Justification for change

JUSTIFICATION FOR CHANGE
SOUTH PACIFIC TUNA ACT
OMB CONTROL NO. 0648-0218
This change request is associated with a final rule (0648-AY91). The rule affects the information
requirements and associated burden for the license application element of the information collection. The
rule is issued under authority of the South Pacific Tuna Act of 1988 (16 U.S.C. 973-973r) and issued at
50 CFR 300 Subpart D.
The rule modifies the procedures used to request vessel licenses, including the information collected as
part of those procedures. There are two changes. First, additional information is collected as part of the
license applications, so the burden for that element of the collection has increased. Second, additional
information is collected in “expressions of interest,” which consist of a subset of the information collected
in the license applications, and which are due from prospective license applicants by a specified date each
year, in advance of the license applications. The information in expressions of interest is needed to
determine license eligibility under the new license allocation system established under the rule.
Expressions of interest are optional but it is expected that most, if not all, license applicants will exercise
this option, as it would enhance the likelihood of being issued a license. Thus, for the purpose of
estimating the information collection burden, it is assumed that every respondent that submits a license
application will also submit an expression of interest, and further, that four additional respondents will
submit an expression of interest but not a license application. The amount of information required in
expressions of interest, and thus the burden and cost, depend on whether the respondent is seeking to
renew a license or obtain a new license.
There are no changes to the license application form, but the form will have to be accompanied by the
following additional information:

(1) A copy of the vessel’s current annual USCG Certificate of Documentation.
(2) Electronic photographs of the vessel, including a bow-to-stern side-view and a photograph of every
area of the vessel that is marked with its international radio call sign.
(3) A schematic stowage/well plan for the vessel.
(4) A copy of the VMS unit installation certificate.
There is no form for the expression of interest. For new licenses, all of the following information will be
required in expressions of interest; for license renewals, only items (1) and (2) will be required:
(1) The licensing period for which the license is being sought.
(2) The current name, international radio call sign, and annual USCG Certificate of Documentation
number of the vessel (if known).
(3) The name and address of each owner, charterer, and master of the vessel.
(4) A copy of the vessel’s current USCG Certificate of Documentation, or if not issued, then a statement
of whether application has been or will be made for one, including any endorsements sought.
(5) A list of the licensing periods, if any, during which a license was issued for the vessel.
(6) A statement of the total amount, in metric tons, of any tuna species landed or transshipped from the
vessel at U.S. ports for each of the years 1988 through the current year.
The new burden associated with the expressions of interest is estimated at 15 minutes per response for
respondents that are seeking to renew their licenses, and 2 hours per response for applicants that are
seeking new licenses. The estimated burden associated with the license application form has changed
from 0.25 hours per response to 1 hour per response. The added burdens for these two components of the
collection are estimated as follows:

(a) Expression of interest (optional) –
(i) renewals – 1 response/yr x 15/60 minutes/response x 22 respondents = 5.5 (6) hours (22
responses/yr).
(ii) non-renewals – 1 response/yr x 2 hr/response x 4 respondents = 8 hours (4 responses/yr).
(b) License application form – 1 response/yr x 45 minutes/response x 22 respondents = 16 hours (22
responses/yr) in addition to the 15 minutes per response currently estimated.
There will be no change to the submission cost for the license application; for the expressions of interest,
postage will be $1 per response, for a total of $26.
Total added responses: 26; total added burden: 30 hours; total added: $26.