0271 ss ren 101409rev

SUPPORTING STATEMENT
NORTHWEST REGION LOGBOOK FAMILY OF FORMS
OMB CONTROL NO. 0648-0271

INTRODUCTION
This collection is authorized by the Pacific Coast Groundfish Fishery Management Plan (FMP)
which was developed by the Pacific Fisheries Management Council (Council) under the
Magnuson-Stevens Fisheries Conservation and Management Act (Magnuson Act), 16 U.S.C.
1801 et seq. The FMP governs the groundfish fishery off Washington, Oregon, and California.
This information collection takes the form of a comprehensive Federal Fisheries data collection
program which includes recordkeeping and reporting requirements for fish processing vessels
over 125 feet in length (at-sea processors which includes catcher/processors and motherships)
and catcher vessels that deliver to motherships operating in the waters off Washington, Oregon
and California (WOC). This information would be used by the observers at sea to obtain fishing
effort information and would also be used to estimate catch if observer data were not available
(i.e. illness or injury of the observer) or to verify observer data.
This data collection statement was originally submitted for review in 1991. The proposed rule for
implementation of the collection was not published in the Federal Register until
November 19, 1992 (57 FR 54552). For a number of reasons, mainly changes in priorities, the
final rule has not yet been filed. However, the at-sea processing industry has recognized the
importance of these data requirements and continues to submit voluntarily most of the
information covered by this information collection. To date, the cooperation has been
exceptional. The industry has voluntarily recorded this information because they understand that
more accurate data allows managers to be less conservative in estimating the closure and thus
provide an increased likelihood of achieving the Pacific whiting allocations (if data are lacking,
managers are more conservative and a fishery may be closed prematurely).
At its April 2009 meeting, the Pacific Fishery Management Council (Council) recommended that
National Marine Fisheries Service (NMFS) implement a trawl rationalization program. As part
of the implementing regulations for a trawl rationalization program, we anticipate that there will
be regulatory requirements for electronic logbooks from vessels in the at-sea processing sectors.
NMFS expects to complete the rulemaking process to support the Council recommendations for
logbooks by 2011. We are requesting continued approval of this information collection until
logbook provisions for the trawl rationalization program are implemented.
This collection of information asks that: (1) all processing vessels that process their own catch
maintain Daily Fishing and Cumulative Production Logs (DFCPL) and Transfer/Offloading
Logs; (2) all processing vessels (motherships) that receive fish from fishing vessels must
maintain the Daily Report of Fish Received and Cumulative Production Logbooks (DRCPL) and
Transfer/Offloading Logbooks; (3) all fishing vessels delivering unprocessed groundfish to a
processing vessel must maintain the daily fishing part of the DFCPL; (4) all processing vessels
must notify the Northwest Region, NMFS 24 hours before the initiation of fishing, receiving or
processing, and 24 hours prior to leaving the WOC fishing area; and (5) all processing vessels
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submit, on at least a weekly basis, catch information that would summarize daily production by
species and product form.
This request is for renewal of this information collection.

