the MSA, the
Sustainable Fisheries Act and NMFS Strategic Plan.
Basis for Revision of Lobster Dealer Reporting Requirement to Address the Commission’s
Lobster ISFMP
The Atlantic Coastal Act establishes the framework for the management and conservation of
Atlantic coastal fishery resources through the preparation and adoption of coastal interstate
fishery management plans. The plans are developed under the auspices of the Commission, a
pact of all the Atlantic coastal states. The Commission coordinates the efforts of the states and
the Federal government in implementing and enforcing the management strategies of the coastal
fishery management plans. The states take action in furtherance of this strategy in their
respective territorial waters (0-3 miles from shore). NMFS is obligated to support the
Commission’s coastal fishery management efforts in the Exclusive Economic Zone (EEZ), the
waters from 3 to 200 miles from shore. In the absence of an approved and implemented FMP
under the MSA, and after consultation with the appropriate fishery management councils, NMFS
may implement regulations that are: 1) compatible with the effective implementation of a coastal
fishery management plans; and 2) consistent with the national standards set forth in section 301
of the MSA.
The American lobster (Homarus americanus) resource is managed within the framework of the
Commission through an ISFMP that includes several amendments and addenda. To address
concerns from the 2005 American Lobster Stock Assessment Peer Review Report, the
Commission’s Lobster Management Board adopted more comprehensive reporting requirements
to include a mandatory Federal lobster dealer reporting program to interface with the current
coastwide data collection program utilized by state agencies and NMFS as established by the
Atlantic Coastal Cooperative Statistics Program (ACCSP). Since the lobster resource is
managed under the authority of the Atlantic Coastal Act, those Federal dealers holding only a
Federal lobster permit (and no permits issued under the authority of the MSA) have not been
subject to the mandatory dealer reporting requirements in place through the management plans
authorized by the MSA. Only those Federal lobster dealers who held permits for species
regulated under the MSA were required to report to NMFS all purchases and receipts including
2

