0206 Ss 102214

SUPPORTING STATEMENT

ALASKA REGION PERMIT FAMILY OF FORMS

OMB CONTROL NO. 0648-0206

This action requests revision and extension of an existing collection of information. There have been changes made to the Federal Processor Permit application.

INTRODUCTION

Under the Magnuson-Stevens Fishery Conservation and Management Act 16 U.S.C. 1801 et seq. (Magnuson-Stevens Act), the Secretary of Commerce (Secretary) is responsible for the conservation and management of marine fishery resources within the Exclusive Economic Zone (EEZ) of the United States (U.S.) through National Oceanic and Atmospheric Administration/National Marine Fisheries Service (NOAA/NMFS). NMFS Alaska Region manages the groundfish fisheries in the EEZ of the Bering Sea and Aleutian Islands Management Area (BSAI) and Gulf of Alaska (GOA) under fishery management plans (FMPs) for groundfish in the respective areas by the North Pacific Fishery Management Council (Council). Regulations implementing the FMPs appear at 50 CFR part 679.

BACKGROUND

Section 303(b)(1) of the Magnuson-Stevens Act specifically recognizes the need for permit issuance. The requirement of a permit for marine resource users is one of the regulatory steps taken to carry out conservation and management objectives. The issuance of a permit is an essential ingredient in the management of fishery resources needed for identification of the participants and expected activity levels and for regulatory compliance (e.g., withholding of permit issuance pending collection of unpaid penalties).

The forms that make up this information collection are listed below:

Form Name	Located in Regulations at 50 CFR part . . .
Federal Fisheries Permit (FFP)	679.4(b)
Federal Processor Permit (FPP)	679.4(f)
Exempted Fisheries Permit (EFP)	679.6

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.

Participation in the groundfish fisheries of the EEZ off the coast of Alaska requires a Federal Fisheries permit (FFP) or Federal Processor permit (FPP), available upon request to any person who is a U.S. citizen. In addition, an Exempted permit is available for limited experimental purposes.

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.

The information requested on the permit applications is used for fisheries management and regulatory compliance by the U.S. Coast Guard (USCG), NMFS Sustainable Fisheries Division, NMFS Restricted Access Management Program, NMFS Observer Program, NOAA Fisheries Office for Enforcement, and the Council.

The applications may be mailed to:

NMFS, Alaska Region

Restricted Access Management (RAM) Program

P.O. Box 21668

Juneau, AK 99802

Delivered to:

Federal Building

709 W. 9th Street, Suite 713

Juneau, AK 99801

Or faxed to: 907-586-7354

a. Federal Fisheries Permit (FFP).

The Federal Fisheries Permit (FFP) is required for U.S. vessels used to fish for groundfish in the GOA and BSAI. The FFP is also required for vessels that must retain any bycatch of groundfish under 50 CFR Part 679. FFPs are non-transferable, three-year permits, issued on request and without charge to vessel owners. These permits are authorized at 50 CFR 679.4(b).

In addition, if the owner of a vessel plans to participate in the directed fisheries for Pacific cod, pollock, and/or Atka mackerel in the GOA or BSAI with any gear other than jig gear, the FFP must be endorsed for these species by gear type used. Vessels endorsed for these directed fisheries in the EEZ off Alaska are required to have onboard an active Vessel Monitoring System (VMS) (see OMB Control No. 0648-0445) while the directed fisheries for which the permit is endorsed are open, regardless of where the vessel is fishing at the time (including Alaska State waters) or what the vessel is targeting.

Only persons who are U.S. Citizens are authorized to receive or hold a Federal Fisheries Permit.