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
This reporting requirement is designed to apply to large processing vessels, and catcher vessels
that deliver to them. After several weeks of fishing, processing vessels in the Pacific whiting atsea sectors offload processed products. Many vessels offload to cargo ships that are bound for
foreign ports; the others land processed products on shore in the states of WOC. We believe that
the information being requested from these vessels is particularly important because NMFS
needs to understand the impacts of the fishery on the Pacific whiting resource, as well as other
biological and socio-economic resources in the management area. In general terms, this
information includes the following: 1) fishing effort; 2) retained Pacific groundfish catch;
3) discard amounts including prohibited species; 4) production information; and 5) employment.
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 applicable NOAA Information Quality Guidelines.
This section summarizes the types of information that would be recorded and reported by the
operators of vessels subject to these regulations and some of the more important uses of the
information collected.
DAILY FISHING AND CUMULATIVE PRODUCTION LOG (DFCPL);
DAILY REPORT OF FISH RECEIVED AND CUMULATIVE PRODUCTION LOG
(DRCPL).
Processing vessels that process their own catch would be asked to maintain a DFCPL.
Motherships (processing vessels that only receive fish from harvesting vessels) would be asked
to maintain a DRCPL. The DFCPL and DRCPL are identical except that the DFCPL combines
the production log with a fishing log and the DRCPL combines the production log with a record
of fish received from other vessels. Harvesting vessels delivering to a processing vessel would
be asked to maintain the fishing log section of the DFCPL. The DFCPL and DRCPL logs record
daily catch or catch receipt information, along with daily and cumulative production information.
The daily fishing portion of the DFCPL includes: 1) vessel and gear specifications;
2) haul-by-haul information; 3) daily information on discards; and 4) information on daily vessel
activity. The haul by haul information includes the date, time, location, sea depth, trawl depth,
haul weight, duration of haul. The crew size information is broken out by fishing and processing
crews where appropriate. The discard information is for Pacific whiting, other groundfish, and
for prohibited species. The estimated daily discards of halibut, crab, and salmon are recorded in
numbers. All other species discard estimates are recorded by weight. The effort information is
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used for inseason enforcement and for biological and economic evaluations of existing and
proposed fishery management measures.
Original copies of the logs would remain on the vessels until the end of the fishing year (or
longer if product remains on board from the WOC fishery) and would be made available to
NMFS observers and to enforcement officers. Processing vessels would be asked to make the
daily fishing log information for its catcher vessels available to the observer on board the vessel.
Observers would collect the effort data and use other information in the logs to assist in meeting
their data collection responsibilities.
Information relating to estimated haul weight or catch receipt weight would be recorded in the
DFCPL or DRCPL within two hours of catch or catch receipt time. Timely recording of this
information is necessary: to minimize the possibility of mixing information from different hauls;
so enforcement officers may account for unrecorded product inventory during at-sea inspections
of the vessel; and so observers can provide managers with real-time data necessary for total
whiting catch estimates. Other entries in the DFCPL and DRCPL would be updated within 12
hours of the end of the day on which the haul, receipt, or production occurred.
The DFCPL and DRCPL also record daily discards by the processor. This information, along
with discard information provided to processors by catcher vessel operators, would be used by
the observers to obtain information relating to total fishing mortality resulting from fishing
operations. Data collected under the observer program provides Pacific whiting, other
groundfish, and prohibited species discard information from a significant portion of the industry.
Observers need access to discard information recorded in the logs to help assess their estimates
of discard amounts, particularly of prohibited species. Furthermore, all catcher vessels and
processors must record discard information to provide at least a minimum estimate of discard
mortality in the event of inadequate observer coverage.
Specific information on catcher vessels (vessel name, vessel permit number, and receipt time),
together with the cumulative production information recorded in DRCPLs. Product transfer
information recorded in the product transfer/offload log (transfer log) would be subtracted from
the verified cumulative production information in the DFCPL or DRCPL to obtain the amount of
product that should be present on a processor vessel.
The logs would remain onboard the vessels during the fishing year and would be made available
to observers and enforcement officers. Duplicate copies of the logbooks would be submitted to
NMFS within 14 days after a processing vessel checks out of the fishery, the harvest guideline is
reached, or the fishery is closed (or quarterly if the vessel remains in the fishery), to allow for
timely data entry and analyses by fishery managers (A catcher vessel that delivers to a
processing vessel would submit its duplicate copy only quarterly because its catch information
already has been recorded in the processing vessel log. Quarterly submission of the vessel's
effort data is adequate for management of the fishery.).
WEEKLY PRODUCTION REPORT.
A weekly production report would be requested from all processing vessels. It would summarize
the following information by area and gear: (1) total estimated catch or receipt weight of
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groundfish, and numbers of prohibited species; (2) weekly production by species and product
form; and (3) product recovery rates by species and product form.
Product weights are already maintained for business purposes. Vessels will also be asked to
report product recovery rates along with the conversion to round weight. This information will
help NMFS compare vessel reported data with observer data and may be used to assess recovery
