Justification for change

JUSTIFICATION FOR CHANGE

NORTHEAST MULTISPECIES AMENDMENT 16

OMB CONTROL NO. 0648-0605

Changes to trip start and trip-end hails and catch reports

Trip Start and End Hails

Submission of trip start and trip end hails was first required in Amendment 16 to the Northeast Multispecies Fishery Management Plan. Hails were developed to facilitate the deployment of dockside monitors to vessels selected for coverage and to inform the sector managers and National Marine Fisheries Service (NMFS) Office of Law Enforcement (OLE) when vessels would be landing. The dockside monitoring program assists with the monitoring and validation of landings and discards as an input to monitoring the utilization of annual catch entitlements (ACEs). Hails, among many other requirements, were approved for collection under OMB Control No. 0648-0605. NMFS is requesting a change to this information collection, to remove the vessel permit number, but, to add questions for fishermen to indicate: 1) their vessel operator number, 2) whether they would be fishing using under an exemption (i.e., redfish trip, closed area trip), 3) whether they would be fishing under a sector provision (i.e., fishing exclusively in the Gulf of Maine (GOM) or offshore, fishing with no ACE).

Members of the fishing industry involved in the Northeast (NE) Multispecies sector management program have collaborated on a proposal to voluntarily collect additional area specific information. Industry’s intent is to better track sector vessels’ activity in the inshore and offshore portions of the GOM Broad Stock Area. In an effort to accommodate industry’s request, NMFS would like to amend the current “Trip Start Hail” to include a line for vessels to indicate whether they plan to fish the inshore or offshore portion of GOM. In addition, under sector management, specific sectors have been given provisions that allow them to fish in particular areas for specific stocks of fish, even if they have run out of ACE of pre-determined stocks of NE multispecies, provided they meet certain requirements. In order to accommodate this request, NMFS would like to amend the current “Trip Start Hail” to include a line for vessels to indicate whether they plan to fish “with no ACE”.

Similarly, at the request of industry, NMFS has developed two exemptions that require additional monitoring and enforcement, trips targeting redfish with smaller mesh and trips fishing in closed areas. Currently, there is no standardized, automated method for fishermen to report that they are targeting a specific stock or to report that they intend to fish in a closed area. Requiring fishermen to describe a target stock or a type of trip in the Trip Start will clarify a fishermen’s intent, improve compliance, make enforcement easier, and streamline catch monitoring and accounting efforts.

Single check box fields will be added for vessels to declare the use of a sector provision or a sector exemption. Requesting this additional information in the trip start is an ideal method for vessels to indicate, for example, where they are fishing (i.e., inshore or offshore GOM), if they intend to target a particular stock, or if they intend to fish in closed area. It would also help improve NMFS ability to identify trip information, rather than relying solely on gear and catch.

The trip start hail would take an estimated two minutes to complete and would affect approximately 1,482 entities annually, which is the total number of limited access NE multispecies permit holders. It is estimated that NE multispecies permit holders will continue to make a total of 25,000 trips next year, issuing one trip start hail per trip, for a total of 25,000 hails. The additional questions are not anticipated to require additional response time. Therefore, the total estimated time burden for all vessels continues to be 833.33 (833) hours (2 min/hail x 25,000 trip start hails). This is not anticipated to change.

This request would remove the vessel permit number field, add a field to submit the vessel operator number, and add six fields to the trip start hail. The most expensive VMS provider currently charges $0.04 per character plus $0.50 per email transmission. The maximum cost per trip start hail will increase from $0.884 to a maximum cost of $0.956 per hail. This results in a total cost to the public of $23,900 ($0.956/hail x 25,000 hails). This represents an increase of $1,800 in costs to the public for improved trip start hails, or an average of $1.21 per entity per year.

Trip end hails notify the law enforcement of the intent to land a trip and schedule the monitoring of an offload.  This hail can be done through VMS or by phone and is estimated to take 15 minutes to complete. It is estimated that NE multispecies permit holders will continue to make a total of 25,000 trips next year, issuing one trip-end hail per trip, for a total of 25,000 trip-end hails, plus continuing to make an estimated 2,500 correction hails.  This request would remove the vessel permit number field, but add a field to submit the vessel operator number to the trip end hail. The additional question is not anticipated to require additional response time. Therefore, the total estimated time burden to the public for complying with this requirement continues to be 6,875 hours.

For the purpose of estimating cost burden, it was assumed that all entities would make the trip-end hail via VMS, as opposed to by radio or phone.  The most expensive VMS provider currently charges $0.004 per character plus $0.5 per email transmission, for a total cost per hail of $1.024. Making the adjustments on the trip start hail will increase the price from $1.024 to $1.104 per trip end hail. Assuming 27,500 items, at one hail per trip (including 2,500 correction hails), the total cost to the public of fulfilling this requirement would increase by $2,200: from $28,160 to $30,360 ($1.104/hail x 27,500 hails), or an average of $1.48 per entity per year.

See table below for cost changes.