If ownership in Block A has changed or if this is a permit application for a vessel to which an FFP has never been issued, documentation of vessel ownership must be provided with this application. To demonstrate vessel ownership you must provide:

♦ For U. S. Coast Guard (USCG) documented vessels, a copy of the USCG Abstract of Title or Certificate of Documentation

♦ For undocumented vessels, a copy of the State of Alaska Department of Fish & Game (ADF&G) vessel license or registration

Federal fisheries permit (FFP) application

Indicate the type of request:

New FFP, Renew FFP, Amend FFP, or Surrender FFP

If requesting to renew, amend, or surrender an existing FFP, provide current FFP number

Block A – Owner information

Owner name and NMFS Person ID

Business mailing address, including street or P.O. box, city, state, and zip code,

indicate whether permanent or temporary

Managing company name (if any)

Business telephone number, business fax number, and business e-mail address

Block B. Vessel information

Vessel name

Home port (city and state)

ADF&G processor code (if applicable)

Indicate whether this is a vessel of the United States

USCG documentation number

ADF&G vessel registration number

Length overall (ft) and registered length (ft)

Gross tonnage and net tonnage

Shaft horsepower

Block C. Permit information

Area of operation.

Type of vessel operation.

Gear type (catcher vessel or catcher/processor only)

GOA Inshore Processing Endorsement (vessels under 125 ft length overall)

Block D. Species Endorsements and Amendments

Indicate requested species endorsements with gear other than jig gear; or

Remove species endorsement

Block E. Applicant Signature

Printed name and signature of applicant and date signed

Personnel costs per hour are changed from $25 to $37.

Federal Fisheries Permit, respondents
Total number of respondents (1603/3) 1252 catcher vessels; 151 catcher/processors 28 motherships 162 tender vessels 10 support vessels Total number of responses Response per participant = 1 Total Time burden (186.90) Time per response (21 min x 534) Total personnel costs ($37/hr x 187) Total miscellaneous costs (656.55) Submit by fax ($6 x 75 = 450) Submit by mail (.45 x 459 = 206.55)	534 534 187 hr $6,919 $657

Federal Fisheries Permit, Federal Government
Total number of responses Total time burden (222.50) Time requirement per response (25 min) Total personnel cost ($37/hr x 223) Total miscellaneous costs	534 223 hr $8,251 $0

b. Federal processor permit (FPP) application

A Federal Processor Permit (FPP) is required before the manager of a shoreside processor, stationary floating processor (SFP), or a community quota entity (CQE) floating processor may receive or process groundfish harvested in the Gulf of Alaska (GOA) or Bering Sea and Aleutian Islands Management Area (BSAI) (see 50 CFR 679.4(f)).

NOTE: For the Federal Processor Permit application to be considered complete, all fees due to NMFS per § 679.55 must be paid.

Persons holding an FPP may be required to pay an ex-vessel value-based fee to NMFS to support the funding and development of observers on vessels and in plants in the new “partial observer coverage category.” This fee is intended to be split evenly between the vessel owner/operator and the processor. However, the owner of a shoreside processor or SFP named on an FPP are responsible for collecting the fee, including the vessel’s portion, at the time of landing and remitting the full fee amount to NMFS.

An FPP permit holder who has incurred a fee liability must pay the fee to NMFS by February 15 of the year following the calendar year in which the landing was made. Full payment of the observer fee liability is required before NMFS will issue a new or renewed FPP.

For additional information on the observer fee liability please refer to the NOAA Fisheries website at: http://alaskafisheries.noaa.gov/sustainablefisheries/observers/default.htm.

FPPs are non-transferable, one-year permits, issued to owners on request and without charge. Only persons who are U.S. Citizens are authorized to receive or hold an FPP. These permits are authorized at 50 CFR 679.4(f).

A shoreside processor, SFP, or CQE floating processor that is issued an FPP under 50 CFR part 679.4(f) must use eLandings (see OMB Control No. 0648-0515) or other NMFS-approved software to daily record and report groundfish. For more information on eLandings, see http://www.alaskafisheries.noaa.gov/elandings/faq.htm#ecr.

For an SFP, a GOA inshore processing endorsement is required in order to process GOA inshore pollock and GOA inshore Pacific cod. An SFP that wishes to receive GOA inshore processing endorsements must complete No. 9 of Block B on the application. An SFP that holds an inshore processing endorsement is prohibited from processing GOA pollock and GOA Pacific cod in more than one single geographic location during a fishing year and is also prohibited from operating as a catcher/processor in the BSAI. Vessels holding the GOA inshore processing endorsement face additional operating restrictions (see 50 CFR 679.7). Once issued, a GOA inshore processing endorsement cannot be rescinded for the duration of a fishing year. It may be changed for the next fishing year by submitting an application for permit amendment prior to the beginning of that fishing year.

