0648-0194 SupportingStatement Part A

SUPPORTING STATEMENT

ANTARCTIC MARINE LIVING RESOURCE REGULATIONS

OMB CONTROL NO. 0648-0194

A. JUSTIFICATION

This request is for extension of a current information collection.

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

The 1982 Convention on the Conservation of Antarctic Marine Living Resources established the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR) for the purpose of protecting and conserving the marine living resources in the waters surrounding Antarctica. The Convention is based upon an ecosystem approach to the conservation of marine living resources and incorporates standards designed to ensure the conservation of individual populations and species and the Antarctic marine ecosystem as a whole.

The United States (U.S.) is a contracting party to the Convention and a member of CCAMLR and the Scientific Committee established by the Commission.

On November 8, 1984, the President signed Public Law 98-623, the Antarctic Marine Living Resources Convention Act (the Act). The Act directs and authorizes the United States to take actions necessary to meet its treaty obligations as a contracting party to the Convention.

The burden associated with this information collection has been updated to reflect changes in costs.

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 reporting requirements included in this collection concern CCAMLR Ecosystem Monitoring Program (CEMP) activities, scientific research in the CAMLR Convention Area, U.S. harvesting permit applicants and/or harvesting vessel operators, and U.S. importers and re-exporters of AMLR.

U.S. regulations require U.S. individuals engaged in AMLR harvesting, transshipping, and importing or entering and/or conducting activities in a CEMP site to apply for and hold a permit for such activities. Individuals involved in certain scientific research in the CAMLR Convention Area are required to report information.

The regulations comply with and give effect to the Convention. Members of the Convention are required to provide, in the manner and at such intervals as may be prescribed, information about harvesting activities, including fishing areas and vessels, so as to enable reliable catch and effort statistics to be compiled.

Members agree in Article XX of the Convention to take advantage of opportunities to assess the impact of harvesting. Members are also required to provide information to the Commission on steps to be taken to implement the conservation measures adopted by the Commission. Article XXI requires the Contracting Parties to take appropriate action to ensure compliance with the Convention and with the conservation measures adopted by the Commission. Each Contracting Party is required to transmit to the Commission information on these actions, including the imposition of sanctions for any violation.

The Department of Commerce (DOC) has reviewed the Convention and the conservation measures adopted by the Commission and concluded that a permit system is the most effective way to monitor Antarctic resources, provide treaty data to the Commission, meet international obligations, and ensure compliance, without unduly burdening harvesting and importing activities.

U.S. regulations govern the harvest and importation into the United States of any AMLR, part or product, by any person subject to the jurisdiction of the United States, including U.S. citizens and those wishing to import into the United States.

Under the Antarctic Conservation Act of 1978, the National Science Foundation (NSF) has permitting authority for collection of native birds and mammals and certain plants south of 60 degrees South latitude. To minimize the public paperwork burden, regulations set forth at 50 CFR 300 Subpart G exempt an Antarctic harvester or importer holding a permit or an award (as evidenced by an award letter) from NSF or an endangered species or marine mammal permit from the National Marine Fisheries Service (NMFS), from the need to obtain a separate AMLR permit from NMFS. Although a NMFS AMLR permit is not required of NSF permit or award holders, they must comply with both preexisting data requirements related to the NSF or NMFS permit or award and CCAMLR data requirements.

I. CEMP Entry Permits

AMLR regulations require that persons proposing to enter or conduct research in a CEMP site submit an application for an entry permit. If issued a permit, the holder must abide by all the conditions in the permit, including submission of an annual report describing the activities conducted and any actions not in compliance with the site's management plan. These permits are valid for 5 years. In the event that a CEMP site is also listed as a specially protected site under the Antarctic Conservation Act of 1978, applicants are redirected to the National Science Foundation to submit an application for a dual permit. Although one permit will serve both purposes, annual reporting is directed to each agency individually for areas within the agency's expertise.

II. Harvest or Transshipment

A. New and exploratory fisheries

The United States issued a Convention Area-harvesting permit to a single U.S. fisherman for a new crab fishery in 1991. When informed of the permit, CCAMLR expressed its strong and collective concern that, although the United States had required the permit holder to submit a Research and Data Collection Plan as a part of his application, the fishery had been authorized without prior knowledge of the demographic characteristics of the species.

