Supporting statement appendix

APPENDIX
to
CHINOOK EDR SUPPORTING STATEMENT
Part A of the Supporting Statement describes three new data forms (collectively referred to as the
Chinook Salmon EDR) for use by members of the Bering Sea pollock fishery:
♦ Chinook salmon PSC Allocation Compensated Transfer Report (CTR),
♦ Vessel Fuel Survey, and
♦ Vessel Master Survey.
The data collected in these reports and surveys and data collected in existing revised collections
(OMB 0648-0213, 0401, and 0515) would be combined with other data to analyze the
Amendment 91 program.
Part B of the Supporting Statement summarizes the Amendment 91 program, describes the data
to be collected to analyze the Amendment 91 program, and answers the five questions on the
statistical sampling methods, response rates, non-response bias, methods for testing the data
forms, and staff involved in the Chinook salmon EDR program.
Part B is divided into the following sections.
INTRODUCTION
Council Purpose and Need Statement -- Chinook Salmon Economic Data Program
AFA sectors, Cooperatives, and CDQ groups
Chinook Salmon Bycatch in the Bering Sea Pollock Fishery
Amendment 91 to the BSAI FMP
CURRENT INFORMATION TO EVALUATE AMENDMENT 91
Incentive Plan Agreement (IPA) and IPA Annual Report
Limitations to IPA plan and IPA Annual Report data for evaluating Amendment 91
AFA Cooperative Report
Limitations of AFA Cooperative Reports for evaluating Amendment 91
Catch Accounting and Observer Data
Limitations to the use of Catch Accounting and Observer Data for Evaluating
Amendment 91
NEW INFORMATION TO EVALUATE AMENDMENT 91
Chinook salmon PSC Allocation Compensated Transfer Report (CTR)
Vessel Fuel Survey
Vessel Master Survey
REVISIONS TO EXISTING COLLECTIONS FOR CHINOOK SALMON EDR
Revisions to the IPA Annual Report
Revisions to Collect Change-in-Location Data

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INTRODUCTION
NMFS would implement the Chinook Salmon Economic Data Program to evaluate the
effectiveness of Chinook salmon PSC management measures for the Bering Sea pollock fishery
that were implemented under Amendment 91 to the Fishery Management Plan for Groundfish of
the Bering Sea and Aleutian Islands Management Area (FMP). The data collected for this
program would be submitted by members of the American Fisheries Act (AFA) inshore,
catcher/processor, and mothership sectors, as well as representatives for the six western Alaska
Community Development Quota (CDQ) organizations that presently receive allocations of
Bering Sea pollock. The management measures, explained in detail in the final rule for
Amendment 91 (75 FR 53026, August 30, 2010), are also intended to provide insight into the
behavioral response of the participants in the pollock fishery.
Council Purpose And Need Statement -- Chinook Salmon Economic Data Program
The purpose of the Chinook Salmon EDR Program is to provide data for the analysis of the
Chinook salmon PSC management in the Bering Sea pollock fishery. The Chinook Salmon PSC
Program was implemented in Amendment 91 to the Bering Sea and Aleutian Islands
Management Area Fishery Management Plan (FMP). The principal objective of Amendment 91
was to minimize Chinook salmon bycatch (Chinook Salmon PSC) to the extent practicable,
while achieving optimum yield.
The Amendment 91 Program was composed of three main parts :
♦ An overall hard cap of 60,000 Chinook Salmon PSC that may not be exceeded by the
Bering Sea pollock fleet.
♦ Access to the higher Chinook Salmon PSC hard cap and conditional privileges to transfer
allocated amounts of that hard cap for participants who agree to a bycatch reduction incentive
plan agreement (IPA).
♦ A performance standard, proportionally applied to each American Fisheries Act (AFA)
sector, for keeping Chinook Salmon PSC below 47,591 Chinook salmon in two years out of
seven years.
The North Pacific Fisheries Management Council (Council) subsequently recommended the
development of a Chinook Salmon EDR Program to analyze the effectiveness of Amendment 91
to reduce Chinook Salmon PSC and to assess any changes in the yield of pollock. The Council’s
purpose and need statement also recommended that these data be used to address four
components of Amendment 91, which are as follows:
♦ Effects and impacts of the Amendment 91 IPAs, the higher and lower PSC hard caps, and
the performance standard;
♦ Effectiveness of the IPA incentives in times of high and low levels of salmon bycatch;
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♦ Effectiveness of the performance standard to reduce salmon bycatch; and
♦ How Amendment 91 affects where, when, and how pollock fishing and salmon bycatch
occur.
NMFS anticipates that analysis of this data collection will provide sufficient information to
provide insights into the primary objective of Amendment 91 -- which is to reduce Chinook
Salmon PSC. Questions include: the costs of Chinook Salmon PSC reduction, the number of
Chinook Salmon PSC, the actions taken by vessel operators to avoid Chinook Salmon PSC, and
transfer information (the number and frequency of Chinook Salmon PSC transfers and why these
transfers occur or do not occur)
AFA Sectors, Cooperatives, and CDQ Groups
NMFS manages the Bering Sea pollock fishery under the American Fisheries Act (AFA) (16
U.S.C. 1851). The AFA “rationalized” the Bering Sea pollock fishery in part by allowing for the
formation and management of fishery cooperatives in the three pollock sectors
(catcher/processor, mothership, and catcher vessel) and the CDQ groups. The AFA authorizes
the formation of fishery cooperatives in all sectors of the Bering Sea pollock fishery, grants antitrust exemptions to cooperatives in the mothership sector, and imposes operational limits on
fishery cooperatives in the Bering Sea pollock fishery. The AFA fishery cooperatives consist of
groups of vessel owners who agree to apportion the available pollock quota among themselves.
In so doing, the cooperatives moderate the unnecessary and wasteful fishing effort that occurred
prior to AFA, and has increased financial returns for most members of the fleet.
Under the AFA, NMFS allocates ten percent of the Bering Sea pollock total allowable catch
(TAC) to the CDQ Program. After allowance for incidental catch of pollock in other fisheries,
NMFS allocates the remaining TAC as follows: 50 percent to vessels harvesting pollock for
processing by inshore processors, 40 percent to vessels harvesting pollock for processing by
catcher/processors, and 10 percent to vessels harvesting pollock for processing by motherships.
NMFS manages the catcher vessels that do not join an inshore cooperative under the “inshore
open-access fishery.”
AFA cooperatives further subdivide each sector’s or inshore cooperative’s pollock allocation
among participants in the sector or cooperative through private agreements. The cooperatives
manage these allocations to ensure that individual vessels and companies do not harvest more
than their agreed-upon share. The cooperatives also facilitate transfers of pollock among the
cooperative members, enforce contract provisions, and participate in the inter-cooperative
agreement to reduce salmon bycatch. A more detailed description of AFA cooperatives and
cooperative and inter-cooperative agreements may be found in the proposed rule for Amendment
91 (75 FR 14016; March 23, 2010) and in OMB Control No. 0648-0401.