lobster. Therefore, this action will impact the current subset of Federal lobster dealers (n = 148)
not previously required to report lobster receipts or purchases to NMFS and will require them to
report all lobster purchases consistent with the reporting requirements in place for species
managed under the MSA.
This action will revise the current dealer requirements as authorized and implemented under the
authority of the MSA and codified in the Federal fishery regulations at 50 CFR 648. However,
this revision is authorized under the ACA and will be implemented through the framework of the
Federal lobster regulations promulgated under 50 CFR 697. Despite the variation in
management authority for the respective actions, the revised requirements dovetail with the
current Federal dealer requirements and satisfy the Federal reporting requirements and address
the Commission’s Addendum X data collection program requirements for dealers. The revision
will seamlessly enfold the balance of the federal lobster dealer population into the reporting
framework in place for other federal dealers.
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.
Almost every international, federal, state, and local fishery management authority recognizes the
value of fisheries statistics collections and uses them as part of their management systems.
Fisheries statistics are used by economists, biologists, and managers to develop, monitor, and
enforce controls on fishery harvests. Without the fundamental data obtained through this
collection of information, NMFS would be unable to meet its statutory requirements under the
Magnuson-Stevens Act and other mandates.
The information from this revision will be used by the northeast and mid-Atlantic coastal states,
NMFS and the Commission to facilitate the effective management of the lobster resource. The
data will also be available for Commission-sanctioned review teams to assess the economic and
biological status of the fishery and to monitor the effectiveness of the Commission’s ISFMP for
American Lobster. The information is also used by state agencies and NMFS for fishery
enforcement purposes. It is used by NMFS as a basis of analyses conducted to satisfy the
agency’s responsibilities under the MMPA, National Environmental Policy Act (NEPA), ESA
and other Federal laws.
Mandatory Electronic Dealer Reporting Program
Federal lobster dealers affected by this action will be required to report their trip-level lobster
receipts and purchases electronically.
In 2007, NMFS issued 511 Federal lobster dealer permits. Of this total universe of Federal
lobster dealers, 148 held only a Federal lobster dealer permit and no other dealer permits.
Therefore, these 148 dealers, or about 29 percent of all Federal lobster dealers, are not required
under current Federal regulations to report lobster receipts or purchases. The current Federal
dealer regulations identify several species managed under the authority of the MSA for which
permitted dealers must report purchases. Any dealer issued a Federal dealer permit for one or
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more of these identified species must provide electronic trip-level reports for all species
purchased to NMFS on a weekly basis. Reports must be received by midnight of the first
Tuesday following the end of the reporting week which runs from Sunday through Saturday.
Dealers must provide electronic reports (see Question 3 for reporting options).
This action will include the balance of Federal lobster dealers into the mandatory reporting pool
to provide a more comprehensive statistical basis for assessing fishery assessment and evaluating
the status of the stock. The data will be shared through an online coastal fisheries database, the
Standard Atlantic Fisheries Information System (SAFIS). SAFIS is accessed and populated by
state and Federal agencies to improve the inter-jurisdictional management of coastal fisheries.
Under current requirements, Federal lobster dealer data is already made available through SAFIS
and this revision will augment the lobster data included into this system by incorporating data
from the entire complement of Federal lobster dealers.
NMFS collects all Federal dealer data electronically, and it is ultimately accessible through the
SAFIS system along with dealer data collected by the states for state licensed dealers. However,
some state dealer data are not collected on a weekly basis as required at the Federal level and
may be loaded onto the SAFIS system only on a monthly basis (Northeast Regional Office
Fisheries Statistics Office Staff, personal communication, March 2008). The data elements
collected by the states and NMFS may vary, resulting in an incomplete real-time coast-wide
landings data set. The infrastructure currently in place is established to handle all dealer reports
strictly on an electronic basis with continued movement to facilitate the integration of that data
into the SAFIS infrastructure and the Commercial Fisheries Dealer Electronic Reporting
Database (CFDERD), managed by the Northeast Fisheries Science Center as the official
warehouse for Federal dealer data. Given this long-term electronic dealer data strategy, NMFS
believes that any short-term benefits of allowing a relatively small number of dealers to report by
non-electronic means would be outweighed by the additional personnel and operational costs
associated with data entry, integration and error-checking. Further, fishery management will be
compromised because these non-electronic data collections will not be integrated
contemporaneously with the electronic data – an issue that is driving the need for mandatory
electronic reporting overall.
Consistent with both Addendum X and the current Federal dealer reporting requirements, the
revised group of Federal lobster dealers must provide the following information in the trip-level
dealer reports: a trip identifier to link the dealer report to a Federal Vessel Trip Report (VTR)
when applicable; species quantity (in lbs.) state and port of landing; market grade and category;
price per pound and, when applicable, NMFS Statistical Area fished 1 .

1

Although the Commission has requested that the Dealer provide the statistical area fished, this may not always be possible
because Federal lobster vessels that do not hold other Federal fisheries permits are not required to submit VTRs for NMFS. In
most cases, the dealer report is linked to the VTR via the trip identifier and the area fished is tracked from the dealer permit to
the VTR as completed by the harvester. In such cases when a Federal dealer purchases lobster from a harvester not required to
submit a VTR, there is no harvester report to link to the dealer report to obtain the area fished data. NMFS believes that the
“area fished” data should come from the harvester and not the dealer. Therefore, NMFS will not mandate that dealers provide
this data, as it may not be accurate. This data, in some cases, may be obtainable from state vessel reports.

4

The pounds of lobster purchased provide important economic and biological data for fishery
assessments. Price and value are used in estimating the earnings and profitability of each fishing
trip by the vessel operator and in regulatory impact reviews and economic input-output models
requiring such data to estimate the economic effects of changes induced by the biology or
management of the fishery. Special economic studies are conducted to obtain detailed
information on specific issues or fisheries when resources are available. It should be noted that
both species and price information are necessary for the dealer=s own accounting operation;
therefore, reporting that information does not constitute an additional reporting burden.
Reporting of null reports by dealers who do not make any purchases during the reporting week
allows NMFS to verify compliance, identify non-reporters, and to take the appropriate action in a
timely manner without placing an undue burden on the respondents.
It is anticipated that the information collected will be disseminated to the public or used to
support publicly disseminated information, subject to the data confidentiality provisions of the
Magnuson-Stevens Act. As explained in the previous 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 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.
Federally-permitted dealers are required to submit detailed electronic reports of all purchases
from fishing vessels. Due to the required confidentiality of fish purchase reports, information
sent from dealers to NMFS is subject to strict encryption standards and is available only to
authorized agency personnel and the submitter. Dealers receive a user name and personal
identification number (PIN) that enables them to log onto a secure site (http://safis.accsp.org)
and submit their reports. Dealers are also allowed to access, review, and edit the information
they have submitted using a secure procedure similar to those in common usage throughout the
banking industry.
The impetus of this revision, the Commission’s ISFMP, does not require that dealer reporting be
conducted electronically, only that it be conducted on a mandatory basis. NMFS will require
that the reporting be done strictly on an electronic basis, consistent with the current requirements
for dealers submitting reports to facilitate the timely receipt and utility of the data. This action
will allow NMFS to have the Federal lobster dealer data on hand and updated each week. This
will be the first time that such a comprehensive data set for lobster is available for fishery
management and stock assessment purposes.