Federal processor permit (FPP) application

Indicate category of processor for which applying

Indicate type of request: New; Renew; Amend; Surrender

If requesting to renew, amend, or surrender an existing FPP, enter FPP number

Block A. Shoreside processor information

Name of shoreside processor

Tax identification number

NMFS Person ID

ADF&G processor code

Permanent business mailing address, including P.O. box or street, city, state, and zip code

A temporary business mailing address (if applicable)

Physical location of plant at which this shoreside processor is operating (no post office boxes)

Business telephone number, business fax number, and business e-mail address

Block B. SFP or CQE information.

Name of vessel

Indicate whether this is a vessel of the United States

Tax identification number

USCG documentation number

ADF&G vessel registration number

ADF&G processor code

Length overall (ft) and registered length (ft)

Gross tonnage and net tonnage

Shaft horsepower

Home port (city and state)

Indicate if requesting GOA Inshore Processing Endorsement

Indicate if requesting GOA CQE Floating Processor Endorsement

Block C. Owner information

List all owners of the Shoreside Processor or Vessel Identified in Block A or Block B

Name of primary owner

NMFS Person ID

Permanent business mailing address of contact owner, including street or box, city, state, and zip code

Business telephone number, business fax number, and business e-mail address

List name and NMFS Person ID of additional owners

Block D. Applicant signature

Printed name and signature of applicant and date signed

If authorized representative, attach authorization

Attachments

Attach USCG Abstract of Title or Certificate of Documentation if requesting a new FPP or if change in ownership

Several changes were made to the Federal Processor Permit application. Several questions were removed that are no longer used for any purpose. The format was changed to relieve confusion expressed by some shoreside processors about who should apply for the permit. The application was made more consistent with other applications where we ask for the name of the business or vessel and then the owners of the business or vessel. The SFP and CQE information was combined into one box, because they are both vessels but each is required to check different endorsement boxes.

The Tax Identification Number was added to both the Shoreside Processor box and SFP/CQE box. This is important to determine if this is a new business to add to our records. Also, these

processors now owe annual observer fees, which means we may need to collect a debt from them through Treasury.

Time to complete is changed from 21 minutes to 25 minutes to allow for new information. Personnel cost is changed from $25/hr to $37/hr.

Federal Processor Permit, respondents
Total number of respondents 110 shoreside processors 14 SFPs 0 CQE floating processor Total number of responses Number annual responses = 1 Total time burden (51.67) Time requirement per response = 25 min Total personnel cost ($37/hr x 52) Total miscellaneous cost Submit by fax ($6 x 24 = 144) Submit by mail (.45 x 100 = 45)	124 124 52 hr $1,924 $189

Federal Processor Permit, Federal Government
Total number responses Total time burden (51.67) Time requirement per response = 25 min Total personnel cost ($37/hr x 52 hr) Total miscellaneous cost	124 52 hr $1,924 $0

c. Exempted fisheries permit (EFP).

NMFS issues an Exempted fisheries permit (EFP) to allow groundfish fishing activities that would otherwise be prohibited under regulations for groundfish fishing. These permits are issued to support projects that could benefit the groundfish fisheries and the environment and result in gathering information not otherwise available through research or commercial fishing operations.

For limited experimental purposes, the Regional Administrator may authorize, after consulting with the Council, fishing for groundfish or fishing for Arctic fish in the Arctic Management Area in a manner that would otherwise be prohibited. No exempted fishing may be conducted unless authorized by an exempted fishing permit issued by the Regional Administrator to the participating vessel owner in accordance with the criteria and procedures.

Exempted fishing permits are issued without charge and expire at the end of a calendar year unless otherwise provided. This expiration requirement is necessary to avoid situations where information obtained from the fishing experiments might not be made available for several years, thereby denying the fishing industry information obtained from the experiment. The process takes 6 to 12 months to issue an EFP, depending on the complexity of the project and Council’s meeting schedule.

No form exists for this application; required information may be submitted in any format. The EFP applicant need not be the owner or operator of the vessel(s). The EFP design must be:

♦ Approved by the Alaska Fisheries Science Center (AFSC) before submitting an EFP application to NMFS;

♦ Presented at a Council meeting; and

♦ Must include observers, if required by the Regional Administrator, and a description of accommodations and work space for the observer(s).