Each year, catcher vessels eligible to deliver pollock to the seven AFA inshore processors may
form up to seven inshore cooperatives that are each associated with a particular inshore
processor. The AFA catcher/processor sector consists of AFA-eligible vessels in the Pollock
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Conservation Cooperative and High Seas Catcher’s Cooperative. The High Seas Catcher’s
Cooperative consists of owners of the catcher vessels eligible to deliver pollock to the
catcher/processors. NMFS issues an annual allocation of pollock to the entire catcher/processor
sector, based on each vessel’s pollock catch history. The AFA mothership sector is made up of
three motherships and the AFA-eligible catcher vessels that deliver pollock to these motherships.
These catcher vessels have formed a cooperative called the Mothership Fleet Cooperative, which
sub-allocates and manages the mothership sector pollock allocation among the catcher vessels
authorized to harvest this pollock.
NMFS does not manage the sub-allocations of pollock among members of the Pollock
Conservation Cooperative, High Seas Catcher’s Cooperative, or Mothership Fleet Cooperative.
The cooperatives control the harvest by their member vessels so that the pollock allocation to the
sector is not exceeded. However, NMFS monitors pollock harvest by all members of the
catcher/processor sector and mothership sector. NMFS retains the authority to close directed
fishing by sector if vessels in that sector continue to fish once the sector’s seasonal allocation of
pollock has been harvested.
Chinook Salmon Bycatch In The Bering Sea Pollock Fishery
Pollock is harvested by AFA fishing vessels using pelagic (mid-water) trawl gear, which consists
of large nets towed through the water by the vessel. At times, Chinook salmon and pollock
occur in the same locations in the Bering Sea. Consequently, Chinook salmon are accidently
caught in the nets as pollock are harvested.
The Bering Sea pollock fishery catches up to 95 percent of the Chinook salmon taken
incidentally as bycatch in the Bering Sea groundfish fisheries. From 1992 through 2001, the
average Chinook salmon bycatch in the Bering Sea pollock fishery was 32,482. Bycatch
increased substantially from 2002 through 2007, with an average of 74,067 Chinook salmon per
year caught during this period. A historic high of approximately 122,000 Chinook salmon were
taken in the Bering Sea pollock fishery in 2007. However, Chinook salmon bycatch has declined
in recent years to 20,493 in 2008 and 12,410 in 2009. The causes of the decline in Chinook
salmon bycatch in 2008 and 2009 are unknown. In years of historically high Chinook salmon
bycatch in the Bering Sea pollock fishery, 2005 to 2007, the rate of Chinook salmon bycatch
averaged 64 Chinook salmon per 1,000 metric tons of pollock harvested.
Chinook salmon bycatch varies seasonally and by sector. In most years, the majority of Chinook
salmon bycatch occurs during the pollock A season of the Bering Sea pollock fishery. The
variation in bycatch rates among sectors and seasons (A season or B season) is due, in part, to the
different fishing practices and fishing patterns each sector uses to fully harvest their pollock
allocations.
Chinook salmon bycatch at sea in the pollock fishery affects various State of Alaska commercial
and recreational salmon fisheries and subsistence salmon fisheries. Chinook salmon bycatch
affects escapement and recruitment of Chinook salmon in the Yukon River and potentially other
Chinook salmon river systems . Escapement is that portion of Chinook salmon that escapes the
commercial and recreational fisheries and reaches the freshwater spawning grounds in rivers.
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Recruitment is the amount of fish added to the exploitable fish stock each year due to growth
and/or migration into the fishing area. These effects are described in detail in the Environmental
Regulatory Impact Review for the Amendment 91 final rule (NMFS 2009).
In summary, in some years Chinook salmon mortality from bycatch in the pollock fishery is
likely to impact the number of Chinook salmon available to the commercial salmon fisheries in
the Yukon River, as well as the subsistence, personal use, and recreational Chinook salmon
fisheries of the Yukon River. In some years, the bycatch may also affect the escapement of
Chinook salmon in the Yukon River and its tributaries, to the extent that low spawning numbers
may impact recruitment of juvenile Chinook in certain tributaries of the Yukon River. Data on
the origin of Chinook Salmon stocks intercepted in the pollock fishery are insufficient to know
with certainty if this bycatch is a significant contributor to low Chinook Salmon escapement
numbers in Yukon River tributaries or to assess the magnitude of possible impacts to Yukon
River salmon fisheries. Data issues associated with the uncertainty are described in detail in the
Amendment 91 EIS/RIR/FRFA.
As documented in the RIR/IRFA for this action, AFA pollock vessel masters and members of
AFA sectors and cooperatives face difficulties detecting the presence of Chinook salmon while
fishing for pollock. They need to determine how best to minimize their bycatch and mortality of
Chinook salmon while comparing the tradeoffs for their sector and AFA cooperative for Chinook
Salmon bycatch avoidance. These difficulties are as follows:
♦ Individual Chinook salmon are difficult to detect in the water column with current sonar
technology, prior to or during a haul and retrieval of pollock trawl gear.
♦ Chinook salmon migrate throughout many areas frequented by pollock trawlers, and
these migration patterns are unpredictable within and between years.
♦ Once Chinook salmon encounters occur, considerable uncertainty exists about whether
those interceptions will impact escapements in the Yukon River and its tributaries, or if the
impacts will occur during periods of high or low Chinook salmon escapements; and
♦ On the pollock fishing grounds, Chinook salmon PSC rates vary by Chinook Salmon
population strength and by overlap spatially and temporally of pollock fishing and Chinook
salmon.
♦ Most actions taken to avoid Chinook salmon PSC are likely to be costly to participants in
this fishery and difficult for individual vessel operators to assess if voluntary efforts to avoid
Chinook Salmon PSC will result in a future benefit.
Bycatch of any species, including discard or other mortality caused by fishing, is a concern of the
Council and NMFS. National Standard 9 of the Magnuson-Stevens Fishery Conservation and
Management Act (Magnuson-Stevens Act), specifically requires the Council to select
conservation and management measures that NMFS implements to minimize bycatch and
bycatch mortality to the extent practicable. The Magnuson-Stevens Act defines bycatch as fish
that are harvested in a commercial fishery but neither, sold nor kept for personal use. Chinook
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salmon is categorized as prohibited species under the Magnuson-Stevens Act, the BSAI FMP,
and NMFS regulations at 50 CFR part 679. The objective for managing Chinook salmon as PSC
in the Bering Sea pollock fishery is to minimize Chinook salmon mortality to the extent
practicable, while achieving optimum yield in target fisheries, because Chinook salmon are a
valuable and fully utilized species caught in commercial, subsistence, and recreational fisheries.
