Memo from NMFS AA to OIRA administrator

While vessels fishing in multiple broad stock areas are currently required to submit trip-level
VMS catch reports (approved under OMB Control No. 0648-0605), we determined that a daily
report will help us better ensure accurate apportionment of cod catch to the GOM and GB stock
areas, and help enforcement efforts. The daily reports will assist NOAA Office of Law
Enforcement officers and U.S. Coast Guard officials in identifying misreporting during their
compliance checks. Ultimately, this will allow us to effectively track and control mortality on
the GOM cod stock. We also expect the daily reports to promote more accurate trip declarations
and catch reporting from vessels, given that the daily VMS reporting requirement can be avoided
(meaning only the trip-level report would be required) if vessels do not intend to fish in the
GOM Broad Stock area.
Delaying implementation of the daily VMS trip reporting requirement to receive approval of this
information collection under the normal timeframe limits our ability to enforce the GOM cod
catch limits during the first few months of the fishing year. During the 2014 fishing year, GOM
cod landings reached 65 mt from May 1 to June 1. While this suggests that, if catch occurred at
a similar pace, less than a quarter of the 2015 GOM quota would be landed during this period,
there are additional circumstances, namely higher quotas for co-occurring stocks, that suggest
that landings may occur more quickly over the same period this year. The 2014 quota for GOM
haddock, which co-occurs with cod, was only 220 mt, but the quota for 2015 will be 1,375 mt.
We expect that the availability of additional haddock quota could increase the pace of catch of
GOM cod. In addition, there is anecdotal evidence of increased cod availability over the past
year from fishermen. Thus, expediting the approval of this reporting requirement is essential to
our efforts to minimize GOM cod mortality. Per the Paperwork Reduction Act regulations, 5
C.F.R. Part 1320.13, we believe that use of this emergency process is essential to the mission of
the agency, and the agency cannot reasonably comply with the normal clearance procedures
under this part because public harm is reasonably likely to result if normal clearance procedures
are followed.
We are requesting approval of this request by May 1, 2015.

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