SUPPORTING STATEMENT
PROCESSED PRODUCTS FAMILY OF FORMS
OMB CONTROL NO. 0648-0018
A. JUSTIFICATION
This request is for extension of a current information collection.
1. Explain the circumstances that make the collection of information necessary.
NOAA Forms 88-13 and 88-13c are used to collect annual (in the case of 88-13) and monthly (in the case of 88-13c) information on seafood and industrial fishery processing plants. These data are required by the Secretary of Commerce in carrying out provisions of the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq. as amended). Each Fishery Management Plan (FMP) established under the Act must determine the estimated capacity by United States (U.S.) seafood processors for the managed fishery. Data from this survey are used in economic analyses to estimate the capacity and extent to which U.S. fish processors, on an annual basis, will process that portion of the optimum yield harvested by domestic fishing vessels. Employment data are used in socioeconomic analyses for determining potential impacts on processing employment, due in part to management measures.
Federally permitted dealers of Atlantic mackerel, squid, butterfish, Atlantic sea scallop, Northeast multispecies, monkfish, summer flounder, scup, black sea bass, Atlantic bluefish, spiny dogfish, Atlantic herring, Atlantic hagfish, Atlantic deep-sea red crab, tilefish, skate, surf clam or ocean quahog in the National Marine Fisheries Service’s (NMFS) Northeast Region are required under 50 CFR 648.7 to complete and submit all sections of NOAA Form 88-13.
NOAA Form 88-13c is used to collect monthly production of fish meal and oil. These data are needed by the Department of Commerce to report market and supply conditions and are used by the industry to procure sufficient inputs to produce such products as animal feeds, paint, lubricants and fertilizers (13 U.S.C. 61 et seq.).
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.
NMFS and Regional Council economists use the collected information to estimate processing capacity and to forecast and subsequently measure the economic impact of fishery management regulations on fish and shellfish supplies using the data on volume and value. The employment data are used to analyze the seasonality of a specific fishery. The data are also used for establishing negotiating positions on international trade by determining which seafood industries might be adversely affected by reducing or eliminating established tariffs.
Data from the annual survey are reported in Fisheries of the United States (NMFS), Statistical Abstract of the United States (Census Bureau) and Agricultural Statistics (U.S Department of Agriculture (USDA)). As a member of the United Nations Food and Agriculture Organization and the Organization for Economic Cooperation and Development, NMFS supplies aggregate data to these organizations.
In addition to the aforementioned publications, the information collected through the 88-13 family of forms supports activities of other federal agencies. NMFS supports the International Trade Commission (ITC) with their various trade investigations by supplying aggregate data on specific processed seafood items. The Office of Management and Budget (OMB) annually requests information on the processing of seafood. The U.S. Customs and Border Protection (CBP), Department of Homeland Security (DHS), establishes the annual tariff-rate quota for tuna fish described in item 1604.14.22 of the Harmonized Tariff Schedule of the United States based on the U.S. canned tuna production for the preceding calendar year (19 U.S.C. 3007). Failure to collect these data would prevent the Secretary of Commerce from meeting the statutory obligations under the Act. It would also prevent the CBP from establishing the annual tariff-rate quota on canned tuna.
It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NMFS 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 Question10 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.
In the current Survey of Fishery Processors (Form 88-13), NMFS provides each processor a unique pre-printed form that includes the products produced by the processor in the previous year. The processor only needs to fill in the quantities and value, and add any new products, before returning the form. Only processors who produce fish meal and fish oil receive and complete the monthly 88-13c form, which is mailed to those processors monthly during the fishing season. We have started to explore the development of electronic-based reporting tools, but our initial discussions with processors have revealed little interest.
4. Describe efforts to identify duplication.
NMFS continues to work with Bureau of the Census to reduce duplication and unnecessary reporting. Although the Census includes the seafood industry in its five-year descriptive surveys, the level of detail is more aggregated than NMFS data and represents a survey of capital investment and value-added. These data are not part of NMFS effort.
The Bureau of Labor Statistics (BLS) collects monthly employment data at the six digit North American Industry Classification System (NAICS) code level. Although these data are used to verify NMFS-collected data, the information provided by the BLS is too aggregated to utilize at the species specific level and can only be used for general comparisons.
The Operational Guidelines on the Fishery Management Plan (FMP) Process require each FMP to evaluate existing state and Federal laws that govern the fisheries in question, and the findings are made part of each FMP. Therefore, NMFS is confident that it is aware of similar collections if they exist.
With the onset of Catch Share Programs, the Office of Science and Technology has been working with port agents in the regional offices to ensure that overlap and duplication of surveys is kept at a minimum. In the case of Catch Share monitoring programs, the data collected are not in the same scope as the data collected in the 88-13 and very little, if any, overlap occurs.
5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
Since all of the respondents are considered small businesses, separate requirements based on size of business have not been developed. Only the minimum data are requested.
6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.
If the collection were not conducted, NMFS would lack key economic data for making fishery decisions. The frequency cannot be reduced from the annual submission, which is currently required for dealers, with the 88-13 form. Since dealer entry into and exit from a fishery is common, an annual collection allows NMFS to use the most accurate information available to compile employment and processing data.
