0518 renewal 03-30-11 ss Part A rev

SUPPORTING STATEMENT
ALASKA REGION BERING SEA & ALEUTIAN ISLANDS CRAB
ECONOMIC DATA REPORTS
OMB CONTROL NO. 0648-0518

INTRODUCTION
In January 2004, the United States Congress amended Section 313(j) of the Magnuson-Stevens
Fishery Conservation and Management Act (Magnuson-Stevens Act) to mandate the Secretary of
Commerce (Secretary) to implement the Crab Rationalization Program for the Bering Sea and
Aleutian Islands Management Area (BSAI) crab fisheries. The Program allocates BSAI crab
resources among harvesters, processors, and coastal communities. The North Pacific Fishery
Management Council (Council) prepared, and the National Marine Fisheries Service (NMFS)
approved, the Fishery Management Plan for BSAI King and Tanner Crabs (FMP). The FMP
establishes criteria for the management of certain aspects of the BSAI crab fisheries by the State
of Alaska Department of Fish and Game (ADF&G). The FMP is implemented by regulations at
50 CFR Part 680.
NMFS, Alaska Region implemented the BSAI Crab Rationalization Program (CR Program) to
both maintain rigorous safeguards on use of fishing privileges for a public resource and to
provide safeguards for program constituents. The CR Program components include quota share
(QS) allocation, processor quota share (PQS) allocation, individual fishing quota (IFQ) and
individual processing quota (IPQ) issuance, quota transfers, use caps, crab harvesting
cooperatives, protections for Gulf of Alaska groundfish fisheries, arbitration system, monitoring,
economic data collection, and cost recovery fee collection. The economic data collection
program details may be found at: http://www.alaskafisheries.noaa.gov/regs/680/default.htm.
This action is a request for renewal for this information collection.

A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
Section 313 (j) of the Magnuson-Stevens Act authorizes a mandatory economic data report
(EDR) to be used “to study the impacts of the CR Program,” to insure that the program will
achieve “equity between the harvesting and processing sectors,” and to monitor the “economic
stability for harvesters, processors, and coastal communities.” The Magnuson-Stevens Act also
provides specific guidance on the type of data to be collected, requirements for selecting a
collection agent, verification of data, and treatment and distribution of confidential data that are
included in this collection.

1

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.
Congress required that an independent third-party data collection agent (DCA) administer the
collection and dissemination of the crab EDR data. NMFS selected the Pacific States Marine
Fisheries Commission (PSMFC) to be the DCA. The PSMFC is under contract (through a
grant/cooperative agreement) with NMFS to collect, verify, and disseminate data to NMFS,
ADF&G, and the Council.
The goal of the EDR design was to apply a format that closely matches the way in which records
are kept by the affected fishing industry. NMFS conducted meetings with fishing industry
accountants to define various cost and expenditure categories that match, with some variation,
the general accounting structure present in much of the fleet. Four categories of crab EDR
collect annual data pertaining to cost, revenue, ownership, and employment data from the
harvesting and processing sectors.
NMFS uses the EDR data to evaluate the CR Program to
♦ Estimate effort, operating revenues and costs, and labor income
♦ Understand changes in the makeup of fishery participants
♦ Determine how fishing and processing are undertaken, and
♦ Determine how crew are compensated or employed
The Council uses the EDR data to evaluate the CR Program to analyze changes in
♦ Resource utilization
♦ Excess harvesting and processing capacity
♦ Economic returns
♦ Variable costs and revenues
♦ Economic efficiency, and
♦ Stability of harvesters, processors, and coastal communities
Section 313(j)(1) requires the Secretary to collaborate with the Federal Trade Commission (FTC)
and Department of Justice (DOJ) to develop economic data for analysis by these agencies. Data
from the EDR will directly contribute to this ongoing evaluation of potential anti-trust and anticompetitive practices in the crab industry.
NOAA Fisheries Office for Law Enforcement uses the individual and confidential EDR data to
ensure industry compliance with the data reporting requirements of the CR Program.
Compliance monitoring is an integral component of collecting reliable and accurate data. It
would not be possible to ensure reporting compliance from the firms that are required to provide
the data in a timely fashion without these enforcement tools.
The Alaska Commercial Fisheries Entry Commission (CFEC) issues permits and vessel licenses
for Alaska’s commercial fisheries to qualified individuals in both limited and unlimited fisheries
and provides due process hearings and appeals. The monitoring and enforcement of this
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Program are coordinated by NMFS and ADF&G. Harvesting and processing activity are
monitored for compliance with the regulations. Methods for catch accounting and catch
monitoring plans for cooperatives generate data to provide accurate and reliable estimates of the
total catch and landings to manage quota share accounts, prevent overages of IFQ and IPQ, and
determine regionalization requirements. Monitoring includes landed catch weight and species
composition, bycatch, and deadloss to estimate total fishery removals.
An EDR is required annually for each of four categories of CR fisheries participants. These
categories are:
♦ Catcher vessel
♦ Catcher/processor
♦ Stationary floating crab processor, and
♦ Shoreside crab processor
The following persons must submit an annual EDR:
♦ Persons who owned fishing vessels or processing plants that harvested crab or processed
crab harvested in the CR fisheries at any time during the calendar year.
♦ Persons who were leaseholders of fishing vessels or processing plants that participated in
the CR fisheries during the calendar year. A leaseholder is a person, other than the owner
of the catcher vessel for which the EDR is required, who:
♦ Was identified as the leaseholder, in a written lease, of the catcher vessel,
♦ Paid expenses of the catcher vessel, OR
♦ Claimed expenses for the catcher vessel or processing plants as a business expense on
schedule C of his/her Federal Income Tax Return, or on a State Income Tax Return.
PSMFC mails the annual crab EDR packages to vessel owners, stationary floating crab processor
owners, and shoreside processor owners of record by May 1 each year. The respondent may
request a crab EDR by telephone at 1-877-741-8913 or by email at [email protected]. A
copy in fillable PDF format is available at http://www.psmfc.org/alaska_crab. In addition, an
online version of the catcher vessel EDR is available at
https://www.psmfc.org/alaska_crab/edr/edrlogin.php. NMFS provides an online version of the
EDR only for catcher vessels, because this EDR is much simpler than the EDRs for processors.
Respondents are required to mail in Certification Pages (pages 3 and 4), because a signature is
required to meet the submission requirements.
The annual EDR submission deadline is June 28. Failure to submit an EDR form when required
will result in delay in and/or denial of any and all crab permit applications.
A designated representative, leaseholder, or owner may complete the EDR. The owner or
leaseholder must submit the EDR certification pages either as part of the entire EDR or as a
separate document.