In some locations, Chinook salmon face conservation concerns. Fishermen must avoid salmon
bycatch and are prohibited from selling or utilizing salmon for personal use. Any salmon caught
must either be donated to the Prohibited Species Donation Program under § 679.26, or returned
to Federal waters as soon as is practicable, with a minimum of injury, after an observer has
determined the number of salmon and collected any scientific data or biological samples.
Chinook salmon bycatch in the Bering Sea pollock fishery is assumed to have 100 percent
mortality.
Amendment 91 To The BSAI FMP
NMFS implemented Amendment 91 to the BSAI FMP to manage Chinook salmon PSC in the
Bering Sea pollock fishery. Amendment 91 combines limits on incidentally caught Chinook
with an Incentive Plan Agreement (IPA) and performance standard. This combination is
designed to minimize bycatch to the extent practicable in all years and prevent bycatch from
reaching the limit in most years. The most important objective of Amendment 91 is to reduce
Chinook bycatch amounts and rates across all AFA sectors, cooperatives, and vessels in future
years in accordance with National Standards 1 and 9. In addition, Amendment 91 provides for
the development of one or more secondary industry-operated incentive programs.
Allocations. Under Amendment 91, NMFS may allocate transferable Chinook salmon PSC
to the catcher/processor sector, mothership sector, inshore cooperatives (shoreside processor or
stationary floating processor), and CDQ groups participating in the Bering Sea pollock fishery.
Transferable Chinook salmon PSC allocations may be further sub-allocated to members of a
sector or cooperative and may be exchanged between sectors, cooperatives, and their members.
In addition, NMFS may allocate non-transferable Chinook salmon PSC allocations under certain
circumstances to AFA catcher vessels and catcher/processors if they do not qualify for
transferable allocations.
The representative for a qualifying sector or inshore cooperative may receive a transferable or
non-transferrable allocation of Chinook salmon PSC from NMFS. The representative is allowed
to administer any transfer of Chinook salmon PSC between any other group that received
transferable Chinook salmon PSC. The transfers could occur between any qualifying sector,
inshore cooperative, or CDQ group.
The requirements for receiving transferable or non-transferable Chinook salmon PSC, as well as
the amount of Chinook salmon PSC vary between each sector, inshore cooperative, or CDQ
group. For example, the catcher/processor sector may receive transferable Chinook salmon PSC
based on each vessel’s proportional amount of the 47,591 or 60,000 Chinook salmon PSC caps
established in Amendment 91 , if they form a single “sector-level entity.” If all members of the
catcher/processor sector also form an IPA that is approved by NMFS and meets other
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qualifications in Amendment 91, the catcher/processor sector may receive an allocation of
Chinook salmon PSC that is based on each vessel’s proportional amount of 60,000 Chinook
salmon. The proposed rule for Amendment 91 provides a detailed explanation of these
requirements.
The inshore cooperatives and the CDQ groups already are recognized by NMFS as entities
eligible to receive allocations on behalf of others. The inshore cooperatives are permitted
annually by NMFS under § 679.4(l)(6) and must submit copies of their cooperative contracts to
NMFS to be issued a permit. The representative for receiving Chinook salmon PSC for the
inshore cooperatives would be the same person as named on the cooperative’s annual application
for pollock allocations. An inshore cooperative or a CDQ group must notify NMFS in writing if
its representative for purposes of Chinook salmon PSC allocations is a different person. The
CDQ groups are authorized under section 305(i)(1) of the Magnuson-Stevens Act to receive
fishery allocations from NMFS. No additional authorizations are needed for the inshore
cooperatives or CDQ groups to be eligible to receive transferable allocations of Chinook salmon
PSC. The representative for a CDQ group would be its chief executive officer
PSC allocations are based on either a 60,000 Chinook salmon PSC limit if some or all of the
pollock industry participates in an industry-developed IPA, or a “lower cap” of 47,591 Chinook
salmon PSC limit if industry does not form any IPAs. This lower Chinook salmon PSC limit is
also referred to as the annual threshold amount.
Performance Standard. Amendment 91 requires that each sector meet a “performance
standard” by staying below the lower cap/annual threshold amount in all but two of any seven
consecutive years. The performance standard for each sector is based on the historical catches of
each vessel in each sector and applied as a proportion of the 47,591 Chinook salmon PSC limit.
The Chinook bycatch cap and performance standard in Amendment 91 is intended to encourage
pollock vessels to avoid Chinook salmon bycatch, even in years when Chinook salmon bycatch
is low.
Low salmon bycatch may occur in periods when escapement of Chinook salmon into the Yukon
River are also low, and thus it may actually be of greater value to conservation of Chinook
salmon to further reduce bycatch in years when salmon bycatch is relatively low. At the same
time, larger bycatch levels may be due to either greater run strength or greater co-location of
salmon and pollock, so having an upper limit to bycatch is also a valuable means to promote
Chinook salmon conservation.
Census of Salmon. To assess Chinook bycatch rates and to use as a basis for monitoring and
enforcing the Chinook salmon PSC allocations, Amendment 91 included in eLandings a new
PSC accounting census of all Chinook salmon for catcher/processors and for catcher vessels
delivering to shoreside processors, stationary floating processors, and motherships. For catcher
vessels, delivering shoreside and to motherships Chinook Salmon bycatch will be accounted for
by a census at the point of delivery. For a mothership or catcher/processor the census of
Chinook Salmon bycatch would occur by each haul.

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Electronic Logbook (ELB). Also, Chinook salmon PSC information would be submitted by
trawl gear catcher/processors to NMFS through a newly created ELB (see OMB 0648-0213)
required by Amendment 91 that works with eLandings (see OMB 0648-0515). NMFS requires
that the Chinook salmon PSC counts be submitted using an ELB so that the data are readily
available to NMFS in a timely manner.
After implementing Amendment 91 and its performance standard, allocation of transferable
Chinook salmon PSC allocations, and the formation of incentives developed in each IPA, the
Council anticipates the likelihood of the following responses from participants in the pollock
fishery:
♦ Substantial changes in sector or cooperative plans and agreements for distribution and use
of Chinook salmon PSC.
♦ Creation of a market for trading Chinook salmon PSC between sectors and cooperatives
and among their members and the joint trading of sub-allocations of Chinook salmon PSC and
pollock by vessels.
♦ Changes in the location and timing of fishing effort for pollock and the bycatch of
Chinook salmon PSC.
♦ Increase in cost of harvesting pollock; and
♦ Reduction of the annual bycatch of Chinook salmon.