The Commission agreed that it was particularly important for members to fulfill their treaty obligation to provide statistical, biological, and other information and, as a consequence, adopted conservation measures for new and exploratory fisheries.

1. New fisheries

The Commission adopted a measure which requires Members to notify the Commission when it is considering initiating a new fishery in the Convention Area. The Commission must receive the notification not less than 3 months in advance of the next regular meeting of the Commission. The Member may not initiate the new fishery pending Commission review. The notification to the Commission must be accompanied by as much of the following information as the Member is able to provide:

• The nature of the proposed fishery including target species, methods of fishing, proposed region and maximum catches levels proposed for the forthcoming season;

• Biological information on the target species from comprehensive research/survey cruises, such as distribution, abundance, demographic data and information on stock identity;

• Details of dependent and related species and the likelihood of them being affected by the proposed fishery;

• Information from other fisheries in the region or similar fisheries elsewhere that may assist in the evaluation of potential yield;

• If the proposed fishery will be undertaken using bottom trawl gear, information on the known and anticipated impacts of this gear on vulnerable marine ecosystems, including benthos and benthic communities.

Information on proposed new fisheries is considered by the Scientific Committee, which then advises the Commission. After Commission review, the Commission takes action, as it deems necessary.

2. Exploratory fisheries

The Commission adopted a measure on exploratory fisheries. An exploratory fishery is one that has previously been classified as a new fishery and reviewed by the Scientific Committee and Commission prior to its initiation.

An exploratory fishery continues to be classified as an exploratory fishery until sufficient information is available to evaluate the fishery's potential yield, review its potential impacts on dependent and related species, and allow the Scientific Committee to formulate and provide advice to the Commission on appropriate harvest catch levels, effort levels, and fishing gear.

To ensure that adequate information is available to the Scientific Committee for evaluation during the period when a fishery is classified as exploratory, the Scientific Committee develops and annually updates a Data Collection Plan. Each Member active in the fishery annually submits to CCAMLR the data specified by the Data Collection Plan. Fishing capacity and effort is limited by a precautionary catch limit at a level not substantially above that necessary to obtain the data specified in the Data Collection Plan.

The Data Collection Plan includes, as appropriate:

• A description of the catch, effort, and related biological, ecological, and environmental data required undertaking an evaluation of the fishery;

• A plan for directing fishing effort during the exploratory phase to permit the acquisition of relevant data to evaluate the fishery potential and the ecological relationships among harvested, dependent, and related populations and the likelihood of adverse impacts;

• A plan for the acquisition of any other research data by fishing vessels, including activities that may require the cooperative activities of scientific observers and the vessel, as may be required for the Scientific Committee to evaluate the fishery potential and the ecological relationships among harvested, dependent and related populations and the likelihood of adverse impacts; and

• An evaluation of the time-scales involved in determining the responses of harvested, dependent and related populations to fishing activities

Each Member active in the fishery or intending to authorize a vessel to enter the fishery annually prepares and submits to CCAMLR a Research and Fishery Operations Plan. The plan is to include as much of the following as possible, to assist the Scientific Committee in its preparation of the Data Collection Plan:

• The nature of the exploratory fishery, including target species, methods of fishing, proposed region and maximum catch levels proposed for the forthcoming season;

• Specification and full description of the types of fishing gear to be used;

• Biological information from comprehensive research/survey cruises, such as distribution, abundance, demographic data, and information on stock identity;

• Details of dependent and related species and the likelihood of them being affected by the proposed fishery;

• Information from other fisheries in the region or similar fisheries elsewhere that may assist in the evaluation of potential yield; and

• If the proposed fishery will be undertaken using bottom trawl gear, information on the known and anticipated impacts of this gear on vulnerable marine ecosystems, including benthos and benthic communities.