5

4. Describe efforts to identify duplication.
The implementation of the mandatory lobster dealer reporting requirement is prompted by the
Commission’s intent to obtain a comprehensive set of landings data for fishery monitoring and
assessment in the absence of a mandatory trip-level harvester reporting requirement. Thus, the
Commission has mandated that the states implement the mandatory dealer reporting requirement
via the SAFIS system. The Commission similarly has requested that NMFS do the same.
Although the intent of this requirement is to ensure that all dealers report, a Federal reporting
requirement could result in duplication of reporting by dealers who have both state and Federal
reporting requirements.
NMFS could, theoretically, accept the dealer data as reported to the states as satisfying the
Federal requirement. However, the agency proposes to require dealers to report electronically,
while many states will continue to allow paper reporting. The electronic reporting requirement
is most desirable since it is more efficient, is consistent with the existing requirements of federal
dealer reports, is easily checked for completeness and accuracy, facilitates enforcement of
reporting, and requires less processing burden than paper reports. Once Federal electronic
reporting requirements for the affected dealers are implemented, some states may alter their
respective requirements for state dealers with Federal permits and accept the Federal electronic
reports in lieu of a state report. This may be beneficial to all parties including the dealers, the
state agencies, the Commission and NMFS since the electronic reports in such cases will ease the
processing burden on state agencies and make the upload of the coast-wide dealer data into the
SAFIS system more timely and accurate.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Because all of the dealers who will respond are considered small businesses, separate
requirements based on the size of business have not been developed. The dealer electronic
reporting system was developed and tested in conjunction with industry members to ensure a
system that is functional and useable for their business purposes. The system accommodates, to
the extent possible, existing business software application systems that are being used by dealers.
The system allows dealers who currently use such applications to upload a data file from their
business application to NMFS, minimizing any additional reporting burden. Dealers who choose
to keypunch their data directly into the web-based data entry system will be able to use those
reports for their own business records.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Gaps in reporting coverage, and inconsistencies in the timing of reporting and data elements
collected for the lobster fishery, limit the effectiveness of fishery assessments and subsequent
management actions. The dealer purchase reports provide the only source of first-purchase
information by Federal lobster dealers. The reports provide critical information on the prices
paid for products, the types of products being landed, and the number of dealers involved in the
fisheries. If this collection were not conducted, the ability for scientists and managers to
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effectively monitor and assess the lobster fishery would be compromised and a complete data set
for lobster purchases by Federal lobster dealers would not be available. Lobster, the most
valuable fishery on the U.S. east coast with ex-vessel values of $395 million in 2006 (Fisheries
of the US, 2006), is culturally and economically important to fishing communities in the
Northeast. In the absence of this collection, this fishery would be the only major fishery in the
nation without a mandatory dealer reporting requirement. The economic and social importance
of this resource and the specific need for a mandatory dealer reporting program, as identified by
the scientific community, will help in the responsible management and sustainability of the
lobster resource. Additionally, implementation of this reporting requirement will satisfy the
agency’s obligations to support the Commission’s Lobster ISFMP.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The data collection is consistent with 5 CFR 1320.6 guidelines except that it requires
information to be reported more frequently than quarterly. Dealers will submit trip-level reports
on a weekly basis. In the absence of mandatory reporting for harvesters at either the state or
federal level, mandatory dealer reports submitted on a weekly basis and in electronic format will
provide a more comprehensive data set for the management of the Northeast U.S. lobster fishery;
an industry with high economic and cultural importance.
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 proposed rule, Regulation Identifier Number (RIN) 0648-AV77, “Atlantic Coastal Fisheries
Cooperative Management Act Provisions; American Lobster Fishery,” will solicit public
comment.
NMFS published an Advance Notice of Proposed Rulemaking (72 FR 53978) on September 21,
2007 to inform the public that the agency was considering implementing a mandatory electronic
reporting requirement for Federal lobster dealers. A total of five comments were received in
response to the ANPR. The comment period closed on October 22, 2007. The notice requested
comments on three general issues: mandatory Federal lobster dealer reporting; changes to
maximum carapace length requirements for lobster in several conservation management areas;
and a revision to the definition of a v-notched lobster. Four of the five comments were germane
to the dealer reporting requirement and are described below.
1. A lobster dealer from Maine wrote in opposition to the mandatory dealer reporting
requirement. The commenter stated that this measure would add to the reporting burden
already mandated by the state. The commenter requests that NMFS get the data from the
state. This dealer purchases lobster from fishermen who drop off their catch on a floating
lobster car and lobster are dropped off by fishermen when the dealer is not there,
7