3

♦ The owner or leaseholder must submit the completed EDR certification pages as part of
the entire EDR and must attest to the accuracy and completion of the EDR by signing and
dating the certification pages; or
♦ The owner or leaseholder must submit the completed EDR certification pages only and
must attest that they meet the conditions exempting them from submitting the EDR, by
signing and dating the certification pages.
For the purpose of defining the persons responsible for submitting the EDR, a Leaseholder is a
person, other than the owner of the vessel for which the EDR is required, who:
♦ Was identified as the leaseholder, in a written lease, of the catcher/processor,
♦ Paid expenses of the vessel,
♦ Claimed expenses for the vessel as a business expense on schedule C of his/her Federal
Income Tax Return, or on a State Income Tax Return.
a. Catcher Vessel Crab EDR
To qualify as a CR fisheries participant who may harvest crab in the CR fisheries, a catcher
vessel owner or leaseholder must obtain QS allocation or IFQ, except that QS/IFQ is not needed
to harvest CDQ or Adak community CR Program allocations. Any owner or leaseholder of a
catcher vessel during any period in the calendar year identified on the EDR in which the catcher
vessel was used to harvest crab in a CR fishery must submit to PSMFC, at the address provided
on the form, an EDR for that catcher vessel.
The owner or leaseholder of a catcher vessel must submit the entire EDR under the following
conditions.
If you are ...
The catcher
vessel owner

The
leaseholder

And ...
You harvested BSAI crab in the vessel during this calendar year.
You leased the vessel for a portion of the year to another party, but harvested
some BSAI crab in the vessel during this calendar year (provide the name,
address, and telephone number of the person to whom you leased the vessel
during this calendar year.
You leased or sold the vessel for a portion of the year to another party and
harvested some BSAI crab in the catcher vessel during the calendar year
(provide the name, address, and telephone number of the person to whom you
leased or sold the vessel during the calendar year).
OR
The vessel was lost or rendered permanently inoperable due to accident, and
harvested no BSAI crab in the vessel during the calendar year.
Your vessel was lost or rendered permanently inoperable due to accident, and
harvested no BSAI crab in the vessel during this calendar year.
You harvested BSAI crab in the vessel during this calendar year.

4

You must
complete and
submit ...
Entire EDR
Entire EDR

Entire EDR

Entire EDR
Entire EDR

The owner of a catcher vessel must submit only the Certification section of the EDR under the
following conditions.
If you are ...
The catcher
vessel
owner

And ...
No one harvested BSAI crab in the vessel during this year.
You leased or sold the vessel to another party and harvested no BSAI crab in
the vessel during the calendar year (provide the name, address, and telephone
number of the person to whom you leased or sold the vessel during the calendar
year).
OR
The catcher vessel was lost or rendered permanently inoperable due to accident,
and harvested no BSAI crab in the vessel during the calendar year.
You leased the vessel to another party, and harvested no BSAI crab in the vessel
during this calendar year (provide the name, address, and telephone number of
the person to whom you leased the vessel during the calendar year).

You must
complete and
submit ...
EDR certification
pages
EDR certification
pages

EDR certification
pages

Catcher vessel crab EDR Certification Page
Catcher Vessel Information
Vessel Name and ADF&G Vessel Registration Number
Crab License Limitation Permit Number(s)
USCG Documentation Number
Current Estimated Market Value of Vessel and Equipment
Replacement Value of Vessel and Equipment
Name of Crab Harvesting Cooperative (if applicable)
Vessel Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner
(If name and address are the same as provided in the Owner Information block, do not repeat)
Leaseholder
(If name and address are the same as provided in the Leaseholder Information block, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business FAX Number
Business E-mail address (if available)
EDR filing Status
Check appropriate statement to describe EDR filing status
Buyer/Leaseholder Information (if applicable)
Buyer/Leaseholder Name
Telephone No (include area code)
Business Address
Date of Sale or Lease (day/month/year)
Certification Signature and date signed

5

Catcher vessel crab EDR
BSAI Crab Activity Chart
CR Fishery Code (provided)
ADF&G Fish Ticket Number
Number of Days Crab Fishing
Number of Days Traveling and Offloading.
Crab Sales, Gross Revenue
Crab landings by fishery and IFQ type
CR Fishery Code (provided)
Quota type: CVO IFQ-A
Live pounds
Deadloss
Gross Revenue
Quota type: CVO IFQ-B, CPO IFQ, CDQ
Live pounds
Deadloss
Gross Revenue
Quota type: CVC IFQ, CPC IFQ
Live pounds
Deadloss
Gross Revenue
Vessel Owner/Leaseholder’s IFQ Allocation
Vessel owner/leaseholder's annual harvest quota permits landed by this vessel
CR Fishery Code (provided)
CPO-IFQ Harvested (pounds)
IFQ A Harvested (pounds)
IFQ B Harvested (pounds)
Vessel owner/leaseholder's annual harvest quota permits transferred to other vessels
CR Fishery Code (provided)
CPO- IFQ Transferred
Pounds
Revenue
IFQ A Transferred
Pounds
Revenue
IFQ B Transferred
Pounds
Revenue
BSAI Crab Harvest Quota Lease Costs
Quota Type (provided)
CR Fishery Code (provided)
Pounds leased
Total cost
Quota Type IFQ-C
CR Fishery Code (provided)
Number of Crew Contributing C Shares
Pounds
Total Cost
Labor Payments to Captain and Crew
CR Fishery Code (provided)
Crew
Number of Paid Harvest Crew Members
Total Labor Payment to Harvest Crew
Captain
Total Labor Payment to Captain

6

Labor Payment Details
Expense categories (provided)
Indicate how expenses were assigned (check one for each category)
Deducted
Directly charged
Not charged to crew
Not applicable
Revenue Shares (percentage of net share)
CR Fishery Code (provided)
Owner share percent
Crew share (excluding captain) percent
Captain share percent
BSAI Crab Crew Licenses and permits
License or permit number
Indicate (check one)
ADF&G Commercial Crew license number or
Alaska Commercial Fisheries Entry Commission (CFEC) gear operator permit number
Costs for BSAI Crab Fishing Only
Cost category (provided)
Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Total cost
Insurance Deductibles
Total cost
Crab Pots Purchased for Use in BSAI Crab Fishery
Location code
Quantity
Total cost
Line and Other Crab Gear Purchases
Location code
Total cost
Bait used in BSAI crab fishery
CR Fishery code (provided)
Location code
Bait species
Pounds
Total cost
Fuel, Lubrication, and Fluids Used in BSAI Crab Fishery
Indicate if cost includes lubes and fluids
CR Fishery code (provided)
Location code
Fuel quantity (gallons)
Total cost
Food and Provisions for Crew
Total cost
Other Crew Costs
List type of costs
Total cost
Freight Costs for Landed Crab
Total cost
Storage, Wharfage, and Delivery
Total cost
Observer Costs
CR Fishery code (provided)
Total cost
Crab Landing Taxes and Fees
Total cost