CURRENT INFORMATION TO EVALUATE AMENDMENT 91
Incentive Plan Agreement (IPA)
A key component of Amendment 91 is the Incentive Plan Agreement (IPA) (see OMB Control
Number 0648-0401). An IPA authorized by Amendment 91 is a private contract among vessel
owners or CDQ groups that establishes incentives for participants to minimize bycatch at all
levels of Chinook salmon abundance. The parties to an IPA must be owners of AFA-eligible
catcher vessels, catcher/processors, motherships, or the representatives of CDQ groups. The
representative, referred to as the IPA representative, of an AFA cooperative or a sector-level
entity formed under Amendment 91 would sign an IPA on behalf of all vessel owners that are
members of that cooperative or sector-level entity. NMFS requires participants to demonstrate to
the Council through performance and annual reports that the vessel owners who are IPA
signatories are accomplishing the Council’s intent that Chinook salmon PSC be minimized in
each year. Each IPA plan will describe the structure of the incentives or penalties for reducing
Chinook salmon PSC at the level of a sector, cooperative, or individual vessel.
Participation in an IPA is voluntary; however, any vessel or CDQ group that chooses not to
participate in an IPA would be subject to a restrictive opt-out cap that provides a maximum
backstop cap of 28,496 Chinook salmon PSC. Each year, NMFS would calculate the backstop
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cap based on the number of vessels that opt-out of an IPA. The backstop cap would not be
allocated to opt-out participants but would be managed by NMFS as a cap. NMFS would not
evaluate any vessel or CDQ group that fishes under the backstop cap.
IPA Annual Report
Each IPA representative is required to submit a written IPA Annual Report to the Council for
each year following the year in which the IPA is first effective. Each IPA Annual Report is
intended to provide a qualitative evaluation and some quantitative information on the
effectiveness of the IPAs.
Each IPA Annual Report must describe the following:
♦ The incentive measures in effect in the previous year.
♦ How the incentive measures affected individual vessels.
♦ Whether incentive measures were effective in achieving salmon savings beyond levels
that would have been achieved in absence of the incentive measures.
♦ Any amendments to the terms of the IPA that were approved by NMFS since the last
annual report, and the reasons that any amendments to the IPA plan were made; and
♦ The reasons that any amendments to the IPA plan were made.
The RIR for this action anticipates that the IPA plan and IPA Annual Reports implemented in
Amendment 91 may provide the following industry observations and data on the effectiveness of
the Amendment 91 management measures including:
♦ Summaries of temporal and spatial shifts in effort undertaken by the fleets;
♦ Comparisons of Chinook salmon bycatch rates achieved by vessels participating in an
IPA versus any vessels not participating in an IPA;
♦ An overview of the use of new gear technologies;
♦ Assessment of the effect of Rolling Hot Spot (RHS) closures; or
♦ Description of research undertaken to reduce Chinook salmon PSC.
The IPA plan and IPA Annual Report, along with other existing data (e.g., catch accounting,
observer), are important information sources for determining whether the Amendment 91
management measures are meeting the Council’s purpose and need statement to understand the
effects of Amendment 91 IPAs, including the performance standard. The information provided
in the IPA Annual Report is essential to address one of the objectives of the Council’s purpose

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and need statement - for the Chinook Salmon EDR to evaluate the conclusions drawn by
industry in that report.
Limitations to IPA Plan and IPA Annual Report Data for Evaluating Amendment 91
NMFS does not require the data and discussion contained in each IPA plan or IPA annual report
in a specific format. For example, the format of information in an IPA plan or report may vary
by between years or by each group submitting a report. As a result, it is likely that data may not
be sufficiently uniform and consistent to quantify the differences between two or more IPAs.
Though some of the sector and cooperative data provided in the report may be quantitative, many
questions are subjective and respondents may have an incentive to portray the components of
Amendment 91 as effective. Individual identifiers (such as a NMFS vessel ID number) are not
required for each transfer recorded in an IPA Annual Report, making it potentially difficult to
merge transfer data with other NMFS information that includes a mutually exclusive identifier.
The market value of PSC allocations reflects its expected value to the pollock fishery. However,
neither IPA Annual Reports nor AFA Cooperative Reports presently require that each transaction
between a person buying and selling Chinook salmon PSC be recorded with a corresponding
price or at the level of an individual owner of a vessel.
Also, Amendment 91 did not implement any requirements for reporting information in the IPA
Annual Report to track how costs may vary by vessel, cooperative, or sector, under the new
program. It would be helpful to have data on how the cost of AFA vessels operating in the
Bering Sea pollock fishery would change under the various Chinook Salmon bycatch incentive
plans. For example, information on the amount of fuel and the cost of fuel used to perform
various Chinook salmon bycatch avoidance actions could assist in evaluating the effectiveness of
Amendment 91.
In summary, The IPA Annual Report is potentially a helpful element to meet the Councils
purpose and need statement, but does not provide information to independently verify its
accuracy; other data must be relied upon to assess the fourth objective of the Council’s purpose
and need statement to “evaluate the conclusions drawn by industry in the IPA annual report.”
AFA Cooperative Report
While AFA cooperative reports do not represent formal NMFS data on groundfish harvests and
PSC, they are one of the only sources of disaggregated catch data that are available to the public.
In addition, the AFA cooperative reports are the only sources that can be used by analysts to
report comprehensive data on individual AFA vessel harvests without violating NMFS and State
of Alaska Department of Fish and Game rules data confidentiality rules.
At the beginning of each year, all AFA cooperatives must submit an AFA Cooperative Report to
the Council by April 1 of the following year, detailing the activities of the cooperative for the
previous year (50 CFR 679.61(f)). Each AFA Cooperative Report must include
♦ The cooperative’s allocated catch of pollock and sideboard species;
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♦ Actions taken by the cooperative for vessels that exceed their allowed catch and bycatch
in pollock and all sideboard fisheries;
♦ Any sub-allocations of pollock and sideboard species made by the cooperative to
individual vessels;
♦ Total weight of pollock landed outside the State of Alaska on a vessel-by-vessel basis;
and
♦ The number of salmon taken by species and season, including Chinook salmon.
AFA Cooperative Reports may contain some information for evaluating Amendment 91,
specifically, the Council purpose and need statement identifies the need to evaluate how
Amendment 91 affects “where, when and how pollock fishing and salmon bycatch occur.” The
AFA Cooperative Reports could provide helpful data for that element of the assessment. For
example, AFA Cooperative Reports could provide some explanation for why fishing effort at the
beginning of a pollock season or at some other point in a season may have been lower, higher, or
similar to a previous season (and if Amendment 91 caused any of the changes).
Limitations of AFA Cooperative Reports for Evaluating Amendment 91
Because AFA Cooperative Reports are not required to itemize reasons or provide systematic and
independently verifiable data for why pollock fishing may progress at a slower or more rapid rate
in a season, it is likely that this data will be anecdotal and of limited use. In the event that IPAs
are not formed in all sectors, the annual AFA Cooperative Reports could document the
distribution of Chinook salmon PSC allocations among vessels in the cooperative. Currently,
some transfers of pollock allocations are reported in AFA Cooperative Reports, but these pollock
transfers are not reported in a uniform manner between each cooperative, making it difficult to
use these data for some types of comparative analysis.