B. Harvesting and/or Transshipment Permit

CCAMLR requires details on every vessel a member country licenses to fish in the Convention Area, including:

• The name of the fishing vessel (any previous names, if known);

• Registration number and vessel’s international maritime organization (IMO) number;

• External markings and port registry;

• The nature of the authorization to fish granted by the flag state, specifying time periods authorized for fishing, areas of fishing, species targeted, gear used;

• Previous flag, if any;

• International radio call sign;

• Vessel communication types and numbers (e.g., INMARSAT A, B and C numbers);

• Name and address of the vessel’s owner(s) and any beneficial owner(s), if known;

• Name and address of license owner, if different from vessel owner;

• Length and type of vessel, where and when built;

• Three color photographs of the vessel (showing starboard side, port side, and stern); and

• Details of the implementation of the tamper-proof requirements on the satellite-linked vessel monitoring device.

The Commission requested, to the extent practicable, the following additional information for vessels:

• Name and address of operator, if different from vessel owner;

• Name and nationality of master and, where relevant, of fishing master;

• Beam in meters;

• Gross registered tonnage;

• Normal crew complement;

• Power of main engine or engines in kilowatts;

• Carrying capacity in tonnes;

• Number of fish holds and their capacity in cubic meters;

• Details of ice classification (if any);

• Details of freezing rate capacity; and

• Any other information in respect of each licensed vessel considered appropriate for the purposes of the implementation of the conservation measures adopted by the commission.

NMFS collects this information on the Vessel Identification Form (VIF), as part of the AMLR harvesting and/or transhipment permit application process. The application to harvest and/or transship AMLR includes a section to be completed if a vessel owner is seeking authorization to harvest AMLR and a section if a vessel owner is seeking authorization to transship toothfish. The applicant can complete one or both sections. A permit is issued to the applicant in one of two forms, depending upon whether the vessel is both harvesting AMLR and receiving transshipments of AMLR or only receiving transshipments of AMLR.

The Harvesting Information Form (HIF) collects narrative identifying each AMLR target species proposed for harvest, the total tonnage requested (a figure), the CCAMLR statistical area to be fished, the gear to be used and the type and amount of bycatch anticipated. This information is required in order to determine whether the proposed fishery is consistent with CCAMLR conservation measures. The harvesting permit notes the obligation of a permit holder to provide catch data to CCAMLR.

If the proposed AMLR harvesting is either a new fishery or an exploratory fishery, specific narrative description is required as noted above.

Information in the application is used to report required information to the Executive Secretary of CCAMLR.

The forms associated with applying for a harvesting and/or transshipment permit are:

• Application for Permit to Transship AMLR

• Vessel Monitoring System Certification Statement

• Harvesting Information Form

• Vessel Identification Form

• Additional Information for Vessels Participating in a New or Exploratory Fishery

C. Radio Contact

It may be necessary for operators of harvesting vessels to provide vessel position or other information via radio when requested by the NMFS, the U.S. Coast Guard, an authorized officer, or CCAMLR inspector. This is a routine and necessary law enforcement requirement when dealing with vessels at sea. It consists generally of providing radio call signals and a set of position coordinates immediately prior to a boarding-at-sea for inspection of the vessel and the vessel’s activities by law enforcement officials. Such radio contacts are infrequent and brief.

D. Centralized Vessel Monitoring System

The Commission adopted a conservation measure (CM 10-04) to implement centralized vessel monitoring system (C-VMS). This conservation measure requires vessels fishing in CCAMLR-managed waters to operate a VMS unit that automatically transmits the vessel’s position at least every hour to a land-based fisheries monitoring center of its Flag State.

Each Contracting Party to the Convention must forward the VMS reports and messages received to the CCAMLR Secretariat as soon as possible, but not later than one hour after receipt for exploratory longline fisheries or no later than 10 working days following departure from the Convention Area for all other fisheries. The Contracting Party may elect to have C-VMS data communicated directly to the Secretariat in parallel with those reports received by the Flag State.

The use of the centralized satellite-linked VMS is required by the AMLR regulations of all U.S. vessels harvesting AMLR in the CAMLR Convention Area and for all shipments of toothfish, regardless of where harvested, seeking entry into the United States. All U.S. vessels must operate VMS to and from their homeport to ensure VMS coverage throughout the entire fishing operation.