7

Crab Harvest Cooperative Fees
Total cost
Other Crab-specific Costs
List type of costs
Total cost
Annual Vessel Costs by Category
Investments in Vessel and Equipment
Location code
Total cost
Indicate if crab-only cost
Repair and Maintenance for Vessel and Equipment
Location code
Total cost
Indicate if crab-only cost
Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Total cost
Indicate if crab-only cost
Fuel, Lubrication, and Fluids
Location code
Total cost
Indicate if crab-only cost
Other Vessel-specific Costs
Location code
Total cost
Indicate if crab-only cost
Annual Totals for All Fisheries
Total days at sea
Total gross revenue
Total pounds landed
Total labor costs

The number of catcher vessels participating in the CR Program was 112 in 2006, 102 in 2007,
98 in 2008, and 90 in 2009. The number 90 is used in this analysis. The time-to-complete is
given as 37 hours based on information provided by a submitter workgroup formed in 2009 to
assess data quality and burden; however, this time may be changed after CR Program analysis is
complete.
The crab EDR responses from respondents are submitted to PSMFC; however, one hour Federal
Government burden is listed for staff comparison of participants who submitted EDRs with
participants who requested permits.

8

Catcher vessel EDR, Respondent
Number of respondents
Certification only – 6
Full EDR - 84
Total annual responses
Frequency of response = 1
Total burden hours
Time per certification = 1 hr (6 x 1 = 6)
Time per full EDR = 37 hr (84 x 37 = 3,108)
Total personnel cost
Total miscellaneous costs ($311,463.60)
Certification (6 x 2pp x $0.05 = $0.60)
Full EDR (84 x 15pp x $0.05 = $63.00)
Postage for certification pages and other 84 EDRs paid by
PSMFC
Accountant completion of EDR ($100 x 3,114 = $311,400)
Catcher vessel EDR, Federal Government
Total annual responses
Total burden hours
Time per response = 1 hr
Total personnel costs ($50 x 1)
Total miscellaneous costs

90

90

3,114 hr
$0
$311,464

0
1 hr
$50
$0

b. Catcher/processor crab EDR
To qualify as a CR fisheries participant who may process crab harvested in the CR fisheries, a
vessel owner or leaseholder must obtain a PQS allocation, IPQ, or a Registered Crab Receiver
permit, except that PQS/IPQ is not needed to process CDQ or Adak community CR Program
allocations. Any owner or leaseholder of a catcher/processor during any period in the calendar
year identified on the EDR in which the catcher/processor was used to process crab in a CR
fishery must submit to PSMFC, at the address provided on the form, an EDR for that
catcher/processor.
The owner or leaseholder of a catcher/processor must submit the entire EDR under the following
conditions.

9

If you are ...
The
catcher/processor
owner

The leaseholder

And ...
You harvested BSAI crab in the vessel during this calendar year.
You leased the vessel for a portion of the year to another party, but
harvested some BSAI crab in the vessel during this calendar year (provide
the name, address, and telephone number of the person to whom you leased
the vessel during this calendar year.
You leased or sold the vessel for a portion of the year to another party and
harvested some BSAI crab in the catcher vessel during the calendar year
(provide the name, address, and telephone number of the person to whom
you leased or sold the vessel during the calendar year).
OR
The vessel was lost or rendered permanently inoperable due to accident,
and harvested no BSAI crab in the vessel during the calendar year.
Your vessel was lost or rendered permanently inoperable due to accident,
and harvested no BSAI crab in the vessel during this calendar year.
You harvested BSAI crab in the vessel during this calendar year.

You must
complete and
submit ...
Entire EDR
Entire EDR

Entire EDR

Entire EDR
Entire EDR

The owner of a catcher/processor must submit only the Certification section of the EDR under
the following conditions.
If you are ...
The
catcher/processor
owner

And ...
No one harvested BSAI crab in the vessel during this year.
You leased or sold the vessel to another party and harvested no BSAI
crab in the vessel during the calendar year (provide the name, address,
and telephone number of the person to whom you leased or sold the
vessel during the calendar year).
OR
The vessel was lost or rendered permanently inoperable due to accident,
and harvested no BSAI crab in the vessel during the calendar year.
You leased the vessel to another party, and harvested no BSAI crab in
the vessel during this calendar year (provide the name, address, and
telephone number of the person to whom you leased the vessel during
the calendar year).

You must
complete and
submit ...
EDR certification
pages
EDR certification
pages

EDR certification
pages

However, with the current catcher processor configuration, all must complete the entire EDR.
Catcher/processor crab EDR Certification page
Catcher/processor Information
Catcher/processor Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
Crab License Limitation Permit Number(s)
USCG Documentation Number
Current Estimated Market Value of Vessel and Equipment
Replacement Value of Vessel and Equipment
Name of Crab Harvesting Cooperative (if applicable)
Vessel Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available

10

Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner
(If name and address are the same as provided in the Owner Information block, do not repeat)
Leaseholder
(If name and address are the same as provided in the Leaseholder Information block, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business FAX Number
Business E-mail address (if available)
EDR filing Status
Check appropriate statement to describe EDR filing status
Buyer/Leaseholder Information (if applicable)
Buyer/Leaseholder Name
Telephone No (include area code)
Business Address
Date of Sale or Lease (day/month/year)
Signature and date signed
Catcher/processor crab EDR
Harvesting and Processing Information
BSAI Crab Activity Chart
CR Fishery Code (provided)
Dates Covered
Begin date (xx/xx/xx)
End date (xx/xx/xx)
Number of Days Crab Fishing
Number of Days Traveling and Offloading
Number of Days Crab Processing
BSAI Crab Production
Eastern Aleutian Islands Golden CR Fishery
Raw Crab Pounds Processed
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Western Aleutian Islands Golden CR Fishery
Raw Crab Pounds Processed
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bering Sea Tanner CR Fishery
Raw Crab Pounds Processed
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bering Sea Snow CR Fishery
Raw Crab Pounds Processed