	# of Entities	Items per Entity	Total # of Items	Response Time (hours)	Total Burden (hours)	Public Expense (dollars)	Govt.
Current Trip start hail	1,482	17	25,000	2 minutes	833	22,100	0
New Trip start hail	1,482	17	25,000	2 minutes	833	23,900	0
Original Trip End Hail	1,482	17	27,500	15 minutes	6,875	28,160	0
New Trip End Hail	1,482	17	27,500	15 minutes	6,875	30,360	0

Multispecies Catch Report

Operators of all vessels issued a limited access NE multispecies permit that are fishing for groundfish under a NE multispecies DAS or on a sector trip, are required to submit a trip-level catch report when fishing in a single broad stock area. They must submit the VTR serial number associated with the first page of the VTR for that trip, as instructed by the Regional Administrator. The VTR serial number is used to link VTRs with dealer reports and VMS data to increase the accuracy of data used for monitoring catch. When a vessel fishes in more than one broad stock area, the vessel operator must specify the VTR serial number, the date fish were caught (applicable only for special management program (SMP) trips), and the amount of each species kept in each broad stock reporting area. Catch reports, including VTR serial numbers, are used to increase the accurate of data used in the monitoring of catch.

When vessels fish in more than one statistical area as a product of fishing in more than one broad stock area, the current catch report allows the vessel only a single field to submit statistical area, yet allows for submitting catch from multiple broad stock areas. Additionally, NMFS requires daily VMS catch reports for SMPs that reflect the requirements outlined in the trip-level catch reports described above. Vessel operators fishing in SMPs are required to specify the VTR serial number or other universal trip ID specified by NMFS, the date fish were caught (applicable only for SMP trips), and the amount of each species kept in each broad stock reporting area. Catch reports, including VTR serial numbers, are used to increase the accurate of data used in the monitoring of catch.

This request would add three additional statistical area fields in addition to the current statistical area field. The four statistical area fields would allow for a vessel to submit catch at the statistical area level, and NMFS would determine from the statistical area reported, what broad stock area the catch is from. Hence, the four statistical areas in total would replace the four broad stock area column headers on the catch report, which were fixed characters on the report and not available for user input. In addition to this change, there was only a single field for a vessel to submit “all fish kept” on the trip. Therefore, this request would remove that field and create four separate fields for the vessel to submit “non-groundfish”, one field for each of the four statistical areas. Because we are not changing the “groundfish” fields, altogether, the vessel would submit “groundfish” and “non-groundfish” by statistical area, and NMFS would sum the fields to calculate “all fish kept”. Lastly, similar to the trip start hail and trip end hail, this request would add a field to allow for the submission of the vessel operator number.

Groundfish vessels make approximately 2,500 trips into multiple broad stock areas and would be expected to make no more than this number into multiple broad reporting areas in the coming fishing years. Currently, it is estimated that it takes approximately 15 minutes to complete a catch report via VMS, and this request does not change that estimate.

Changes in costs:

• All vessels that declare the intent to fish in two or more of the broad reporting areas will be required to submit a report via VMS at the conclusion of the trip that details the amount of fish the vessel kept. The catch report would include the operator number (8 characters), VTR serial number (14 characters), date (8 characters), statistical area fished (4 areas x 3 characters each = 12 character), kept catch of each groundfish stock (13 species x 4 stock areas x 6 characters each = 312 characters), kept catch of non-groundfish (4 areas x 6 characters = 24 characters, and commas separating the fields (62 characters), for a total of 432 characters per report. At a cost of $0.004 per character plus $0.50 per submission, each catch report would cost $2.228. Therefore, the total cost to the public of complying with this requirement is estimated to be $2,451 ($2.228/report x 1,100 reports), this represents an increase of $167 in costs to the public (an increase of $1.59 per entity).

• The SAP catch reports will include the same data fields as the broad reporting area catch reports, and will have the same transmission cost of $2.228 per report. Therefore, the total cost to the public of vessels participating in the U.S./Canada Management Area and associated SAPs is estimated to be $31,192 ($2.228/report x 14,000 reports), this represents an increase of $2,128 in costs to the public (an annual increase of $5.32 per entity).

• The total cost to the public of vessels participating in the Closed Area I Hook Gear Haddock SAP is estimated to be $4,746 ($2.228/report x 2,130 reports), this represents an increase of $324 to the public (an annual increase of $2.28 per entity).

• The total cost associated with vessels participating in the Regular B Program is estimated to be $11,140 ($2.228/report x 5,000 reports), this represents an increase of $760 to the public (an annual increase of $0.76 per entity).

See table below for updated costs.

	# of Entities	Items per Entity	Total # of Items	Response Time (hrs)	Total Burden (hrs)	Public Expense (dollars)	Govt.
Current Broad Stock Area Catch Report	105	10	1,100	.25	275	2,284	n/a
New Broad Stock Area Catch Report	105	10	1,100	.25	275	2,451	n/a
Current U.S/Canada Area and SAPs	400	35	14000	.25	3500	29,064	n/a
New U.S/Canada Area and SAPs	400	35	14000	.25	3500	31,192	n/a
Current Closed Area I SAP	142	15	2,130	.25	533	4,422	n/a
New Closed Area I SAP	142	15	2,130	.25	533	4,746	n/a
Current Regular B Program	997	5	4,985	.25	1246	10,380	n/a
New Regular B Program	997	5	4,985	.25	1246	11,140	n/a

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