rates and types of products produced at different times during the season.
PRODUCT TRANSFER/OFFLOADING LOGBOOKS (PTOL).
Processing vessels would be asked to maintain a transfer log. This log would record all
shipments or transfers of product by species and product type, product weight (or units) and
value, the name of the company or person transporting the product, the date of shipment, and the
destination of the product within twelve hours of the completion of the transfer or offloading.
Each processing vessel asked to maintain a transfer/offloading log would need to submit copies
of their transfer log to NMFS within fourteen days after the vessel leaves the fishery or the
fishery is closed. This information assists enforcement officers in verifying reported catch, and
will be compared with the original of the transfer/offloading log onboard the vessel and with
DFCPLs and DRCPLs.
Product weight, product types and values for each species harvested in the WOC currently are
recorded on State fish tickets for vessels landing in ports in WOC. The same information is
needed from processing vessels for economic analyses. However, the most immediate need is to
enable enforcement personnel to compare product inventories with production and transfer
logbooks.
START AND STOP NOTIFICATIONS.
Before the initial start and upon completion of fishing, receiving fish, or processing groundfish
from the fishery management area, a processing vessel must submit the following information:
1) vessel's name and WOC Federal permit number; 2) date and time when fishing, receipt of fish,
processing will begin or the vessel will leave the area; and 3) the reporting area and vessel's
position.
The purpose of start and stop notifications is to better track the fishing effort of the processing
fleet, to know which vessels should be submitting weekly reports, and to help locate individual
vessels in enforcement and emergency situations. The messages will be sent to the Northwest
Regional Office of NMFS when appropriate and will be received within 24 hours before the start
or within 24 hours after leaving the fishery management area off WOC.
The information collection is designed to yield data that meet all applicable information quality
guidelines. Although the information collected is not expected to be disseminated directly to the
public, results may be used in scientific, management, technical or general informational
publications. NMFS will retain control over the information and safeguard it from improper
access, modification, and destruction, consistent with NOAA standards for confidentiality,
privacy, and electronic information. See response to Question 10 of this Supporting Statement
for more information on confidentiality and privacy. Should NMFS decide to disseminate the
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information, it will be subject to the quality control measures and pre-dissemination review
pursuant to Section 515 of Public Law 106-554. NMFS will retain control over the information
and safeguard it from improper access, modification, and destruction, consistent with NOAA
standards for confidentiality, privacy, and electronic information.
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 Northwest Region sends the logbooks in paper form to the respondents, and will accept data
by fax, computer, mail, or in person. Land-line or satellite communication may be used. Methods
to facilitate industry submission of weekly (or daily) reporting requirements have been
encouraged by NMFS. Many vessels now use a computer to scan the report and email it to
NMFS; the others use the fax.
In anticipation of a trawl rationalization program, NMFS is in the process of analyzing the data
needs of such a program; reviewing electronic logbooks used to support other NMFS fisheries,
including the Alaska fisheries where these vessels also operate; and under an exempted fishing
permit, supporting the field testing of communications equipment that could be used to transmit
logbook data from sea. Following consideration of the data needs relative to a trawl
rationalization program, we expect to fund the development or adaptation of an electronic
logbook specific to the need of the at-sea Pacific whiting fishery.
4. Describe efforts to identify duplication.
The Magnuson Act's operational guidelines require each FMP to evaluate existing State and
Federal laws that govern the fisheries in question, and the findings are made part of each FMP.
For the most part, vessels that process catch at sea are not subject to state fishery reporting
requirements. The states of Washington, Oregon, and California do require reporting for vessels
that offload product in port; however, not all products are off loaded in United States (U.S.)
ports. Beyond state requirements for product offloading record and the VMS fishing position
reports, there are no alternate sources of this information or duplicative requirements.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
There are 9 catcher/processors and 6 mothership processors licensed to participate in the fishery
and who are affected by this information collection. The Small Business Administration (SBA)
guidelines for fishing firms use a $3,000,000 gross revenue threshold to separate small from
large operations. In the application to any one firm, the $3,000,000 threshold considers income to
all affiliated operations. NMFS records indicate that the gross annual revenue for each of the
catcher/processor and mothership operations operating in the WOC exceeds $3,000,000 and they
are therefore not considered small businesses. There are 30 catcher vessels licensed to
participate in the mothership fishery. These companies are all assumed to be small businesses.
NMFS will provide logbook and report forms to the vessel operators. To lessen the cost to the
industry of meeting the recordkeeping and reporting requirements, logbooks have been designed
so that each sector of the industry receives a logbook form tailored to meet its specific needs.
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The logbook and reporting programs developed for the Pacific whiting industry have been
designed to complement reporting requirements and would consolidate, to the extent practicable,
other recordkeeping requirements to lessen the paperwork burden on operators of catcher vessels
and at-sea processors. The NMFS has consulted with vessel operators to answer questions on
maintenance of the NMFS logs and submission of associated reports. We will continue to seek