11

Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bristol Bay Red CR Fishery
Raw Crab Pounds Processed
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
BSAI Crab Sales to Affiliated Entities
Species Code
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
FOB Revenues (check FOB Port Alaska or Seattle)
BSAI Crab Sales to Unaffiliated Entities
Species Code
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
FOB Revenues (check FOB Port Alaska or Seattle)
Custom Processing Services Provided
CR fishery code
Product Code and Process Code
Custom Processing Revenue
Catcher/Processor Owner/Leaseholder’s IFQ and IPQ Allocation
Vessel Owner/Leaseholder’s Annual Quota Permits Harvested by this Vessel
CR Fishery Code (provided)
CPO – IFQ Harvested (pounds)
IFQ A Harvested (pounds)
IFQ B Harvested (pounds)
IPQ Processed (pounds)
Vessel Owner/Leaseholder’s Annual Quota Permits Transferred to other Vessels
CR Fishery Code (provided)
CPO – IFQ Transferred
Pounds
Revenue
IFQ A Transferred Pounds
Pounds
Revenue
IFQ B Transferred Pounds
Pounds
Revenue
IPQ Transferred
Pounds
Revenue
BSAI Crab CDQ and IFQ Lease Costs
Quota Type (provided)
CR Fishery Code (provided)
Pounds Leased
Total Cost

12

IFQ C Quota Type
CR Fishery Code (provided)
Number of Crew Contributing C Shares
Pounds
Total Cost
Crab Harvesting Labor Costs
Crab Harvesting Labor Payments to Captain and Crew
CR Fishery Code (provided)
Number of Paid Harvest Crew Members
Total Labor Payment to Harvest Crew
Total Labor Payment to Captain
Crab Processing Labor Costs
CR Fishery Code (provided)
Number of Crew with Pay Determined by Processing Work
Average Number of Crab Processing Positions
Total Processing Labor Payment
Harvest Labor Payment Details
Expense Categories (provided)
Indicate whether each expense was
Deducted (shared expenses taken off the top of gross revenues)
Directly charged (charged to an individual after the crew share is calculated), or
Not charged to crew
Not applicable
BSAI Harvest Crew Licenses and Permits
For each individual who worked as a captain or harvest crewmember during the calendar year, record
Alaska Commercial Crew license number or
Alaska CFEC gear operator permit number
Do not count any crewmember more than once.
BSAI Crab Processing Employee Residence
For U.S. residents
If Alaska, enter primary city of residence
If other than Alaska, enter primary state of residence
For country other than United States, enter primary country of residence
Number of employees residing in each of the listed residence locations
BSAI Crab Custom Processing Done for You
Custom Processing - Eastern Aleutian Islands Golden CR Fishery
CR Fishery Code (provided)
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Western Aleutian Islands Golden CR Fishery
CR Fishery Code (provided)
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bering Sea Tanner CR Fishery
CR Fishery Code (provided)
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade

13

Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bering Sea Snow CR Fishery
CR Fishery Code (provided)
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bristol Bay Red CR Fishery
CR Fishery Code (provided)
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Raw Crab Purchases from Delivering Vessels
Raw Crab Purchases, Eastern Aleutian Islands Golden (EAG) CR Fishery
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Western Aleutian Islands Golden (WAG) CR Fishery
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bering Sea Tanner (BST) CR Fishery
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bering Sea Snow (BSS) CR Fishery
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bristol Bay Red (BBR) CR Fishery
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Vessel Costs
Costs for BSAI Crab Production Only
Total cost of Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Total cost of Insurance Deductibles
Crab Pots Purchased for Use in BSAI Crab Fishery
Location Code
Quantity
Total cost
Line and Other Crab Gear Purchases
Location Code
Total cost
Bait used in BSAI crab fishery
CR Fishery Code (provided)
Location Code(s)
Bait species
Pounds

14

Total cost
Fuel, Lubrication, and Fluids Used in BSAI Crab Fishery
Indicate (YES or NO) if cost includes lube/fluids
CR Fishery Code (provided)
Location Code(s)
Fuel Quantity (gallons)
Total Cost
Total cost of Food and Provisions for Crew
Other Crew Costs
Describe
Total Cost
Total cost of Processing and Packaging Materials, Equipment, and Supplies
Total cost of Re-packing
Total cost of Broker Fees and Promotions for BSAI Crab Sales
Total cost of Crab Landing and Sales Taxes and Fees
Total cost of Storage, Wharfage, and Delivery
Observer Costs
CR Fishery Code (provided)
Total Cost
Total cost of Freight and Handling for Processed Crab Products from the Vessel
Total cost of Product Storage
Total cost of Fishing Cooperative
Other Crab-specific Costs
Describe
Total cost
Annual Vessel Costs
Investments in Vessel and Equipment
Location code
Total cost
Indicate (YES or NO) if crab only cost
Repair and Maintenance (R&M) for Vessel and Equipment
Location code
Total cost
Indicate (YES or NO) if crab only cost
Number of Employees and Salaries for Foremen, Managers, and other Employees
Number of employees
Total cost
Indicate (YES or NO) if crab only cost
Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Total cost
Indicate (YES or NO) if crab only cost
Fuel, Lubrication, and Fluids
Location code
Total cost
Indicate (YES or NO) if crab only cost
Indicate (YES or NO) if fuel costs include lube/fluids
Other Vessel-specific Costs
Describe
Total cost
Indicate (YES or NO) if crab only cost
Annual Totals for All Fisheries
Total sum for the calendar year for all fishing and processing activities
Total Processing days
Total Days at sea
Gross FOB revenues
Indicate whether Alaska or Seattle

15

Total cost
Total Finished pounds processed
Total Round Pounds Caught (exclude discards)
Total Labor costs

The number of catcher/processors participating in the CR Program was 7 in 2006, 6 in 2007,
5 in 2008, and 5 in 2009. The number 5 is used in this analysis. The time-to-complete is given
as 37 hours based on information provided by a submitter workgroup formed in 2009 to assess
data quality and burden; however, this time may be changed after CR Program analysis is
complete.
The crab EDR responses go to PSMFC; however, one hour Federal Government burden is listed
for staff comparison of participants who submitted EDRs with participants who requested
permits.
Catcher/processor crab EDR, Respondent
Number of respondents
Total annual responses
Frequency of response = 1
Total burden hours
Time per response = 37 hr
Total personnel cost
Total miscellaneous costs ($18,507.50)
Photocopy $0.1 x 15 x 5 = $7.50
Postage paid by PSMFC
Accountant fee to complete EDR
($100 x 185 = $18,500)