Data from individual vessels shall be used for compliance purposes only, i.e., active surveillance presence and /or inspections, including for the purposes of verifying the content of a Dissostichus Catch Document (DCD).

U.S. requires also requires participation in C-VMS in real time, from port to port, for foreign vessels that caught toothfish contained in shipments seeking entry into the United States. Applications for pre-approval of imports for which the C-VMS on the harvesting vessel was not active as required will not be approved. This requirement addresses experiences with numerous problems with shipments of toothfish that were reported as having been harvested outside the Convention Area but were suspected of having been harvested illegally from inside the Convention Area.

E. Vessel marking

The vessel’s name and its International Radio Call Sign (IRCS) must be displayed amidships on both the port and starboard sides of the superstructure or hull, so that is it visible at all times from an enforcement or inspection vessel, from another vessel or from the air. The deck must also be marked with the vessel’s IRCS. The markings must meet the specifications in 50 CFR 300.108. The official number provides law enforcement personnel or inspectors with a means to monitor fishing, at-sea processing, and other related activities, to ascertain whether the vessel’s observed activities are in accordance with those authorized for that vessel. NMFS, the U.S. Coast Guard, and other agencies generally use the identifying number when issuing violations, prosecutions, and other enforcement actions. The United States, however, does not currently maintain an enforcement presence in the CAMLR Convention Area.

CCAMLR Inspectors are authorized, by international agreement, to board vessels harvesting in the Convention Area and to inspect for compliance with CCAMLR conservation measures. Vessels that fish in the Convention Area are readily identified when the vessels are marked; vessel-marking violations are more readily prosecuted, allowing for more cost-effective enforcement. Cooperating fishers also use the vessel markings to report suspicious activities that they observe. Regulation-compliant fisheries ultimately benefit as unauthorized and illegal fishing is deterred and more burdensome regulations are avoided.

F. Gear Marking

Under 50 CFR 300.108, the operator of vessel fishing pursuant to an AMLR vessel permit in the CAMLR Convention Area must mark all fishing gear with the vessel’s identification markings. International CCAMLR Inspectors rely on this information to monitor compliance with fisheries management regulations. NMFS, the U. S. Coast Guard, and other agencies in issuing violations, prosecutions, and other enforcement actions generally use the identifying number. Gear that is not properly marked may be confiscated. The United States, however, does not currently maintain an enforcement presence in the CAMLR Convention Area. CCAMLR Inspectors are authorized, by international agreement, to board vessels harvesting in the Convention Area and to inspect for compliance with CCAMLR conservation measures, including gear restriction and gear marking requirements. Gear marking helps ensure that a vessel harvests fish from its own traps/pots/other gear and that traps/pots/other gear are not illegally placed or used. Gear violations are more readily prosecuted and this allows for more cost-effective enforcement.

NMFS regulations do not require the owner of the gear to confirm the specific markings used. There is no information on file. The markings allow identification of the owner of the gear in situations involving damage, loss and civil proceedings. There is no dissemination of information to the public.

G. Scientific Observers

CCAMLR adopted a Scheme of International Scientific Observation in 1992 at its 11th annual meeting. Observers placed on board fishing vessels, pursuant to the scheme, observe and report on the operations of fishing activities and the catch of target and related species of living marine resources. Observers undertake tasks and record their observations pursuant to protocols and using forms provided by the CCAMLR Secretariat. These tasks include recording details of vessel operation; taking catch samples; recording biological data by species caught; recording bycatch; recording entanglement and incidental mortality of birds and mammals; recording procedures by which declared catch weight is measured; collecting and reporting factual data on sightings of fishing vessels in the Convention Area, including vessel type identification, position and activity; and collect information on lost fishing gear and garbage disposal by fishing vessels at sea. NMFS regulations require that all U.S. vessels fishing in the Convention Area, including vessels fishing for krill, and all U.S. vessels conducting longline testing outside the Convention Area prior to longline fishing within the Convention Area, carry one or more scientific observers as required by CCAMLR conservation measures or NMFS regulations.

