Justification for Change

JUSTIFICATION FOR CHANGE
ALASKA REGION BSAI CRAB PERMITS
OMB CONTROL NO. 0648-0514

This action merges the OMB Control No. 0648-0576 collection entitled “Application for
Converted CPO Quota Share and CPO IFQ” into OMB Control No. 0648-0514, Alaska Region
Bering Sea and Aleutian Islands (BSAI) Crab Permits.
The Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act)
authorizes the North Pacific Fishery Management Council to prepare and amend fishery
management plans for any fishery in waters under its jurisdiction. National Marine Fisheries
Service (NMFS) manages the crab fisheries in the waters off the coast of Alaska under the
Fishery Management Plan (FMP) for Bering Sea and Aleutian Islands King and Tanner Crabs.
Regulations implementing the FMP appear at 50 CFR part 680. Regulations at 50 CFR part 679
and subpart H of 50 CFR part 600 also pertain.
The Crab Rationalization Program (CR Program) allocates BSAI crab resources among
harvesters, processors, and coastal communities. The CR Program is a limited access system
that balances the interests of several groups who depend on these fisheries. The CR Program
addresses conservation and management issues associated with the previous derby fishery,
reduces bycatch and associated discard mortality, and increases the safety of crab fishermen by
ending the race for fish.
The 0576 collection consists of an application for catcher/processor owner quota share and
individual fishing quota (IFQ). An eligible entity and its commonly-owned affiliates may
combine North processor quota share (PQS) and North catcher vessel owner quota share
(CVO QS) and exchange these shares for newly created converted catcher/processor owner quota
shares (CPO QS). Allowing entities to convert PQS and CVO QS to CPO QS allows them to
harvest and process crab onboard a catcher/processor. Electing to exercise this provision could
reduce each eligible entity’s operating costs associated with purchasing crab, processing crab on
land or in a stationary floating processor (SFP), and complying with the CR Program’s
arbitration system.
Eligible entities would receive one unit of North CPO QS in exchange for one unit of North
CVO QS and 0.9 units of North PQS. The amount of converted CPO QS issued to each entity
could not exceed 1 million pounds during any calendar year.
According to the NMFS Official Record, three individual entities are eligible for these
provisions. Yardarm Knot Fisheries, Limited Liability Company (LLC), and its
commonly-owned affiliates, and Blue Dutch, LLC, and its commonly-owned affiliates, are
eligible for the first type of conversion. Trident Seafoods, and its commonly-owned affiliates,
are eligible for the second type of conversion. NMFS cannot predict the amount of converted
CPO QS that would be annually issued because the participants would elect to exercise this
provision year by year and need not request conversion of all CVO QS and PQS held.
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While the statutory language does not specifically define which fisheries are subject to this
provision, converted CPO QS was created for the snow crab and Bristol Bay red king crab
fisheries, because these were the only fisheries for which the eligible entities were initially issued
North PQS and North CVO QS.
Because the entities involved in the 0576 collection are also entities with CR Program permits,
the merging of the 0576 and 0514 will not result in additional respondents; however, it does
result in addition of three total annual responses, two hours of burden, $50 in personnel costs,
and $7 in miscellaneous costs.
Annual application for Crab Converted CPO QS and CPO
IFQ, Respondent
Number of respondents
3
Total annual responses
3
Frequency of response = 1
Total burden hours (0.5 x 3 = 1.50)
2 hr
Time per response = 0.5 hr
Total personnel cost ($25 x 2)
$50
Total miscellaneous costs (7.42)
$7
Annual postage (.41 x 2 = .82)
Annual photocopy (2 x .10 x 3= 0.60)
Annual fax ($6 x 1 = 6)

Thus, total responses for OMB Control No. 0648-0514 will become 2,902; hours, 4,452, and
miscellaneous costs, 12,381.

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