industry guidance.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The DFCPLs and DRCPLs will be submitted by processors within 14 days after the vessel leaves
the fishery, the fishery is closed or the harvest guideline is reached (or quarterly if the vessel
remains in the area). Submission of DFCPLs and DRCPLs by catcher/processors and
motherships may be combined with submission of transfer logs, and so 3 submissions per at-sea
processing vessel per year are estimated. Catcher vessels will submit their effort information
(DFCPL) quarterly. This will allow timely input of logbook information into a central database
that may be accessed by fishery managers to gauge fishery performance against existing or
proposed management measures. This also will allow NMFS to monitor inseason compliance
with logbook requirements and to interface with individual vessel operators if logbook entries
are being recorded inappropriately (catcher vessels may submit their logs less frequently than the
processors because their harvest is recorded in the processors' logs and fishing effort data is not
needed more frequently than quarterly). Also, catcher vessels are most likely to be local vessels
that do not leave the WOC area. A less frequent submission of logbooks could undermine the
availability of timely fishery information upon which NMFS and the Council base their
management decisions. The absence of adequate biological, effort, and economic information
from the domestic industry increases the risk of error associated with any given management
decision, and can result in ineffective decision-making.
Transfer log information assists enforcement officers in verifying reported catch, and will be
compared with onboard transfer/offloading logs, DFCPLs, DRCPLs, and product inventory to
verify the amount of retained product. The fishery may be conducted in as little as 3-15 weeks
(an estimate of 72 days was used throughout this statement). If transfer logs were not submitted
during the fishing season, the ability to verify catch and production amounts while the vessel is
on the grounds would be jeopardized.
Start/Stop notifications must be submitted within 24 hours of the vessel entering or leaving the
fishery. This is necessary to accurately estimate processing effort, to schedule enforcement
boardings at the beginning and end of the vessel's operation in WOC.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The collection is consistent with Office of Management and Budget (OMB) guidelines except
that DFCPL or DRCPL must be completed within two hours of catch or catch receipt time. For
the reasons given above in this statement, logbook data must be available for observers so that
real-time management of the fishery can occur. The data must be recorded and the observers
must have access to the information. Product transfer logs must be submitted following each
offload to allow for effective enforcement of the fishery. As the normal whiting season is less
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than 72 days, quarterly submissions are not adequate to monitor the fishery, protect the resource,
or assure that harvest guidelines and allocations are not exceeded.
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 was published on May 19, 2009 (74 FR 23390) soliciting public
comment on this submission. No comments were received.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
Not applicable.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
As stated on the forms, the information collected is confidential under section 402(b) of the
Magnuson Act (16 U.S.C. 1801 et seq.). All data submitted are treated in accordance with
NOAA Administrative Order 216-100, Protection of Confidential Fisheries Statistics.
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 questions of a sensitive nature are asked.
12. Provide an estimate in hours of the burden of the collection of information.
Effort and production information are normally maintained by harvesting vessel operators and atsea processing vessel owners for their own business purposes. The labor costs associated with
the information collection pertain to the additional burden assumed by the vessel operators to
transfer this information to the correct logbook or report and to submit this information to
NMFS. See Table 1 for the estimated burden hours and the changes from the previous statement.
The following calculations of cost and burden hours assume that the processing and catcher
vessels operate 72 days of the year. Processing capacity is such that 15 vessels could process the
entire Pacific whiting quota in 72 days or less. Consequently, the DFCPLs and DRCPLs are
estimated to be kept for a maximum of 72 days a year and submitted no more than 3 times a year
per vessel (with no activity in the first quarter due to the season start in the spring. However, the
estimated 72-day season may be spread across the rest of the year in several openings, or a vessel
may depart and re-enter the fishery, so three submissions are possible.) Stop/start logs are
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estimated to be submitted no more than 4 times a year per vessel, and product transfer logs are
estimated to be submitted no more than 3 times a year per vessel.
Processing vessels will be asked to maintain Product Transfer/Offloading Logbooks. Because
the information in the Transfer logs would be summarized in the DFCPL or DRCPL, little
additional time would be required to fill them out. Three transfer logs, requiring 20 minutes to
complete, would take 1 hour per year per vessel. The 4 stop/start messages expected per vessel
are expected to take only 5 minutes per vessel per year.
Individual vessels may incur a greater or lesser cost burden depending on actual annual
participation in the Pacific whiting fishery. A vessel that both fishes and processes its catch
would have the maximum recordkeeping burden, about 31 minutes/day (37 hours, 12 minutes
annually based on a 72 days of operation). The other vessels have a lesser burden,
approximately 18 minutes/day (21 hours, 54 minutes annually) for a mothership (a vessel that
only processes), and approximately 13 minutes/day (15 hours, 36 minutes annually) for a vessel
that only fishes. These burdens are the same per vessel as in the last submission. The total
annual burden incurred by the industry to comply with the proposed information collection
program would be approximately 937 hours.
TABLE 1. BURDEN HOURS
B
Minutes
per Record