The limitations for pollock allocations and transfers in the AFA Cooperative Reports also apply
to Chinook salmon allocations and transfers of PSC. Tracking Chinook salmon PSC transfers by
owner or vessel is not required in an AFA Cooperative Reports. The AFA Cooperative Reports
do not require submission of pollock or Chinook salmon PSC price data. Prices of pollock and
Chinook salmon PSC allocations could be helpful in evaluating Amendment 91.
The market value of PSC allocations reflects its expected value to the pollock fishery. However,
the AFA Cooperative Reports presently require that each transaction between a person buying
and selling Chinook salmon PSC be recorded with a corresponding price or at the level of an
individual owner of a vessel. Also, Amendment 91 did not implement any requirements for
reporting information in the AFA Cooperative Reports to track how costs may vary by vessel,
cooperative, or sector, under the new program.
AFA Cooperative Reports are not likely to provide sufficiently detailed data to make reliable
comparisons of individual vessel Chinook salmon PSC rates relative to distance traveled from
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port. Considering each of these previously detailed limitations, AFA Cooperative Reports are
not likely to provide sufficiently detailed data to make reliable comparisons of Chinook salmon
PSC rates for individual vessels or masters of vessels by time and location, or distance from port.
Thus, the AFA Cooperative Report would have specific limits as a stand-alone source of
information for addressing all four components of the Council’s purpose and need statement.
Specifically the “evaluation of conclusion drawn by the industry in the IPA Annual Report” and
the effectiveness of the IPA incentives in times of high and low levels of salmon bycatch” could
not be evaluated with this data.
Catch Accounting and Observer Data
The two primary sources of information used to account for catches in the Bering Sea pollock
fishery are onboard observer information and industry-reported data on catch and processed
product amounts. Both sources are electronically recorded and submitted to NMFS. Catch
accounting and observer data linked with other data would be used to assist analysts in
addressing the four components of the Council’s purpose and need statement. It would help
analysts understand the effects and impacts of the IPAs, evaluate the performance standard,
evaluate when and how Chinook Salmon bycatch and pollock catches occur, and could assist in
evaluating the conclusions drawn by industry in IPA annual reports.
In 2005, NMFS implemented an interagency electronic reporting system for the catch accounting
system to reduce reporting redundancy with other agencies and consolidate fishery landings data.
All vessels in the Bering Sea pollock fishery are required to report all groundfish landings,
discard, and production through a web-based interface known as eLandings (OMB 0648-0515).
There is also a stand-alone application available for the vessels fishing and processing catch at
sea (the at-sea fleet). The at-sea fleet submits eLandings files via email.
The eLandings software provides managers with real-time access to individual vessel
information, including individual pollock vessel catch and bycatch and unused amounts of
allocated pollock and Chinook salmon PSC. Each industry report submitted via eLandings
undergoes error checking by NMFS. Data are then stored in a database and are made available
to management agencies. There are two basic eLandings report types used for catch estimation:
production reports and landing reports.
Observer data are also used in the catch accounting system, and are collected using a stratified
sample design where strata are defined by vessel size and gear fished. Within each stratum, a
multi-stage sampling design is used to sample the species composition of the catch, length
distribution of select species, and other catch components.
Observer data collected on vessels in the Bering Sea pollock fishery are transmitted
electronically to a centralized database. The Alaska Fisheries Science Center (AFSC) quality
control staff review the data, interview each observer returning from the fishery, and conduct
several quality control processes for each dataset incorporated into the database. This database
contains all data collected by observers at processing plants and onboard vessels, including
marine mammal interaction data, groundfish and non-target catch, and salmon PSC (including
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Chinook salmon PSC). The data tables are organized in the database to reflect where and how
the data are collected. NMFS merges observer data with industry reports nightly; the merged
data are available to fishery managers the following day.
For catcher/processors and catcher vessels delivering pollock to motherships, observer data
combined with a census of each vessel’s eLandings landing reports may be used to make
comparisons of Chinook salmon PSC rates of vessels fishing in different areas during the same
period of time or similar areas at different periods of time. These comparisons allow for an
analysis of how PSC catch rates vary by vessel type and location. For catcher vessels that make
several tows over a large area and that deliver to shoreside processors or SFPs at the end of a
fishing trip, the actual location of Chinook salmon bycatch will be more difficult to estimate.
For these deliveries, a full accounting of Chinook salmon PSC occurs at the plant, and in most
cases covers multiple tows made within a trip.
Observer data combined with landing reports will allow analysts to assess trends in rates and
variation of Chinook salmon PSC by vessel, pollock vessel operation type, week or season, and
across cooperatives, sectors, or the entire AFA fleet. The combined observer and landing data
will also allow analysts to make accurate and reliable comparisons of percentages of the TAC
harvested at times of relatively high or low Chinook salmon encounter rates. Combining
information on the variation in Chinook salmon PSC amounts and rates with other information
on the structure, timing, and application of the incentives that apply to different groups at
different times could provide insight into the effectiveness of Chinook salmon PSC measures.
Limitations to the Use of Catch Accounting and Observer Data for Evaluating Amendment 91
Catch accounting and observer data allow an assessment of trends in Chinook Salmon PSC by
individual vessel, cooperative, and sector. However, observing changes in bycatch levels and
rates has limitations for assessing whether the Amendment 91 incentives or the IPAs in particular
actually caused a given change in bycatch rates. One difficulty is the variability in the abundance
of Chinook salmon that appears in different years in different locations. For example, no
currently available data exists to determine if high or low Chinook salmon encounter rates are
independent from the spatial and temporal effort from the pollock fleet. In other words, the only
information we have on the abundance of Chinook salmon on the pollock grounds is through
observations of bycatch during directed fishing on pollock. Because a change in bycatch rates
may be the result of either a decrease in salmon on the fishing grounds or a change in fishing
behavior, the lack of fishery-independent Chinook salmon abundance estimates is a constraint to
drawing conclusions about the cause and effect of industry and regulatory incentives for
avoiding Chinook salmon bycatch.
For catcher vessels delivering shoreside or to an SFP, NMFS accounts for all catch of groundfish
and Chinook salmon PSC at the time of landing. Because catcher vessels may trawl in several
locations before delivering to an inshore processor, it is not possible to verify the amount of
Chinook salmon catch by individual haul. Attempts to apportion Chinook salmon PSC to a
specific haul using vessel monitoring system (VMS) or other data are subject to error. These
data constraints may complicate efforts to attribute a change in Chinook salmon PSC to specific
types of incentives. For example, the effectiveness of an IPA penalty for a catcher vessel that
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exceeded a predetermined Chinook salmon PSC rate in a specific statistical area may be difficult
to assess if catcher vessels are deploying trawl gear on consecutive hauls on either side of the
boundary set out by the IPA penalty.
