Justification for change

JUSTIFICATION FOR CHANGE
HIGH SEAS FISHING PERMIT, VESSEL IDENTIFICATION, AND REPORTING
REQUIREMENT
OMB CONTROL NO. 0648-0304

The National Marine Fisheries Service (NMFS) issues permits, under the High Seas Fishing
Compliance Act (HSFCA), to United States (U.S.) fishing vessels fishing on the high seas.
HSFCA also requires vessels be marked for identification purposes and for permitees to report
their fishing effort and catch. These requirements apply to all vessels fishing on the high seas.
NMFS proposes to modify OMB Control No. 0648-0304 in the following ways:
•
•
•

Revise the application fee in the application form and instructions;
Add additional options for vessel types in the permit application form and
Merge multiple, related information collections under a single OMB Control Number.

Application Fee
NMFS would change the application fee from $67 to $129. The fees are recalculated every two
years using guidance provided in the National Oceanic and Atmospheric Administration
(NOAA) Finance Handbook.
The HSFCA requires the Secretary to establish by regulation the level of fees to be charged for
high seas fishing permits. HSFCA published such regulation at 50 CFR 300.13(d), which states
that NMFS will charge a fee to recover the administrative expenses of permit issuance, with the
amount determined in accordance with the procedures of the NOAA Finance Handbook. The fee
is specified on the application form and in the application instructions.
The change in fee alters the cost burden for this collection. Recent information indicates that
about 120 persons apply for this permit annually, as opposed to the currently approved number
of 200. Assuming 120 persons apply each year, the new number of responses is 120, the new
burdens are 60 hours (currently approved, 100) and the cost is $15,533 ($15,480 in fees plus $53
in postage) (currently approved, $13,484).
Vessel Types
A change would be made to the permit application instructions to alert applicants of the
requirement to obtain a NMFS-issued fishing authorization called a “Western and Central Pacific
Fisheries Commission (WCPFC) Area Endorsement”. This authorization is issued by the
Regional Administrator of NMFS Pacific Islands Region as an endorsement on the permit issued
under the High Seas Fishing Compliance Act. Any vessels receiving fish from another fishing
vessel or bunkering or otherwise supplying or supporting a vessel that is harvesting highly
migratory species (HMS), as well as those vessels harvesting HMS, are subject to this
requirement.
NMFS would also add new vessel types to the application form under the section for vessel

types. The new types include “fish carrier,” “bunker,” and “other support.” This addition will
allow NMFS to know about such vessels operating on the high seas, particularly the high seas
areas of the WCPFC Convention Area.
At this time, there are no U.S. vessels of these types that would apply for an HSFCA permit or a
WCPFC Area Endorsement. The change is requested in the event such vessels apply.
All changes on the form are highlighted.
The burden estimates are not affected by these changes in the application and application
instructions.
Merging Information Collections
NMFS would be adding No. 0648-0348 (High Seas Vessel Identification) and No. 0648-0349
(High Seas Vessel Reporting) to No. 0648-0304. These two collections will be discontinued
once this change request is approved. These three collections pertain to vessels that conduct
fishing activities on the high seas. A person who operates a vessel on the high seas submits
information for a permit and is required to mark their vessel and submit information on their
fishing activities.
The merging of the collections will result in the summation of burden estimates into OMB
Control No. 0648-0304.
The response and burden estimates for OMB Control No. 0648-0348 is 50 responses, 38 hours,
and $1,250.
The response and burden estimates for OMB Control No. 0648-0349 is 15,000 responses, 850
hours, and $3,012.
The latest response and burden estimates for OMB Control No. 0648-0304, based on adjusting
the numbers of permit applications and raising the application fee and postage costs, is 120
responses, 60 hours, and $15,533.
Thus, the burden estimate for OMB Control No. 0648-0304 will become 15,170 responses, 948
hours, and $19,795.