For this already established observer program, the only information collection subject to the Paperwork Reduction Act is the vessel owner, operator or fisher’s request for an observer or observers. In preparation for a trip, the applicable person makes a telephone call either to the Southwest Fisheries Science Center/Antarctic Marine Living Resource Program or directly to an observer provider.

H. Transshipment Notifications

In accordance with CCAMLR requirements, a vessel operator would be required to provide notification of any transshipment within the Convention Area, of AMLRs or of any other goods or materials, to the CCAMLR Secretariat directly and to submit a confirmation of such notification to NMFS Headquarters. This notification must be provided at least 72 hours in advance.

III. AMLR Trade Control and Monitoring

A. Permits

As a part of meeting its treaty obligations, the United States must also monitor and control the import, export, and re-export of Antarctic marine living resources.

Any person importing, exporting, or re-exporting AMLRs into the United States must have an International Fisheries Trade permit (IFTP). The IFTP, along with submission of information for import and re-export filings, is under a separate information collection, OMB No. 0648-0732.

A person wishing to import and/or re-export AMLR receives an IFTP permit valid for one year, which is a prerequisite, but not an authorization, for trading in AMLR. Note that there are no exports of AMLR given that no U.S. vessels harvest AMLR at this time and all AMLR coming into the United States are imported from other countries.

This information aids NMFS in the development and maintenance of a comprehensive database listing all dealers who import or re-export their product, enabling NMFS to notify all known dealers in a timely fashion of any changes to requirements.

B. Requirements for Toothfish Imports and Exports

Imports of frozen toothfish require a pre-approval certificate issued by NMFS and the appropriate documents from CCAMLR’s Dissostichus Catch Documentation Scheme. No shipment of toothfish can be released for entry into the customs territory of the United States unless accompanied by a complete, validated and electronically transmitted Dissostichus Catch Document (DCD) issued through the E-CDS web-based system hosted by the CCAMLR Secretariat. A Flag State issues a non-transferable DCD that is uniquely identified for a vessel. Once the master of the harvesting vessel records the catch information and conveys such catch information to their Flag State, it is recorded via the web-based system onto the unique Dissostichus Catch Document. Upon transshipment or landing toothfish, the landing state accesses the E-CDS web-based system and completes the landing information.

At the time of export, the exporting State will also access and complete a Dissostichus Export Document (DED) with the export information required by the E-CDS system. Once an export has been completed, the NMFS’ CDS officer will be able to access both the DCD and the DED in the E-CDS system. NMFS then accesses the documents associated with that particular import and matching the Electronic Catch Document with the corresponding request for pre-approval. If all matches, and all other requirements for import are met (such as confirmation of C-VMS for the vessel trip) then NMFS approves the import.

Any dealer who imports toothfish must first obtain the document number and the export reference number on the E-DED corresponding to the import shipment. The dealer enters these reference numbers on the pre-approval application for the shipment.

Any person who imports frozen toothfish is required to complete an application to NMFS requesting pre-approval to allow import of all shipments that contain frozen toothfish, using the Application for Pre-Approval Certificate to Import Frozen Toothfish. Toothfish caught on the high seas outside the Convention Area in Food and Agriculture Organization (FAO) Statistical Areas 51 or 57 may not be imported.

The dealer is required to provide the documentation described above, along with a check for the required fee, so that NMFS receives it at least 10 business days prior to the anticipated date of import. However, some dealers have difficulty obtaining a U.S. Customs 7501 number 10 days in advance of a shipment’s arrival. For this reason, NMFS allows dealers to supply the 7501 number within 3 working days of a shipment’s arrival. All other information on the Application for Pre-Approval is due 10 days prior to the shipment’s arrival.

A separate DED with a unique export reference number is required for each export (import into the United States). A single DED cannot be used to request pre-approval for multiple shipments. However, a single DCD can be used more than once (in conjunction with different, unique DEDs because the DCD covers the entire catch for that vessel). The quantity of toothfish listed on the DED must match the quantity listed on the pre-approval application within a variance of 10 percent. The dealer is required to provide the documentation described above so that NMFS receives it at least 10 business days prior to the anticipated date of import. NMFS reviews the documentation submitted, notifies the dealer whether the import will be approved, and if approved issues a certificate of approval to the applicant

Pre-approval applications for all frozen product must include an application fee of $200.00. We estimate that we receive 640 applications annually, with 90 percent (576) expected to meet the pre-approval requirement, including the $200.00 application fee.