For each EFP application, NMFS:

♦ may write an environmental analysis to determine the impacts of the EFP prior to awarding the permit. This analysis would support the decision making and inform the public of the EFP project.

♦ must consult with the Council. This includes filing a Federal Register notice announcing receipt of the EFP application and another notice announcing approval of the EFP application, if obtained.

♦ will disseminate EFP project information when it becomes available and all information that is obtained through its own investigations. Through the release of information from NMFS and the EFP participants, other interested parties in the fishing industry could make use of information obtained and not duplicate efforts already expended by those who initially received an EFP.

The applications and reports for existing EFPs are listed at http://alaskafisheries.noaa.gov/ram/efp.htm.

Exempted fisheries permit (EFP) application

Date of the application.

Name of applicant

Permanent mailing address and telephone number of applicant

EFP Project Information

Purpose and goal of the EFP project

Describe arrangements for disposition of all species harvested under the EFP

Procedural information about the EFP project

(e.g., sampling procedures, the data and samples to be collected, and analysis of the data and samples)

Fishing mortality anticipated.

Mortality resulting from exempted fishing is outside of any total acceptable catch specification and is authorized only if overfishing as defined in the GOA and BSAI FMPs would not occur

Amounts of each species to be harvested that are necessary to conduct the experiment

Area and timing of the experiment

Vessel and gear to be used

Details for all coordinating parties engaged in the experiment

Vessel Information

Vessel name

Name, address, and telephone number of owner and master

USCG documentation, ADF&G license, or vessel registration number

Home port

Length of vessel

Net tonnage

Gross tonnage

Signature of the applicant and signatures of all representatives of all principal parties

Exempted fishing Permit, Respondent
Estimated number of respondents Total estimated responses Number of annual responses = 1 Total time burden (4 x 20 hr) Time per response = 20 hr Total personnel cost ($37/hr x 80 hr) Total miscellaneous cost Priority Mail Postage (4.50 x 4)	4 4 80 hr $2,960 $18

Exempted fishing Permit, Federal Government

Estimated total responses Number of annual responses = 1 Total time burden Review application & resolve questions (10 hr) 4 hr at GS-12/13 5 hr at GS-14/15 1 hr at $100/hr Process application, create EA, issue EFP (33 hr) 24 hr at GS-12/13 9 hr at GS-14/15 Complete report of EFP activity (2 hr) 1 hr at GS-12/13 1 hr at GS-14/15 Total personnel cost (4 + 24 + 1 GS-12/13) x $43 = 1247 (5 + 9 + 1 GS-14/15) x $60 = 900 1 hr at $100 = 100 Total miscellaneous costs

4 45 hr $2,247 $300

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NOAA Fisheries will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy. The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology.

The FFP and FPP applications may be completed onscreen using fillable forms, downloaded, and printed from the NMFS Alaska Region website http://www.alaskafisheries.noaa.gov.

The EFP application must be signed and mailed to: Regional Administrator, Attn: Exempted Fisheries Permits, P.O. Box 21668, Juneau, AK 99802

4. Describe efforts to identify duplication.

No duplication exists with other information collections.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

None of the respondents qualify as small businesses.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

The permit system is an integral part of the management of groundfish fisheries in the Alaska Region. It would not be possible to carry out the mandates of the Magnuson-Stevens Act and other laws if approval to continue these previously approved collections were to be denied.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

No special circumstances exist.

8. Provide a copy of 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.

Public comment was solicited in a Federal Register Notice (79 FR 29741) published May 23, 2014. No comments were received.

A questionnaire was prepared and transmitted by email to 21 randomly selected permit holders; three were returned because of incorrect address. Two responses were received. A summary of the comments received is provided below. The survey form is appended.