complicating the ability to garner specific data on where and when the lobster were
harvested.
2. Two comments were received from small dealers who oppose the mandatory reporting
requirement. One said this measure is redundant because they already report to their
state. The other said it will only impact small owner/operator businesses like theirs who
are already overburdened with state and federal reporting requirements. Additionally, the
dealer information is already reported on the vessel trip reports submitted to NMFS by
this lobster permit holder/vessel owner/dealer.
3. The state of Maine responded in opposition to the mandatory dealer reporting measure,
indicating that it would impact about 86 small dealers in Maine. The Maine Department
of Marine Resources is already collecting trip-level data from dealers on a monthly basis
and believes that electronic reporting requirements would be too burdensome on dealers
who do not have access to the Internet or to a computer and are now able to provide this
data on paper trip tickets to fulfill state requirements. The state believes this federal
action could jeopardize the relationship that Maine has fostered with its dealers to
facilitate the receipt of lobster landing data.
NMFS understands that this data is being obtained by the states from Federal dealers who are
required to report to their respective states which, to some degree, may be duplicative. NMFS,
however, sees this as a timely opportunity to obtain the entire set of Federal dealer data in an
electronic format. The submission of paper reports to states is cumbersome and not always
loaded by the states into the SAFIS system in a timely manner. In fact, some states only require
trip-level reports be submitted on a monthly basis at which time, state employees enter in the
data. The NMFS reporting protocol, on the other hand, requires trip-level data be submitted on a
weekly basis and once received, it is already in the system. NMFS expects that some states may
eliminate their paper-based reporting requirements for those state dealers who must report to
NMFS on an electronic basis. A full complement of dealer data at the NMFS level will allow for
ease in error-checking and compliance checks. It will also load the dealer data into the SAFIS
system in a timely manner to the benefit of the states, NMFS, ACCSP clients and the industry.
NMFS realizes that this requirement will largely impact lobster dealers from Maine. However,
since these dealers represent the major component of lobster purchases, it is important that their
landings be retrieved to ensure the responsible management of the fishery. This is especially
important since the majority of Federal vessels that are not subject to VTR reports hail from
Maine ports. Many of these vessels sell to Federal dealers who aren’t required to submit reports
to NMFS under the existing regulations. Therefore, the mandatory dealer reporting requirement
will allow for inclusion of these landings in the absence of a mandatory vessel reporting
program, which is not required for many Maine-based vessels at the state or Federal level.

8

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift, other than remuneration of contractors or grantees, will be provided to
respondents of this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
All data will be kept confidential as required by section 402(b) of the Magnuson-Stevens Act,
and will not be released for public use except in aggregate statistical form, without identification
as to its source. Logbooks are considered confidential under the Trade Secrets Act as well.
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.
No sensitive questions are asked.
12. Provide an estimate in hours of the burden of the collection of information.
Table 1.
Calculation of Public and Federal
Cost and Burden Estimates
Information
Collection
Mandatory
Federal Lobster
Dealer Weekly
Reporting
Existing
Mandatory
Dealer Burden
*Existing
Voluntary Dealer
Burden

Existing
Voluntary
Dealer Burden
(occasional
voluntary
interviews by
field agents)
TOTAL

No. of
Respondents

Responses
per Year

Total
Annual
Responses

Avg.
Response
Time (Hrs)

Total
Response
Hours

**Annual
Labor Cost
to Public

148

52

7,696

0.07 (4 min.)