Catcher/processor EDR, Federal Government
Total annual responses
Total burden hours
Time per response = 1 hr
Total personnel cost ($50 x 1)
Total miscellaneous costs

5
5
185 hr
0
$18,508

0
1 hr
$50
0

c. Stationary floating crab processor (SFCP) EDR
To qualify as a CR fisheries participant who may process crab harvested in the CR fisheries, a
SFCP owner or leaseholder must obtain a PQS allocation, IPQ, or a Registered Crab Receiver
permit, except that PQS/IPQ is not needed to process CDQ or Adak community CR Program
allocations. Any owner or leaseholder of an SFCP during any period in the calendar year
identified on the EDR in which the SFCP was used to process crab in a CR fishery must submit
to PSMFC, at the address provided on the form, an EDR for that SFCP.
The owner or leaseholder of a stationary floating processor (SFCP) must submit the entire EDR
under the following conditions.

16

If you are ...
The SFCP
owner

The SFCP
leaseholder

And ...
You processed BSAI crab in the SFCP during this calendar year.
You leased a portion of your IPQ to another party, and processed BSAI crab in
the SFCP during the calendar year (provide the name, address, and telephone
number of the person to whom you leased the IPQ during the calendar year).
You operated the SFCP, and you processed BSAI crab during the calendar
year.

You must
complete and
submit ...
Entire EDR
Entire EDR

Entire EDR

The owner of an SFCP must submit only the Certification section of the EDR under the
following conditions.
If you are
...
The
SFCP
owner

And ...
No one processed BSAI crab in the SFCP during the calendar year.
You leased all of your IPQ to another party, and you processed no BSAI crab in
the SFCP (provide the name, address, and telephone number of the person to
whom you leased or sold the vessel during the calendar year).

Stationary floating crab processor (SFCP) EDR Certification page
SFCP Information
SFCP Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
USCG Documentation Number
Current Estimated Market Value of SFCP and Equipment
Replacement Value of SFCP and Equipment
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business Fax Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business Fax Number
Business E-mail address, if available
Person Completing this Report
Indicate if owner, leaseholder, or designated representative
Designated Representative
Name and Title
Business Telephone Number and Business Fax Number
Business E-mail address (if available)
EDR Filing Status
Select the appropriate statement to describe EDR filing status
Buyer/leaseholder Information
Name
Business Telephone Number and Business Fax Number
Business E-mail address (if available
Signature and date signed
SFCP EDR
BSAI Crab Processing Activity
Eastern Aleutian Islands Golden CR Fishery
Dates Covered

17

You must
complete and
submit ...
EDR certification
pages
EDR certification
pages

Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Western Aleutian Islands Golden CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bering Sea Tanner CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bering Sea Snow CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bristol Bay Red CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
BSAI Crab Sales and Processing
BSAI Crab Sales to Affiliated Entities
Species Code
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
FOB Revenues
Total revenues
check FOB Port Alaska or Seattle
BSAI Crab Sales to Unaffiliated Entities
Species Code
Product Code and Process Code

18

Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
FOB Revenues
Total revenues
check FOB Port Alaska or Seattle
Custom Processing Services Provided
CR fishery code
Product Code and Process Code
Custom Processing Revenue
Labor Information
Crab Processing Labor Costs
CR fishery code (provided)
Average Number of Crab Processing Positions
Total Man-Hours
Total Processing Labor Payment
BSAI Crab Employee Residence
For U.S. residents
If Alaska, enter primary city of residence
If other than Alaska, enter primary state of residence
For country other than United States, enter primary country of residence
Number of employees residing in each of the listed residence locations
BSAI Crab Custom Processing Done for You
Custom Processing - Eastern Aleutian Islands Golden CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Western Aleutian Islands Golden CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bering Sea Tanner CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bering Sea Snow CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bristol Bay Red CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)

19

Finished Pounds
Processing Fee
Raw Crab Purchases from Delivering Vessels
Raw Crab Purchases, Eastern Aleutian Islands Golden (EAG) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Western Aleutian Islands Golden (WAG) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bering Sea Tanner (BST) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bering Sea Snow (BSS) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bristol Bay Red (BBR) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Vessel/Plant Costs
Costs for BSAI Crab Production Only
Total cost of Fisheries Taxes
Processing and Packaging Materials, Equipment, and Supplies
Location of purchase (provided)
Total cost
Total cost of Food and Provisions
Total Other Costs for Direct Crab Labor
Total cost of Insurance Deductibles
Total Re-packing Costs
Broker Fees and Promotions for BSAI Crab Sales
CR Fishery Code (provided)
Total cost
Processor Quota (IPQ) Lease Costs
CR Fishery Code (provided)
Total pounds
Total cost
Total Observer Costs
CR Fishery Code (provided)
Total cost
Total cost of Freight Costs for Supplies to the Plant
Total cost of Freight and Handling Costs for Processed Crab Products from the Plant
Total cost of Product Storage
Total cost of Water, Sewer, and Waste Disposal
Other Crab-specific Costs
Describe
Total cost
Annual Vessel/Plant Costs

20

Fuel, Electricity, Lubrication and Hydraulic Fluids
Total cost
Indicate (YES or NO) if crab only cost
Investments in Plant and Equipment
Location code
Total cost
Indicate (YES or NO) if crab only cost
Repair and Maintenance for Vessel and Equipment
Location code
Total cost
Indicate (YES or NO) if crab only cost
Number of Employees and Salaries for Foremen, Managers, and other Employees
Number of employees
Total cost
Indicate (YES or NO) if crab only cost
Other Vessel-specific Costs
Describe
Total cost
Indicate (YES or NO) if crab only cost
Annual Totals for All Fisheries
Total Processing days
Total FOB revenues (indicate Alaska or Seattle)
Total Finished pounds processed
Total Processing Labor costs

The number of stationary floating crab processors participating in the CR Program was 10 in
2006, 4 in 2007, 5 in 2008, and 8 in 2009. The number 8 is used in this analysis. The time-tocomplete is given as 48 hours based on information provided by a submitter workgroup formed
in 2009 to assess data quality and burden; however, this time may be changed after CR Program
analysis is complete.
The crab EDR responses go to PSMFC; however, one hour Federal Government burden is listed
for staff comparison of participants who submitted EDRs with participants who requested
permits.