Federal Fisheries Permit
Number of respondents who have this permit:	1	Yes	No	No Comment
Information is easily available to complete the application		1
Prefer to have application online		1
21 minutes is adequate to collect and record information		1
Less than $10 to submit application is adequate		1
Instructions are clear and understandable		1
Renewing FFP every three years is necessary		1
Comments

Federal Processor Permit
Number of respondents who have this permit:	2	Yes	No	No Comment
Information is easily available to complete the application		2
Prefer to have application online		1	1
25 minutes is adequate to collect and record information		1		1
Less than $10 to submit application is adequate		2
Instructions are clear and understandable		2
Renewing FPP every year is necessary		1	1
Comments from 1 respondent I prefer to fax I believe there is no cost for this (absorbed by business) Renew every five years – this information hasn’t changed. Response: we need more frequent renewal due to changes in contact information.

Exempted Fisheries Permit
Number of respondents who have this permit:	0	Yes	No	No Comment
Information is easily available to complete the application
Prefer to have application online
24 hours is adequate to collect and record information
Less than $5 to submit application is adequate
Instructions are clear and understandable
Comments

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payment or gift is provided.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

The information collected is confidential under section 402(b) of the Magnuson-Stevens Act

(16 U.S.C. 1801 et seq.); and also under NOAA Administrative Order (AO) 216-100, which sets forth procedures to protect confidentiality of fishery statistics.

All information collected is part of a system of records: NOAA #19, Permits and Registrations for United States Federally Regulated Fisheries.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

This information collection does not involve information of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.

Estimated total respondents: 662. Estimated total responses: 662. Estimated total burden: 319, up from 310 hr. Estimated total personnel cost: $11,803 up from $7,750.

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).

Estimated total miscellaneous cost: $864.

14. Provide estimates of annualized cost to the Federal government.

Estimated number of responses: 662. Estimated total burden: 293, down from 320 hr. Estimated total personnel cost: $12,422, up from $9,122. Total miscellaneous costs: $300.

15. Explain the reasons for any program changes or adjustments.

Program Change:

Changes were made to the Federal Processor Permit application: removed several questions, changed format, combined SFP and CQE sections, added Tax Identification Number to both the Shoreside Processor and SFP/CQE, changed time to complete from 21 minutes to 25 minutes.

Federal processor permit application

an increase of 9 hr burden, 52 hr instead of 43 hr

Adjustments are made in this collection: Personnel costs are changed from $25/hr to $37/hr.

Federal fisheries permit application

an increase of $2,244 personnel costs, $6,919 instead of $4,675

Federal processor permit application

an increase of $849 personnel costs, $1,924 instead of $1,075

Exempted fishery permit application

an increase of $960 personnel costs, $2,960 instead of $2,000

In the last request under this OMB Control No., a change request related to 0648-AX78, there were net decreases to responses (95), hours (6) and costs ($88). Due to an error of omission, these changes were not actually changed in ROCIS. Thus, all adjustments other than personnel costs are actually corrections to what should have been the new current numbers.

16. For collections whose results will be published, outline the plans for tabulation and publication.

The information obtained from the applications for FFPs and FPPs are not expected to be published for statistical use. Applications, comments on the applications, and final reports resulting from issuance of EFPs are available to the public on the Alaska Region website at http://alaskafisheries.noaa.gov/ram/efp.htm.

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.

In accordance with OMB requirements, the control number and expiration date of OMB approval are shown on the FFP and FPP applications. The EFP application does not have a form; required information may be submitted in any format.

18. Explain each exception to the certification statement.

In accordance with OMB requirements, the certification statement will be shown on the FFP and FPP applications. The EFP application does not have a form; required information may be submitted in any format.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

Appendix

SURVEY

ALASKA REGION PERMIT FAMILY OF FORMS

OMB CONTROL NO. 0648-0206

The Office of Management and Burden (OMB) requires each Federal agency to ask for comments from non-agency persons who are required to comply with recordkeeping and reporting requirements for that agency. To satisfy the Paperwork Reduction Act requirements of the OMB, National Marine Fisheries Service (NMFS) Alaska Region is seeking your help to review the information collection, Alaska Region Permit Family of Forms, OMB Control Number 0648-0206.

Participation in the groundfish fisheries of the Exclusive Economic Zone off the coast of Alaska requires a Federal Fisheries permit (FFP) or Federal Processor permit (FPP), available upon request to any person who is a U.S. citizen. In addition, an Exempted Fisheries permit (EFP) is available for limited experimental purposes.

Please look over the survey attached. For each permit application listed, please make a check mark to indicate your answer.