In contrast to the constraints for apportioning Chinook salmon PSC at the haul level for catcher
vessels, catcher/processors will have continuous census accounting of Chinook Salmon PSC at
sea. Each haul must be observed, and all Chinook salmon must be removed and accounted for at
the flow scale. The observer records the haul start and end times and locations of each haul; the
path may be tracked with VMS. The combination of location data with haul-by-haul catch
accounting allows for Chinook salmon PSC to be accurately observed. Even for
catcher/processors, however, catch accounting and observer data combined will not explain
which bycatch incentives changed a specific amount of bycatch by time and location for each
sector or cooperative or how the back stop cap of 47,591 changed a specific amount of bycatch
by time and location. For example, a master of a catcher/processor (or catcher vessel) relocates
to new fishing grounds to avoid Chinook salmon bycatch. Catch accounting data, even if it
records a reduced catch of Chinook salmon PSC, would not, by itself, provide a reason for the
transit. Various factors such as weather, time, and area encounters with Chinook Salmon
bycatch, or market prices for pollock could easily have influenced the movements and fishing
effort by a vessel, as well as that vessel’s rate of Chinook salmon PSC.
NEW INFORMATION TO EVALUATE AMENDMENT 91
In December 2009, the Council recommended three new data collection requirements and
revisions of two existing collections. Representatives of AFA catcher/processor and mothership
sectors, inshore cooperatives, the inshore open access fishery, and CDQ groups would submit the
Chinook Salmon EDR. The Council intended these requirements to provide additional data and
to improve the quality of data to assess the effectiveness of Amendment 91.
To collect the data required by the Council, NMFS would require submission of each of the
following new forms, which are collectively called the Chinook Salmon EDR. These forms
would be in a fillable electronic format available on the NMFS Alaska Region website.
The Reports/Surveys are:
♦ Chinook Salmon PSC Allocation Compensated Transfer Report (CTR).
♦ Vessel Fuel Survey; and
♦ Vessel Master Survey.
In addition to the Chinook Salmon EDR, NMFS would collect new information concerning
vessel movements on the fishing grounds and more general data on pollock allocations and
transfers through revisions to the IPA Annual Report. These new data are described below in the
section titled: “New Information: Revisions to Existing Collections for Chinook Salmon EDR.”
NMFS will use the new data to conduct descriptive analysis and quantitative or tabular
comparisons of the annual, seasonal, and where possible, trip-level and haul-level changes in the
pollock fleet under Amendment 91 by sector, cooperative, and vessel. Descriptions of these
analyses are provided below. NMFS may also conduct statistical analysis of the effect of the
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Amendment 91 IPAs and Chinook salmon PSC limits on trawl location choices, variation in the
amount of Chinook salmon bycatch in the AFA trawl fishery, and the changes in the value of
Chinook salmon PSC transactions if data are sufficiently accurate and complete.
In describing the data required for this program, the Council’s motion recognized that the
proposed data collection program would be limited in scope, and the quantity and quality of data
submitted may only partially address the purpose and need statement for this action:
“The Council recognized the challenges associated with evaluating the effectiveness of the
Chinook salmon bycatch incentive program with data collected on trip-based information and
stated preferences for transiting and fishing practices aimed at avoiding the bycatch of Chinook
salmon. Statistical analyses generated from this type of data is novel and involves some trial and
error in designing collection methods, specifying variables to collect, and verifying accuracy of
data. The draft forms in this analysis reflect that NMFS and the Council analysts have worked
with industry to focus this collection to address the key impacts of Amendment 91. This
collection is intended to provide additional information to status quo data, but may not provide
an unequivocal answer to all of the Council's policy questions.”
Chinook Salmon PSC Allocation Compensated Transfer Report (CTR).
A detailed explanation of the variables and submission requirements for the CTR is included in
Part A of this supporting statement. The purpose of the CTR is to account for Chinook salmon
PSC transfers and the amount of money exchanged for transfers between AFA vessel owners and
other entities transferring Chinook salmon PSC. NMFS would examine data reported for each
transaction and tabulate the data to compare the amount of Chinook salmon PSC transferred in
each transaction, number of transactions by vessel type (sector and AFA cooperative), and time
intervals of the transfers in a season or year. Also, this data will allow for tabulation of the
average and variation in price paid for transactions by vessel operation type, sector, and AFA
cooperative. It will be possible to enumerate the number of potential traders of Chinook salmon
PSC by date and season and those that did or did not participate in Chinook salmon PSC
transfers. The timing and patterns of the transfer data in comparison with the specific IPAs in
effect by date, sector, and AFA cooperative will help to assess the market for Chinook salmon
PSC in each year, and how the IPAs may have impacted that market. If there is a significant
volume of unbiased price data collected, it may be possible to address two elements of the
Council’s purpose and need statement, specifically the effects of certain incentives included in
the IPAs and the performance standard.
The CTR data may help to verify and explain some of the industry-reported information in the
contracts and agreements for allocating Chinook salmon PSC within and between AFA sectors
and cooperatives included in IPA Annual Reports and AFA Cooperative Reports. This will
assist in addressing the Council’s objective to understand the overall effects and impacts of the
Amendment 91, by permitting transactions reported in other industry-reported sources to be
compared with and reconciled with the transactions reported in the CTR.

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To help explain which incentives impose the largest costs on the pollock fleet, NMFS may
combine and compare data on initial allocation of Chinook salmon PSC and intra-sector or intracooperative apportionments of PSC with
♦ Data on the incentives from IPA plans;
♦ Data on pollock transfers from IPA Annual Reports;
♦ Distribution and amounts of pollock and Chinook salmon PSC exchanged
between vessels; and
♦ Estimated travel costs to avoid Chinook salmon PSC.
The information on the costs generated by some incentives should also help analysts describe the
impacts of the Chinook salmon PSC cap, IPAs, and performance standard.
Persistent transfers of pollock to vessels with higher Chinook salmon PSC rates may potentially
suggest that vessels with poor PSC performance have an incentive to lower their participation in
the fishery. Knowing the number of transfers by each individual vessel and amount of Chinook
salmon PSC transferred in years of low Chinook salmon encounters will also potentially provide
information concerning whether the incentives change fishing behavior at aggregate bycatch
levels below the hard cap. Additionally, observing transfers to vessels that are approaching their
individual share of the Chinook salmon PSC cap (if those share amounts are available to NMFS)
will provide information on if and how PSC transferability helps the fishery to obtain a higher
yield of pollock.
If a sufficient number of high-quality data observations is reported and the quality of the price
data is high, these data should assist in determining the distribution of Chinook salmon PSC
allocations and transfers in-season and over multiple years. This data would assist in addressing
the Council’s objective to understand the effects and impacts of the Amendment 91 IPAs, the
caps, and the performance standard. When combined with additional fields on entity affiliations
and the bundling of transactions that may be accounted for in IPA Annual Reports, the CTR
could assist in determining if prices exchanged represent independent and arms-length
transactions or if the prices are merely accounting measures within affiliated entities.