21

Stationary floating crab processor EDR, Respondent
Number of respondents
8
Certification only – 6
Full EDR -- 2
Total annual responses
8
Frequency of response = 1
Total burden hours
102 hr
Time per certification = 1 hr (6x1=6)
Time per full EDR = 48 hr (2x48=96)
Total personnel cost
0
Total miscellaneous costs ($10,202.10)
$10,202
Photocopy
Certification (6 x 2pp x 0.05 = 0.60
Full EDR (2 x 15pp x 0.05 = $1.50)
Postage paid by PSMFC
Accountant fee to complete EDR
($100 x 102= $10,200)
Stationary floating crab processor EDR, Federal
Government
Total annual responses
Total burden hours
Time per response = 1 hr
Total personnel costs ($50 x 1)
Total miscellaneous costs

0
1 hr
$50
0

d. Shoreside processor EDR
To qualify as a CR fisheries participant who may process crab harvested in the CR fisheries, a
shoreside processor owner or leaseholder must obtain a PQS allocation, IPQ, or a Registered
Crab Receiver permit, except that PQS/IPQ is not needed to process CDQ or Adak community
CR Program allocations. Any owner or leaseholder of a shoreside processor during any period in
the calendar year identified on the EDR in which the shoreside processor was used to process
crab in a CR fishery must submit to PSMFC, at the address provided on the form, an EDR for
that shoreside processor.
The owner or leaseholder of a shoreside processor must submit the entire EDR under the
following conditions.
If you are ...
The shoreside
processor owner

The shoreside
processor
leaseholder

And ...
You processed BSAI crab in the Shoreside Processor during this calendar
year.
You leased a portion of your IPQ to another party, and processed BSAI crab
in the Shoreside Processor during the calendar year (provide the name,
address, and telephone number of the person to whom you leased the IPQ
during the calendar year).
You operated the Shoreside Processor, and you processed BSAI crab during
the calendar year.

22

You must
complete and
submit ...
Entire EDR
Entire EDR

Entire EDR

The owner of an shoreside processor must submit only the Certification section of the EDR
under the following conditions.
If you are ...
The shoreside
processor
owner

And ...
No one processed BSAI crab in the Shoreside Processor during the calendar
year.
You leased all of your IPQ to another party, and you processed no BSAI
crab in the Shoreside Processor (provide the name, address, and telephone
number of the person to whom you leased or sold the vessel during the
calendar year).

You must
complete and
submit ...
EDR certification
pages
EDR certification
pages

Shoreside processor EDR Certification page
Shoreside processor Information
Shoreside Processor Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
Physical Location of Land-based Plant (street address, city, state, zip code)
Borough Assessed Value of Plant and Equipment ($) and Year Assessed
Current Estimated Value of Plant and Equipment ($)
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same name and address provided in the Owner Information
block above, do not repeat)
Leaseholder (If name and address are the same name and address provided in the Leaseholder Information
block above, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business FAX Number
Business E-mail address (if available)
EDR Filing Status
Select the appropriate statement to describe EDR filing status
Signature and date signed
Shoreside processor EDR
BSAI Crab Processing Activity
Eastern Aleutian Islands Golden CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Western Aleutian Islands Golden CR Fishery
Dates Covered
Number of Crab Processing Days

23

Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bering Sea Tanner CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bering Sea Snow CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
Bristol Bay Red CR Fishery
Dates Covered
Number of Crab Processing Days
Raw Crab Pounds Purchased
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Custom Processed (Yes or No)
BSAI Crab Sales and Processing
BSAI Crab Sales to Affiliated Entities
Species Code
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
FOB Revenues (check FOB Port Alaska or Seattle)
BSAI Crab Sales to Unaffiliated Entities
Species Code
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
FOB Revenues (check FOB Port Alaska or Seattle)
Custom Processing Services Provided
CR fishery code
Product Code and Process Code
Custom Processing Revenue
Labor Information
Crab Processing Labor Costs
CR fishery code (provided)
Average Number of Crab Processing Positions

24

Total Man-Hours
Total Processing Labor Payment
BSAI Crab Employee Residence
For U.S. residents
If Alaska, enter primary city of residence
If other than Alaska, enter primary state of residence
For country other than United States, enter primary country of residence
Number of employees residing in each of the listed residence locations
BSAI Crab Custom Processing Done for You
Custom Processing - Eastern Aleutian Islands Golden CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Western Aleutian Islands Golden CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bering Sea Tanner CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bering Sea Snow CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Custom Processing - Bristol Bay Red CR Fishery
Raw Pounds Supplied to Custom Processors
Product Code and Process Code
Crab Size and Crab Grade
Box Size (check lb or kg)
Finished Pounds
Processing Fee
Raw Crab Purchases from Delivering Vessels
Raw Crab Purchases, Eastern Aleutian Islands Golden (EAG) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Western Aleutian Islands Golden (WAG) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bering Sea Tanner (BST) CR Fishery

25

IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bering Sea Snow (BSS) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Raw Crab Purchases, Bristol Bay Red (BBR) CR Fishery
IFQ Type
Crab Size and Crab Grade
Raw Pounds Purchased
Gross Payment
Plant Costs
Costs for BSAI Crab Production Only
Total cost of Fisheries Taxes
Processing and Packaging Materials, Equipment, and Supplies
Location of purchase (provided)
Total cost
Total cost of Food and Provisions
Total Other Direct Costs for Crab Labor
Total cost of Insurance Deductibles
Total Re-packing Costs
Broker Fees and Promotions for BSAI Crab Sales
CR Fishery Code (provided)
Total cost
Processor Quota (IPQ) Lease Costs
CR Fishery Code (provided)
Total pounds
Total cost
Observer Costs
CR Fishery Code (provided)
Total cost
Total cost of Freight Costs for Supplies to the Plant
Total cost of Freight and Handling Costs for Processed Crab Products from the Plant
Total cost of Product Storage
Total cost of Water, Sewer, and Waste Disposal
Other Crab-specific Costs
Describe
Total cost
Annual Plant Costs
Fuel, Electricity, Lubrication and Hydraulic Fluids
Total cost
Indicate (YES or NO) if crab only cost
Investments in Plant and Equipment
Location code
Total cost
Indicate (YES or NO) if crab only cost
Repair and Maintenance for Vessel and Equipment
Location code
Total cost
Indicate (YES or NO) if crab only cost
Number of Employees and Salaries for Foremen, Managers, and other Employees
Number of employees
Total cost