♦ If a permit application does not apply to you, please check N/A, and go to the next form.

♦ If you do have a certain permit, check YES.

And, let us know why you answered YES or NO to each question.

Please e-mail your responses to Patsy A. Bearden at [email protected]

by September 19, 2014.

If you have any questions or need more information, call me at 907-586-7008.

Thanks in advance.

Respectfully,

Patsy A. Bearden

Sustainable Fisheries Division

NMFS Alaska Region

FEDERAL FISHERIES PERMIT (FFP) view at http://alaskafisheries.noaa.gov/ram/ffpapp.pdf
[__] YES, I have this permit [__] Not applicable GO TO THE NEXT FORM.
1. Do you have the information easily available to complete the FFP application?	[__] YES
If NO, tell us what you need to do to complete this form.	[__] NO
	[__] NO COMMENT
2. Would you prefer to file this application online?	[__] YES [__] NO [__] NO COMMENT
If NO, tell us your preferred method – U.S. mail, fax, courier, other method?
3. Is our estimate of 21 minutes long enough for you to collect and record the information?	[__] YES [__] NO [__] NO COMMENT
IF NO, how long does it take? Why does it take this much time?
4. Is our estimate of less than $10 per application accurate?	[__] YES [__] NO [__] NO COMMENT
IF NO, what is your FFP submittal cost?
5. Are the instructions for the application clear and understandable?	[__] YES
If NO, which question(s) is not clear? and why?	[__] NO
	[__] NO COMMENT
6. Do you think that renewing the FFP every three years is necessary?	[__] YES [__] NO [__] NO COMMENT
If NO, tell us what renewal cycle you would prefer.
7. Provide any additional comments on any aspect of the FFP application	[__] NO COMMENT
COMMENTS:

FEDERAL PROCESSOR PERMIT (FPP) view at http://alaskafisheries.noaa.gov/ram/fppapp.pdf
[__] YES, I have this permit [__] Not applicable GO TO THE NEXT FORM.
1. Do you have the information easily available to complete the FPP application?	[__] YES
If NO, tell us what you need to do to complete this form.	[__] NO
	[__] NO COMMENT
2. Would you prefer to file this application online?	[__] YES [__] NO [__] NO COMMENT
If NO, tell us your preferred method – U.S. mail, fax, courier, other method?
3. Is our estimate of 25 minutes long enough for you to collect and record the information?	[__] YES [__] NO [__] NO COMMENT
IF NO, how long does it take? Why does it take this much time?
4. Is our estimate of less than $10 per application accurate?	[__] YES [__] NO [__] NO COMMENT
IF NO, what is your FPP submittal cost?
5. Are the instructions for the application clear and understandable?	[__] YES
If NO, which question(s) is not clear? and why?	[__] NO
	[__] NO COMMENT
6. Do you think that renewing the FPP every year is necessary?	[__] YES [__] NO [__] NO COMMENT
If NO, tell us what renewal cycle you would prefer.
7. Provide any additional comments on any aspect of the FPP application	[__] NO COMMENT
COMMENTS:

EXEMPTED FISHERIES PERMIT (EFP) view at http://alaskafisheries.noaa.gov/ram/efp.htm
[__] YES, I have this permit [__] Not applicable GO TO THE NEXT FORM.
1. Do you have the information easily available to submit the EFP application?	[__] YES
If NO, tell us what you need to do to complete this application.	[__] NO
	[__] NO COMMENT
2. Would you prefer to file this application online?	[__] YES [__] NO [__] NO COMMENT
If NO, tell us your preferred method – U.S. mail, fax, courier, other method?
3. Is our estimate of 20 hours long enough for you to collect and record the information?	[__] YES [__] NO [__] NO COMMENT
IF NO, how long does it take? Why does it take this much time?
4. Is our estimate of less than $5 per application accurate?	[__] YES [__] NO [__] NO COMMENT
IF NO, what is your EFP submittal cost?
5. Are the instructions for completion of the application clear and understandable?	[__] YES
If NO, which question(s) is not clear? and why?	[__] NO
	[__] NO COMMENT
6. Provide any additional comments on any aspect of the EFP application	[__] NO COMMENT
COMMENTS:

20