C (A*B)
Hours per vessel
per year

D
Number
of
Vessels

E (A*D)
Total responses
for fleet

F (C*D)
Total hrs for
fleet

Record Type

A
Number of
records per year
per vessel

DFCPL(catchers)

72

13 min

15.6 hrs

30

2,160

468

DFCPL (catcherprocessors)

72

26 min

31.2 hrs

9

648

281

DRCPL
(motherships)

72

13 min

15.6 hrs

6

432

93.6 (94)

Weekly/Daily
Production Report
( catcher-processors
and motherships
only)

21

14.8 min`

5.2 hrs

15

315

78

PTOL

3

20 min

1.0 hrs

15

45

15

Start/Stop

4

1.25 min

.08 hrs

15

60

1.2(1)

TOTAL
---45
3,660
937
CHANGE IN BURDEN HOURS: Hours in the previous submission were 1,374. The reduction of 437 hours, to 937 hours, is due to a license
limitation program for the Pacific whiting fishery implemented under Amendment 15, which reduced the total number of vessels that can
participate in the fishery

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).
There are no capital or startup costs. Logbook data may be sent by fax, email, mail or in person.
Land-line or satellite communications may be used. This statement and the calculation of
submission costs assumes the submission of DFCPLs and DRCPLs by mail and PTOLs and
Start/Stop reports by fax. However, PTOLs and stop/start notifications are also expected to be
submitted by email via satellite communication.
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TABLE 2. LABOR COSTS ASSOCIATED WITH THE SUBMISSION OF DATA
A
Hours per vessel
per Yr

B
# Vessels

DFCPL(catchers)

15.6 hrs

30

DFCPL (catcherprocessors)

31.2 hrs

9

DRCPL
(motherships)