26

Indicate (YES or NO) if crab only cost
Other Plant-specific Costs
Describe
Total cost
Indicate (YES or NO) if crab only cost
Annual Totals for All Fisheries
Total Processing days
Total FOB revenues (check Alaska or Seattle)
Total Finished pounds processed
Total Processing Labor costs

The number of shoreside processors participating in the CR Program was 21 in 2006, 15 in 2007,
19 in 2008, and 29 in 2009. The number 29 is used in this analysis. The time-to-complete is
given as 48 hours based on information provided by a submitter workgroup formed in 2009 to
assess data quality and burden; however, this time may be changed after CR Program analysis is
complete.
The crab EDR responses go to PSMFC; however, one hour Federal Government burden is listed
for staff comparison of participants who submitted EDRs with participants who requested
permits.
Shoreside processor EDR, Respondent
Number of respondents
Full EDR = 16
Certification only = 13
Total annual responses
Frequency of response = 1
Total burden hours
Time per certification = 1 hr (13x1=13)
Time per full EDR = 48 hr (16x48=768)
Total personnel cost
Total miscellaneous costs (78113.30)
Photocopy
Certification (13 x 2pp x 0.05 = 1.30)
Full EDR (16 x 15pp x 0.05 = $12)
Postage paid by PSMFC
Accountant fee to complete EDR
(100 x 781 = $78,100)
Shoreside processor EDR, Federal Government
Total annual responses
Total burden hours
Time per response = 1 hr
Total personnel costs ($50 x 16)
Total miscellaneous costs

29

29
781 hr

0
$78,113

0
1
$50
0

e. Verification of data.
NMFS authorizes PSMFC to obtain the services of an auditor to assist in verification of EDR
data. At a minimum, the auditor shall be board certified and be selected based upon ability to
perform the services in a timely manner within professional standards.

27

To ensure that each company consistently and accurately completes the EDR, a qualified
PSMFC auditor conducts verification of EDR information with the owner or leaseholder.
Auditing will ensure that the data produce accurate and reliable information for the Alaska crab
fisheries. The PSMFC auditor may review and request copies of additional data provided by the
owner or leaseholder, including but not limited to: previously audited or reviewed financial
statements, worksheets, tax returns, invoices, receipts, and other original documents
substantiating the data. It is estimated that approximately one-third of submitted EDR forms will
need to be subject to verification audit in any given year due to questionable or omitted data.
The owner or leaseholder must provide copies of additional data to facilitate verification by
PSMFC. Auditors will verify records by comparing specific elements of the report with
participant accounting records. To make this activity a s efficient and non-intrusive as possible,
NMFS suggests that participants:
♦ Keep a copy of the completed EDR or certification pages submitted to PSMFC. Copy
and attach extra sheets as needed.
♦ Keep a file that has all of the supporting information used in the preparation of the EDR.
♦ Make sure that the EDR agrees to the company's highest level of financial information.
For this purpose, the highest level of financial information is defined in order as:
• Audited financial statements
• Reviewed financial statements
• Compiled financial statements
• Tax returns.
♦ Record only whole numbers. Round up dollar figures to the next highest dollar.
It is estimated that approximately one-third of submitted EDR forms will need to be audited in
any given year due to questionable or omitted data. The owner or leaseholder must respond to
data verification inquiries from PSMFC within 20 days of the date of issuance of the inquiry;
there may be questions that are sequential based on previous questions. It would be difficult to
reasonably complete verification, if a longer period were allowed. The verification questions are
likely to be small in number, and occur through a telephone call or other short communication.
The 20-day response period should not place a significant burden on submitters.

28

Verification of Data, Respondent
Number of respondents [(90+4+8+29)]/3
Total annual responses
Frequency of response = 1
Total burden hours
Time per response = 8 hr
Total personnel cost
Total miscellaneous costs
Photocopy ($.05 x 300 pp x 44 = 660)
Telephone calls ($5 x 44 = 220)
Accountant fee to verify EDR ($100 x 352 = 35,200)
Verification of Data, Federal Government
Total annual responses
Total burden hours
Total personnel costs
Total miscellaneous costs

44
44
352
0
$36,080

0
0
0
0

It is anticipated that the information collected will be disseminated in aggregated and nonconfidential form to the public or used to support publicly disseminated information about Crab
Rationalization. As explained in the preceding paragraphs, the information gathered has utility.
NOAA Fisheries 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. 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.
The EDRs may be downloaded from the NMFS web site at www.alaskafisheries.noaa.gov.,
printed, and submitted by mail or FAX to PSMFC. Of these documents, only the catcher vessel
EDR is set up for online submission. All other EDRs must be mailed or faxed.
NMFS in the future plans to coordinate efforts with PSMFC in the next year or so to create a
data entry system that will allow additional applicants to enter EDR data online. The data will
go directly into a database. It is anticipated that this type of system will be more efficient,
timely, and accurate, though as stated above, some may choose to continue with the fillable pdf
version.
4. Describe efforts to identify duplication.
None of the information collected as part of this information collection duplicates other
collections. This information collection is part of a specialized and technical program that is not
like any other.

29

5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Approximately 238 small entities own crab harvest vessels or crab catcher/processors. Eight
small entities appear to qualify for processor allocations. This information collection does not
impose a significant impact on small entities.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The intent of this collection is to study the impacts of the CR Program; to ensure that the
program achieves equity between the harvesting and processing sectors; and to monitor the
economic stability for harvesters, processors, and coastal communities. Without the specified
reporting scheme described in this Supporting Statement, the program would be jeopardized.
The consequences of not collecting this information would be that NMFS could not fulfill the
intent of the law created under Pub. L. No. 108-199 and would be unable to provide data to the
Council and the State of Alaska to evaluate the CR Program for each of the required review
periods. Pub. L. No. 108-199 also requires that each component of the crab program enacted by
Congress must be implemented or the whole program must be withdrawn. Thus, disapproval of
this data collection program would threaten all components of Pub. L. No. 108-199.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Not applicable.
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, 75 FR 59687, published September 28, 2010, solicited public
comment on this collection. One comment was received.
The commenter stated that it takes 35 hours to complete an EDR for an active fishing vessel,
longer if the vessel is selected for audit. He goes on to say "The estimate of 7.5 hours is not
accurate and understates an important industry contribution towards the joint management of the
Bering Sea Fishery." This comment is similar to many comments received in the past year from
the fishing industry. With this action, NMFS revised the burden hour estimates to respond to this
comment and to input from an industry workgroup convened in 2009 to assess data quality and
reporting burden.