Limited information in the CTR on the prices of bundled Chinook salmon PSC transactions may
restrict the application of this data. For example, it is possible that masters of vessels or the
representatives submitting the CTR will not use unpaired or independent monetary transactions
to exchange Chinook salmon PSC. If the CTR respondents find it to be more efficient to bundle
all or nearly all Chinook salmon transactions with pollock or other items of value, very few
transactions or prices of Chinook salmon PSC transactions would be submitted. Also, if each
independent Chinook salmon PSC transfer consists of both a monetary transfer component and a
non-monetary transfer component, these observations may not be useful. The possibility exists
that these reporting constraints would result in a sufficiently low number of reported transactions
to significantly reduce the value of these data.

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The Council motion acknowledges that the data collected from the Chinook salmon EDR may
not produce definitive conclusions about the effectiveness of Amendment 91. NMFS may
undertake more rigorous, quantitative analyses to examine the effectiveness of Amendment 91 if
the collected CTR data include a sufficient number of compensated transfers. The utility of this
data could be reduced for addressing the four elements of the Council’s purpose and need
statement if poor-quality transaction data are collected in this report.
Vessel Fuel Survey
A detailed explanation of the variables and submission requirements for the Vessel Fuel Survey
is included in Part A of this supporting statement. After each calendar year, each owner of an
AFA-permitted vessel catching CDQ or non-CDQ pollock in the Bering Sea must submit to
NMFS the Vessel Fuel Survey to report annual fuel use and cost. The owner must include
identifying information on the certification page of the report, including a NMFS person ID. The
Vessel Fuel Survey, submitted by June 1 of the following year, would include average annual
hourly fuel burned while fishing and transiting, and annual fuel purchases in cost per gallon.
Each of these values would be combined with other NMFS data (such as VMS and observer data
reports) to estimate the costs of moving vessels to avoid salmon bycatch (including the fuel use
during trawling, transit between trawls, and lost fishing time).
The RIR/IRFA for this action notes that the Council specifically requested data to allow for
estimates of fuel used by a vessel when moving to areas with higher or lower areas of bycatch.
NMFS has no other data on fuel consumption or average fuel price on a vessel-by-vessel basis
for this fishery; therefore, this fuel data collection is likely to increase the quantity and quality of
information available for understanding the effects of Chinook salmon PSC measures, including
IPAs. Given the variety of circumstances in the fishery, these data should prove useful for
understanding variability of fuel usage, which can aid in assessing fuel costs more generally in
the fishery.
Data from the Vessel Fuel Survey would be used with other available data, including observer
reports, VMS data, catch accounting data, IPA Reports, and AFA Cooperative Reports. Fuel use
and fuel cost data may be combined with other data on distance traveled to avoid Chinook
salmon bycatch. The costs borne by parties for moving to lower bycatch areas can be estimated
with these data.
Analyses with fuel data may range from basis comparisons of estimated transit costs between the
types of AFA operations to quantitative or statistical estimates of the fuel costs for Chinook
salmon PSC avoidance from specific IPAs and Amendment 91.
It is possible that variation in vessel fuel costs among vessels could affect the response of
different vessels to incentives or disincentives for avoiding Chinook salmon. For example, if it
is less expensive for vessels with lower travel costs to travel farther to reach clean fishing
grounds, they may be more likely to engage in this action, all other things being equal. NMFS
may examine vessel response to Chinook salmon encounter rates to determine whether these
operational differences are affected by variations in fuel- based travel costs between vessels,

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which in turn may have implications for the effectiveness of certain types of IPAs. These
findings could be important for addressing the Council’s purpose and need statement.
Vessel Master Survey
A detailed explanation of the variables and submission requirements for the Vessel Master
Survey is included in Part A of this Supporting Statement. The Vessel Master Survey is a
qualitative assessment survey that would pose a series of questions to elicit vessel master input
on factors that impacted the vessel’s performance during the year. The Vessel Master Survey
would be conducted at the end of each fishing year. The owner of each AFA-permitted vessel
would be responsible for submitting the Vessel Master Survey to NMFS on behalf of any person
who is the master of an AFA-permitted vessel. The owner of the AFA-permitted vessel will be
required to verify that each person listed on the Certification page for this form is a master of the
AFA-permitted vessel.
The intent of the Vessel Master Survey is to identify the purpose for decision-making during the
pollock season (fishing location choices and salmon bycatch reduction measures). The survey is
designed to obtain master responses to on-the-fishing-grounds conditions to gain information
concerning the effect of IPAs and Chinook salmon measures on decision-making. The nine
questions in the Vessel Master Survey collect master assessments of the past year’s fishing
performance regarding the causes for bycatch avoidance, factors impacting Chinook salmon PSC
rates, and the influence of the IPAs and AFA cooperatives on fishing and Chinook salmon
bycatch avoidance behaviors. NMFS will use this information to guide interpretation of data on
the change in fishing revenue obtained from existing NMFS data and data in the Vessel Fuel
Survey on fuel cost and fuel consumption rates. These data will assist in evaluating the
conclusions drawn by industry in the IPA annual reports that are required to describe the impact
of IPAs on the behavior of each sector, cooperative or CDQ group. This evaluation is an
objective identified in the Council’s purpose and need statement for this action.
To initially process the data on the qualitative questions in the Vessel Master Survey, PSMFC
would correct obvious spelling and grammar. The responses would be organized into similar
answers and then would be aggregated. The range of responses for each question would be
assessed. If possible, some descriptive statistics would be developed on each answer to a given
question. The answers would be compared by sector, cooperative, vessel type, or other strata.
The common and conflicting viewpoints will be highlighted and tabulated if possible. Where
responses converge by a particular stratum of vessels or members of an AFA cooperative, these
would then be compared with other quantitative information to see if the qualitative responses
provide similar or different understanding of the quantitative data elsewhere in the Chinook
Salmon EDR.
Though the Vessel Master Survey information would involve subjective responses, it would be
useful to couple this survey with quantitative estimates of the effectiveness of the IPAs and other
measures. Where possible, NMFS will examine the effect of the behavioral influences reported
in this survey in greater detail and corroborate the responses with other data sources, such as
observer data, VMS data, and catch accounting data. This utilization of self-reported

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experiences and observable fishing behavior will ensure that analysts consider fishermen’s
experiences in formulating assessments of the Amendment 91 program, and that this data assists
in addressing the Council’s purpose and need statement.