15.6 hrs

6

Weekly/Daily
Production Report
(processors only)

5.2 hrs

PTOL

1.0 hrs

Start/Stop

.08 hrs

C
Total hrs for Fleet

Annual Labor Cost ($)*
D (A* wage)
E (C*wage) or (D*B)
Per Vessel
Fleet

Record Type
468

284

8,508

281

567

5,105

94

284

1,702

15

78

95

1,418

15

15

18

273

15

1.2

1.5

22

45
936.8
TOTAL
-* assumes the wage is equivalent to the 2009 GS-7 step 5 wage or $18.18/hour

$17,028

TABLE 3. OTHER SUBMISSION COSTS
A
Submission
Method

B
$ Cost per
Submission

C
Number of
Submissions per
Year
(Frequency)

D
Number of
Vessels

DFCPL
(catchers +
catcher-proc)

mail

8.00

3

39

$24

$936

DRCPL

mail

8.00

3

6

$24

$144

PTOL

FAX

11.00

3

15

$33

$495

Start/Stop

FAX

11.00

4

15

$44

$660

45

$125

$2,235

Record Type

TOTAL

Annual Cost of Submission ($)
E (B*C)
F (D*E) for total)
Vessel
Fleet

TABLE 4. CHANGE IN COSTS
Previous statement

This statement

Labor costs

$23,548

$17,028

Record Submission
Costs

$2,652

$2,235

Total costs to fleet

$26,200

$19,263

Reason for Change
Change primarily due to the decreased number of
vessels qualified to participate in the fishery due to a
license limitation program implemented under
Amendment 15, plus minor change in the hourly wage.
Change primarily due to the decreased number of
vessels qualified to participate in the fishery due to a
license limitation program implemented under
Amendment 15.

14. Provide estimates of annualized cost to the Federal government.
Enforcement and administrative costs: certain costs would be incurred by management agencies
in administering and enforcing the proposed recordkeeping and reporting requirements. Current
enforcement costs include salaries of enforcement personnel and costs associated with utilizing
support platforms, e.g., U.S. Coast Guard vessels. No additional enforcement personnel or U.S.
Coast Guard vessels are needed because (1) enforcement personnel are already hired to support
the conservation and management role of NMFS, and (2) U.S. Coast Guard vessels are already in
9

place to carry out search-and-rescue and fisheries enforcement missions off of WOC. NMFS
estimates that the amount of time to inspect a catcher/processor or mothership vessel, including
auditing DFCPLs, DRCPLs and Product Transfer/Offloading Logbooks, would average about 4
hours. If each processor were inspected quarterly then about 180 hours would be required to
inspect 15 at-sea Pacific whiting processors..
The most significant additional cost to the Federal government would be the input of data
recorded in the DFCPL and DRCPL logbooks into a fisheries information database, the analyses
of the data, and maintenance of the database. This would require the time of one full-time
employee (GS-9 step 5) for 180 hours. At $23.55/hr the annual cost would be about $8,478.
15. Explain the reasons for any program changes or adjustments.
Even though the number of participating vessels has fluctuated over recent years, the total
number of vessels participating in the Pacific whiting fishery has become more stable since
May 11, 2009. Amendment 15, RIN 0648–AW08, to the FMP requires vessels that wish to
participate in the non-tribal whiting fishery to qualify for an additional whiting entry limitation
program within the overall groundfish limited entry program. Vessels must have qualified for a
Pacific whiting vessels license during the one time application period that ended on May 11,
2009. Table 1 shows the number of vessels that are qualified to participate in each sector of the
fishery. The changes from the previous submission are due to the reduction in the number of
vessels that can qualify to participate in the fishery under the newly implemented license
limitation program, and because there is no longer a need for production data to be transmitted
from the vessel by fax – because the reductions in burden and cost are directly related to the new
license limitation program, they would be considered program changes.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
Results for this collection are not planned for publication.
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.
Not applicable.
18. Explain each exception to the certification statement.
Not applicable.

B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

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