30

The Council is also conducting a major review and revision of the CR Program EDRs.
Alternatives for revising EDRs to improve data quality, simplify the reporting requirement, and
reduce reporting burden and duplication with other reporting requirements are currently under
development. A determination on a selected alternative for revisions to the EDR Program and
survey instruments is expected during 2011, and implementation of revised reporting
requirements is expected for 2012.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift will be provided under this program.
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 EDR data are confidential and are not disseminated to the public.
PSMFC disseminates the EDR data to NMFS, ADF&G, and the Council staff after removing all
personal identifiers such as Social Security Numbers, vessel identification numbers, names,
addresses, and telephone numbers. PSMFC supplants the data with a randomized identification
number that can be matched between datasets.
The information collected is confidential under section 402(b) of the Magnuson-Stevens Act (16
U.S.C. 1801 et seq.) and under NOAA Administrative Order (AO) 216-100, which sets forth
procedures to protect confidentiality of fishery statistics. It was last revised in 1994.
NOAA also follows regulatory procedures for data confidentiality found at 50 CFR Sec. 600.405
et seq. The Magnuson-Stevens Act generally prohibits collection of economic data, particularly
from processing entities. In the legislation for the CR Program, an exception was created to the
prohibition. NMFS was directed to implement a mandatory economic data program and feed the
data to prescribed entities, with or without identifiers, depending on the entity.
NMFS will retain control over the information that is supplied, and safeguard it from improper
access, modification, and destruction, consistent with NOAA standards for confidentiality,
privacy, and electronic information.
System of Records: Routine Uses
The routine uses were described in the COMMERCE/NOAA System-16; Crab Economic Data
Report for Bering Sea/Aleutian Islands Management Area (BSAI) off the coast of Alaska,
published on March 3, 2005 (70 FR 10360).
1. In the event that a system of records maintained by the Department to carry out its
functions indicates or is relevant to a violation or potential violation of law or contract,
whether civil, criminal or regulatory in nature and whether arising by general statute or
particular program statute or contract, or rule, regulation or order issued pursuant thereto,
or the necessity to protect an interest of the Department, the relevant records in the
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system of records, including individual identifiers, may be referred to the appropriate
agency, whether Federal, State, local or foreign, charged with the responsibility of
investigation or prosecuting such violation or charged with enforcing or implementing
the statute or contract, or rule, regulation or order issued pursuant thereto, or protecting
the interest of the Department. That agency may disclose such records in the course of
conducting its investigation.
2. A record from this system of records may be disclosed in the course of presenting
evidence to a court, magistrate or administrative tribunal, including disclosures during the
course of litigation, such as through discovery or to opposing counsel in the course of
settlement negotiations.
3. A record in this system of records may be disclosed to a Member of Congress submitting
a request involving an individual when the individual has requested assistance from the
Member with respect to the subject matter of the record.
4. A record in this system of records may be disclosed without individual identifiers to a
contractor of the Department having need for the information in the performance of the
contract, but not operating a system of records within the meaning of 5 U.S.C. 552a(m).
5. A record in this system of records may be disclosed with individual identifiers to
Department of Justice and the Federal Trade Commission when such records are
requested by those agencies for anti-trust analyses or enforcement proceedings.
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.
This information collection does not involve information of a sensitive nature.
12. Provide an estimate in hours of the burden of the collection of information.
Estimated total respondents: 132, increased from 131. Estimated total responses: 176, down
from 262. Estimated total burden: 4,534 hr, increased from 1,478 hr. Estimated total personnel
costs: $0.
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).
Estimated total miscellaneous costs: $454,367 increased from $150,606.
14. Provide estimates of annualized cost to the Federal government.
Estimated total burden: 4 hr. Estimated total personnel costs: $200. Estimated total
miscellaneous costs: $500,000 (see below).
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A significant cost of administering the EDR is the cost of the contract with the independent third
party. In P. L. No. 108-199, section 801, Congress required that the economic data collection be
administered by an independent third party under contract to NMFS. The PSMFC is the
independent agent selected by NMFS to disseminate EDR forms, to be the collection point for
the EDR, and to verify the accuracy of the data collected from the BSAI crab fishing industry.
The estimated cost of this contract is $500,000 annually.
Total annual estimated costs: $500,200.
15. Explain the reasons for any program changes or adjustments.
This action is a renewal without program change to EDRs or regulations.
Adjustments:
•

There was a net increase of one respondent, based on the most recent records.

•

NMFS increased the estimated burden hours for completion and submittal of the different
types of EDR, which then increased the miscellaneous costs (for accountant fees) to
complete and submit the EDRs.

•

For the Verification of Data, it is estimated that approximately one-third of submitted
EDR forms will need to be audited in any given year due to questionable or omitted data.
In the 2008 renewal, which should have been shown as applying to only 1/3 of responses,
burden and cost for verification of all responses was included. For this renewal, the
adjustment is made to show auditing of only 1/3 of responses.

Total estimated changes are shown below:
♦ Catcher Vessel EDR
Respondents and responses changed from 100 to 90.
Burden hours changed from 750 hours to 3,114 hours.
Miscellaneous costs changed from $ 75,139 to $ 311,464.
♦ Catcher/processor EDR
Respondents and responses changed from 10 to 5
Burden hours changed from 125 hours to 185 hours
Miscellaneous costs changed from $ 12,515 to $ 18,508.
♦ Stationary floating crab processor EDR
Respondents and responses changed from 5 to 8
Burden hours changed from 50 hours to 102 hours
Miscellaneous costs changed from $ 5,008 to $ 10,202.
♦ Shoreside processor EDR
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Respondents and responses changed from 16 to 29
Burden hours changed from 160 hours to 781 hours
Miscellaneous costs changed from $ 16,024 to $ 78,113.
♦

Verification of data
Respondents and responses changed from 131 to 44
Burden hours changed from 393 to 352
Miscellaneous costs changed from $41,920 to $36,080.

Net changes: increase of one respondent, decrease of 86 respondents, increase of 3,056 hours
and increase of $303,761 in miscellaneous costs.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
NMFS is required by the Council to provide 18-month, three-year, and five-year reviews of the
economic effects of the CR Program. As part of these reviews, a number of data reports with
aggregated and verified EDR data will be available to the Council and/or Congress. The analysis
will include assessment of the change in the benefits and costs of the BSAI crab resource as well
as distributional effects of the implementation of CR Program. Data regarding costs and
revenues of harvesting and processing crab fisheries are displayed in aggregate to protect
individual data.
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.

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