Various federal and state government, industry and academic entities use the quarterly meal and oil reports made available on the NMFS Office of Science and Technology Commercial Fisheries Market News website. Quarterly reports would not be possible without the monthly reporting requirement of the 88-13c.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
Form 88-13c obtains monthly data on processed production of fish meal, oil and solubles for reporting in the Fishery Market News series. NMFS, USDA, state fishery agencies and industry in forecasting market needs utilize these data. Forms are mailed to respondents on a monthly basis during the fishing season. The seasonality (four-five months) of the fisheries supporting the processing of meal and oil precludes reducing the reporting time frame to less than monthly. Companies reduce employment at season closure to primary maintenance needs. If the reporting time frame was reduced to quarterly submission, a loss of data for the season would jeopardize the statistics.
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 published on April 12, 2013 (Vol. 78 No. 71 pp. 21912-21913) solicited public comments on this information collection. No comments were received.
Direct feedback from respondents is the primary source for changes in the survey form. Input from regional port agents is also considered.
We engage extensively with the processors who are in our survey. Our port agents are usually known by the processors and they often interact in various ways, including dropping off duplicate forms to the processor, making calls requesting submission of data, and, in many cases, actually filling in the form at the side of the processor. These port agents report to our office any complaints received about the survey. We seldom get any comments regarding the reporting burden. We do occasionally receive comments from new companies who have not implemented sufficient record keeping procedures necessary to provide the requested information. In these cases we ask the company to provide their best estimate of the fishery products that they process with the hope that they will improve their record keeping for subsequent reporting years. Finally, in the cover letter accompanying the survey form, processors are directed to contact the Office of Science of Technology with any questions or comments about the form and the survey. A great majority of the questions we receive involve the definition of a processor – i.e. companies want to know if they should be completing the survey at all due to the wide variety of processing practices in the industry.
In order to make the instructions for completing the survey form more straightforward, we have introduced and distributed an example data sheet (attached as Instruction Letter Example.docx) that demonstrates how to complete the form.
Specific comments received on 88-13, the annual survey:
Judith Woodard at Olympia Oysters: It takes no longer than 30 minutes to fill out the form
Quang Nguyen at H&N Foods International: It takes 30 minutes or a little longer depending on what information they have to pull up.
Cynthia Bell at Galveston Shrimp Company: Not as bad as some other government forms. It takes her about 30 minutes.
Britney Underwood at Jeri’s Seafood said it takes her 20-30 minutes to do the report.
Lisa Halili at Prestige Oysters: She has the data on her computer so it takes 1-2 hours depending on how many interruptions she has.
It should be expected that it will take longer for a company with many products to report their production. Also, good record keeping is necessary for the reporting. The information we ask is very basic business information which should reasonably be expected to be part of what the companies keep track of to assess their own business costs, profitability, and tax burden.
9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts are made.
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 data contained in the Processed Products Report, Form 88-13 and Form 88-13c, will be kept confidential as required by section 402(b) of the Magnuson-Stevens Act and NOAA Administrative Order 216-100, Confidentiality of Fisheries Statistics, and will not be released for public use except in aggregate statistical form without identification as to its source. Any NMFS employee or contractor is required to sign and abide by the NOAA Administrative Order 216-100 Non-Disclosure Form before able to work with, or access, non-aggregated data.
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.
There are no questions of a sensitive nature.
12. Provide an estimate in hours of the burden of the collection of information.
Table 1. Calculation of Public and Federal Estimate of Reporting Burden Hours and Costs.
Permit Requirement |
Number of Entities |
Items/ Entity |
Total Number of Items |
Response Time (Hours) |
Total Burden (Hours) |
Cost ($) to Public |
NOAA Form 88-13 |
855 |
1 |
855 |
30 minutes |
428 |
0 |
NOAA Form 88-13c |
9 |
12 |
108 |
15 minutes |
27 |
0 |
Totals |
855* |
|
963 |
|
455 |
0 |
* Excludes duplication
13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).
There are no start-up, capital, or maintenance costs associated with this collection. No new or specialized equipment is needed to respond to this collection. The forms are provided with postage-paid envelopes.
14. Provide estimates of annualized cost to the Federal government.
The estimated Cost to Government is $5,315
Estimated Cost of Printing: 963 forms at 5 cents per copy = $48
Estimated Cost of Mailing: 963 forms at 85 cents total = $819
Estimated Staff Support: 220 hours at GS 7/1 salary ($20.22/hour) = $4,448
15. Explain the reasons for any program changes or adjustments.
Adjustment: The number of burden hours is reduced from the previous submission due to consolidation in the seafood processing industry; that is, there are fewer companies processing. This calculation of burden was based on the number of forms sent for the 2012 data year as shown above.
16. For collections whose results will be published, outline the plans for tabulation and publication.
Results from this collection may be used in scientific, management, technical or general informational publications such as Fisheries of the United States, which follows prescribed statistical tabulations and summary table formats. Data are available to the general public on request in summary form only; data are available to NMFS employees in detailed form on a need-to-know basis only.
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.
There are no exceptions.
| File Type | application/msword |
| File Modified | 2013-08-12 |
| File Created | 2013-07-22 |