539

$10,176

578

52

30,056

0.07 (4 min.)

2,104

$39,724

50

52

2,600

0.03 (2 min.)

78

$1,473

5

2

10

0.03 (2 min.)

0.3

$6

781

N/A

40,362

N/A

2,722

$51, 379

*Some dealers submit reports on a voluntary basis.
** Labor costs based on a respondent wage of $18.88 per hour.

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Dealers required to complete and submit Electronic Dealer Purchase Reports include those
permitted in the Atlantic mackerel, squid, butterfish, Atlantic sea scallop, NE multispecies,
monkfish, summer flounder, scup, black sea bass, Atlantic bluefish, spiny dogfish, Atlantic
herring, Atlantic deep-sea red crab, tilefish, skate, Atlantic surf clam and/or ocean quahog
fishery and hagfish. According to data available through the Northeast Region permit database,
approximately 578 dealers are permitted for one or more of the fisheries and are, thus, required
to report all purchases to NMFS.
As indicated in Table 1, the total current annual reporting burden associated with this collection
is estimated at 2,183 hours (2,104 + 78 + 1). This burden assumes an average response time of 4
minutes to populate and submit electronic data files, with the exception of the voluntary
reporting, which takes 2 minutes. The reporting burden reflects only the time needed to gather
any information needed to complete the reports and submit the data file to NMFS. In addition, it
is anticipated that several of the reports submitted will be negative reports and will take less time
to complete and transfer.
Specific to this revision, an additional 148 Federal lobster dealers will be required to submit
weekly electronic reports. To estimate the burden associated with this revision on the new
respondents, the same time and cost burdens are applied as determined for the current population
of dealers previously impacted under this measure. Therefore, the burden for the 148 new
respondents is 4 minutes (.07 hours) to complete and submit an electronic dealer report each
week at $18.88/burden hour, totaling 539 total annual burden hours at a total annual labor cost of
$10,171. The revised total burden for this collection, then, would be 2,722 hours with overall
labor costs equal to $51,387.
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).

Table 2.
Calculation of Cost to Respondents Excluding Respondent Time

Collection

No. of
Respondents

Startup Costs
per
Respondent
(Annualized)

Subtotal
Startup
Costs

Operating
Costs per
Respondent
(Internet
Access )

Subtotal
Operating
Costs

Mandatory
Federal
Lobster
Dealer
Weekly
Reporting

148

$116

$17,168

$652

452

$77

$34,804

600

N/A

$51,972

Existing
Burden
TOTAL

10

Total Costs
per
Respondent

Total Costs
All
Respondents

$96,496

$768

$113,664

$652

$294,704

$729

$329,508

N/A

$391,200

N/A

$443,172

For this analysis, NMFS estimates the burden based on the worst-case assumption that the newly
affected dealers (n = 148) neither own a computer nor have Internet access. These burdens,
therefore, may be slightly over-estimated since some dealers may have a computer and Internet
access already. Start-up costs for each of those 148 respondents not already in possession of a
computer and monitor are $580, broken down to $116 per year over a 5-year period to show the
annualized start-up costs per respondent (Table 2). For this same group of respondents the
annual operating costs are those costs associated with obtaining and maintaining Internet service
through either dial-up or cable modem, with an average annual cost of $652. Based on the
average annual start-up and operating costs per respondent of $116 and $652 respectively, the
total costs are $768 for each of these 148 respondents. Therefore, the total new costs for this
information collection on the 148 new respondents would be $113,664.
The start-up costs to the current pool of 452 dealers of the 578 respondents already affected by
dealer reporting, who did not have computers (and were not already paying Internet costs for
general business use) when the reporting requirements were initiated) are adjusted to account for
the three years of realized computer payments since the initial mandatory dealer reporting
requirement was implemented. The annual costs over five years are $116 per year for a
computer estimated to cost $580.00. Since three years have passed, the remaining balance is
estimated at $232 per respondent. In Table 2, the balance of the start-up costs is broken down
over three years, equal to $77 per year per respondent. The annual operating costs for Internet
service ($652) are ongoing and unchanged. Therefore, the total cost per respondent for each of
the 452 current respondents is $729 per year ($77 + $652). Total costs for all current
respondents are $329,508, reduced from $347,136 as initially calculated in the original
submission. Thus, the total costs for all respondents in this subset of dealers are decreased by
$17,628. When the total new costs ($113,664) are added to the adjusted costs for the current
respondents ($329,508), the total respondent costs associated with this information collection are
$443,172.
14. Provide estimates of annualized cost to the Federal government.
Table 3.
Costs to Government
Maintenance Costs
Totals
Information Collection