REVISIONS TO EXISTING COLLECTIONS FOR CHINOOK SALMON EDR
NMFS would revise existing requirements for the following reports and collections. These
information sources provide some industry data for evaluating the effectiveness of the hard cap,
performance standard, IPA, and incentives in Amendment 91 for the AFA catcher/processor and
mothership sectors, inshore cooperatives, inshore open-access fishery, and CDQ groups.
♦ IPA Annual Report (OMB 0648-0401)
♦ AFA Cooperative Report (OMB 0648-0401)
♦ Catcher Vessel Trawl Gear Groundfish Daily Fishing Logbook (DFL) (OMB 0648-0213)
[see Movement Information]
♦ Catcher/processor Trawl Gear Electronic Logbook (ELB) (OMB 0648-0213) [see
Movement Information]
♦ eLandings Landing Report (OMB 0648-0515)
Revisions to the IPA Annual Report
Revisions to the IPA Annual Report required by the Chinook salmon EDR Program are
described in detail in the OMB collection 0648-0401. The IPA Annual Report would be revised
to request the sub-allocation and transfers of Chinook salmon PSC and pollock to each
participating vessel, IPA, AFA cooperative, or entity authorized to receive Chinook salmon
allocations at the start of each fishing season, and the number of Chinook salmon and amount of
pollock (mt) caught at the end of each fishing season.
Each in-season transfer of Chinook salmon and pollock would be requested by amount and date,
regardless of whether the transfers were “compensated” transfers. Intermediate transfers among
and between each AFA cooperative, IPA, or AFA sector would also be required in the IPA
reports.
This revision would provide a single location for Chinook salmon and pollock data on initial
allocation, transfer, catch, and residual allocations by season and year for each catcher vessel,
catcher/processor, or mothership participating in an IPA.
These revisions to the annual IPA Annual Report would provide additional quantitative and
qualitative information on Chinook salmon and pollock transfers for analysts to examine the
effectiveness of Amendment 91. For example, the initial allocation and transfers of pollock and
Chinook salmon may be tabulated by sector, AFA cooperative, or members of an IPA. This will
assist in comparing how transfers may differ between various entities.
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If the data are provided in a uniform and comparable manner, IPA data analysis could include
descriptive statistics on the pollock and Chinook salmon PSC, allocations, and transfers between
participants in each of the above groups. This information could be displayed with annual data
and if useful, data may be pooled over multiple years. This would assist the analysts in
comparing how transfers differ across years.
If data on transfers of Chinook salmon in IPA Annual Reports could be matched with
information on individual compensated transfers of Chinook salmon from the CTR, some
analysis of the number of transfers, average amounts transferred, and frequency of transactions
may be displayed by vessel category, AFA cooperative, and AFA sector. To improve our ability
to match information from two different sources, NMFS would revise the IPA Annual Report
and the AFA Cooperative Report to provide the NMFS ID number of each entity involved in a
transfer of pollock or Chinook salmon. The distribution of these transfers and information on the
IPA measures may provide insight into which IPA measures are most effective.
By combining data from the IPA Report with other available data, NMFS would address the
Council’s purpose and need statement to improve our understanding of:
♦ The effects and impacts of the Amendment 91 IPAs, the caps, and the performance
standard;
♦ The effectiveness of the IPA incentives and the effectiveness of the performance standard
to reduce salmon bycatch; and
♦ How Amendment 91 affects where, when, and how pollock fishing and salmon bycatch
occur.
NMFS does not require that data and discussion provided in each IPA Annual Report or AFA
cooperative report to be submitted in a specific format. Therefore, because more than one IPA
Annual Report would be received annually, performance information may not be uniformly
reported. This could create consistency issues when comparing information between IPAs and
could limit any statistical analysis with IPA data to simple descriptive statistics. Thus, there are
analytical limits to the potential usefulness of this data for statistical analysis.

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Revisions to the AFA Cooperative Report
The request for pollock and salmon PSC information would be removed from the AFA
Cooperative Report. The annual AFA cooperative report does not need to include any
information about pollock or salmon PSC allocation or catch on a vessel-by-vessel basis if that
information is provided in the IPA annual report.
Revisions to Collect Change-in-Location Data
A detailed description of the revisions for including data on the purpose of movements on the
fishing grounds is described for the catcher vessel trawl daily fishing logbook (DFL) and the
catcher/processor trawl electronic logbook (ELB) (see OMB 0648-0213) and eLandings (see
OMB 0648-0515). NMFS would require additional data to describe the reasons that a master of
an AFA vessel changed locations in the pollock fishing grounds and specifically those location
changes that may be related to Amendment 91. To accomplish this, NMFS would require each
AFA master to indicate that a specific haul was followed by a subsequent move to relocate the
vessel to a different fishing area primarily to avoid Chinook salmon bycatch whenever:
♦ The master of an AFA catcher vessel using trawl gear chooses to move the vessel to
reduce Chinook salmon PSC, the master would indicate each change in location for any haul by
checking a vessel movement box in the DFL.
♦ The master of an AFA catcher/processor using trawl gear chooses to move the vessel to
reduce Chinook salmon PSC, the master would indicate each change in location for any haul by
checking a vessel movement box in the ELB.
♦ The master of an AFA mothership receives notification that an AFA catcher vessel
delivering pollock moved the vessel to reduce Chinook salmon PSC, the master would indicate
each change in location for any haul by checking a vessel movement box in the eLandings
mothership landing report.
NMFS would use the movement information to compare salmon PSC avoidance between
individual vessels, and by various vessel characteristics. Chinook salmon PSC rates could be
merged with this information by vessel to assess how rates change prior to and following a
change in fishing location. Movement data combined with other management data (such as the
date a season is opened and closed) could be helpful in assessing a vessel’s willingness to leave
fishing grounds to avoid Chinook salmon PSC. That would help address the Council’s purpose
and need objective to “evaluate how Amendment 91 affects where, when, and how pollock
fishing and salmon bycatch occur.” These industry-reported data may be helpful in evaluating
assumptions in more sophisticated statistical models that combine catch by location, VMS, and
other data to explain the reasons for a specific set of moves and fishing choices. That
information could, in turn, assist with the Council’s purpose and need objective to “study and
evaluate conclusions drawn by industry in the IPA annual reports.”
Movement data helps us understand how the incentives from the IPA may drive the behavior of
individuals and groups. The master’s decision to relocate vessels from areas with high Chinook
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salmon PSC to areas with lower PSC rates may reflect differences in the incentives to the master
created by an IPA. Alternatively, upon examination, these data and other information provided
by cooperatives may reflect the amount of central coordination of fishing by area and time a
cooperative applies to each member of the cooperative. By combining movement data with IPA
report data on the effectiveness of incentive measures, analysts may compare the relationship
between movement events and response to IPA measures.
While these data are subjective, the data are intended to provide NMFS with a better
understanding of each vessel master’s perception of factors that impact fishing decisions, and
are likely to inform the Council objective for analyzing the effectiveness of IPAs and
Amendment 91.

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