Current Electronic Dealer Requirement
Additional Burden based on 148 dealers –
includes costs to train dealers and process
additional reports.

Labor

Non - Labor

$250, 000

$20, 500

$270,500

$59,259

$12,313

$71,572

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There are some additional costs to the government in requiring an additional 148 Federal lobster
dealers to provide weekly electronic dealer reports. These burdens include the staff time and
costs associated with processing, correcting, compiling, error checking and submitting the data
to SAFIS and the CFDERD system. Additionally, government time and cost burdens are
associated with training new dealers to submit electronic reports.
The overall costs to the Government incurred as a result of this action are maintenance costs that
would be associated with personnel who currently manage the automated data-collection
program. The cost estimates for the Government to handle the responses from the 148 dealers
affected by this action are based on cost per response calculated from the estimate of the current
reporting requirements.
Labor costs include personnel who would still be utilized on the dealer reporting process after
system implementation although their job functions would change to maintenance,
troubleshooting, auditing and assistance-providing mode. Limited system support and assistance
for dealers is also provided by NMFS. Technical experts may accompany field staff, to the
extent possible, on visits to industry and port offices for system troubleshooting and
maintenance. The estimated costs per response for labor are $7.7 per response for 7,696 annual
responses, totaling $59,259 in government labor to assimilate the new dealers into the system.
These costs could be less since it is expected that the per response cost of maintaining the data
will not be as high since the infrastructure for the system is already in place.
Non-labor maintenance costs include expenses incurred for system upgrades and computer
equipment. Using the labor estimates from the previous submission for the current mandatory
reporting requirement we can make an estimate of the expected costs of this revision. The nonlabor costs of $20,500 for the 32,666 responses yields a $1.60 cost per response. In applying
that to the 7,696 additional responses expected with this revision, the total non-labor costs to the
Government to handle the 148 new dealers is $12,313.
Therefore, the combined labor and non-labor costs associated with this revision are $71,572.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
The program change for this action adds the reporting requirements for the 148 dealers. This
increases the annual burden by 539 hours and $113,664. The adjustment to the current burden, a
decrease of 17,628, is provided in 14.f.2 of the Form 83i and is based on the decrease in
annualized start-up costs as described in response to Question 13, above. The annual operating
costs per respondent for Internet service remain unchanged at $652 per year, bringing the
adjusted annual costs for current respondents to $729 per year. The overall costs for this
category of dealers are now adjusted to $329,508.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
Results from these collections may be used in scientific, management, technical, or general
informational publications such as Fisheries of the United States (FUS) and in Status of the
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Fishery Resources (SFR) off the Northeastern United States, which follow prescribed statistical
tabulations and summary table formats. The time schedule for publication of FUS is June of the
year following collection. Publication of SFR has usually been in September. Data are available
to the general public on request in summary form only and to NMFS Service employees in
detailed form on a need-to-know basis only. Aggregate landings and economic data are
available on NMFS web-pages as well. This data will also be available for use in future lobster
stock assessments and as the basis for fishery management actions.
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.
Because this collection involves electronic reports, there is no form on which to display an
expiration date. However, an expiration date will be displayed in the instructions or cover letter
that will be mailed to each permit holder who is required to report purchases through the
electronic system. An expiration date will appear on the voluntary reporting paper forms used in
this collection of information.
18. Explain each exception to the certification statement identified in Item 19 of the OMB
83-I.
No exceptions are requested.

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

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