The remaining fresh, air-shipped, shipments of toothfish, which do not require pre-approval, should continue to be reported within 24 hours of import using the Reporting Form for Shipments of Fresh Toothfish. DCDs and DEDs are required for fresh shipments as described above.

C. Re-Exports of Toothfish

In the case of re-exports of toothfish, an exporter completes an Application for Re-export of Toothfish, specific to a DCD that is contained in the particular re-export shipment, the document and export reference number of the original DCD, the species and product type, weight to be re-exported, the name of the importer and point of import, and the exporter’s name, address, email, and permit number. The dealer is also required to reference or include the import approval documentation as well. This helps verify the accuracy of the document and export reference numbers. The U.S. CDS Officer creates the re-export certificate through the E-CDS for the dealer and acts as the validating authority. This document is transmitted with the shipment upon re-export.

The form associated with the re-export of toothfish is the Application for Re-export of Toothfish.

D. Import Ticket

Within 24 hours of any import of AMLR other than toothfish, the importer must submit a completed import ticket describing the resources imported. The import ticket collects the name and address of the individual and company importing the resource, the resource imported and the date, the quantity of the resource, the harvesting vessel or vessels, and the flag country.

It is anticipated that information collected will be disseminated to the public or used to support publicly disseminated information.

Information Quality Guidelines

NMFS will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with National Oceanic and Atmospheric Administration (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 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.

Electronic copies of NMFS harvesting and dealer forms are available at https://www.cio.noaa.gov/services_programs/prasubs.html. VMS data are electronically transmitted. DCDs are electronically generated, completed and transmitted.

The requirement that each vessel display an identification number on its deckhouse or hull, and its weather deck does not lend itself to advanced technology. The requirement that fishing gear be marked with an identifying number does not lend itself to information technology.

4. Describe efforts to identify duplication.

There is no duplication with collection efforts.

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.

No or less frequent collection of data would not provide DOC/NOAA with data it must have for adequate and timely monitoring and reporting on the harvesting and importation of AMLR resources. NMFS and the U.S. Coast Guard could not enforce the fisheries management measures and CCAMLR Inspectors could not conduct effective gear inspections, if the gear and vessel are not marked.

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

Not Applicable.

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 May 6, 2019 (84 FR 19768) solicited public comments. No pertinent comments were received.

NMFS is preparing to make the toothfish import pre-approval certificate applications available on-line. However, the date of availability is not yet known.

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 collection forms, the data collected 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.

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.

There are 87 unique respondents, 1,415 responses, 363 hours and $12,731 in labor costs for this request.

SSA Part	Requirements	Respondents	Annual # of Responses / Respondent	Total # of Annual Responses	Burden Hrs / Response	Total Annual Burden Hrs	Annual Labor $ @$35/hr
Ia)	5-year CEMP permit application	1	1 / 5 years	0.2	0.2	0.2	$35
Ib)	CEMP annual report	1*	1	1	1	1	$35
II A)	Applicants for new or exploratory fishery	2*	1	2	28	56	$1,960
II B)	Harvest and/or transshipment applications	5	1	5	2	10	$350
II C)	Radio transmissions	5*	2	10	0.0833	0.833	$35
II D)	Centralized VMS	5*	1	5	6.0833	14.0833	$490
	Installation (burden averaged over 5 years)	5*	1	5	4	4	$140
	VMS certifications (burden averaged over 5 years)	5*	1	5
	Maintenance	5*	1	5	2	10	$350
	Installation & Activation Checklist (burden averaged over 5 years)	5*	1	5	0.0833	0.0833
	Annual VMS transmission costs	5*	1	5	N/A	N/A
II E)	Vessel Marking	5*	3	15	0.25	3.75	$131
II F)	Gear Marking (2 Longline vessels, 1 Crab Vessel, 2 Trawl Vessels)	5*	307	314	0.1499	11	$385
	Buoys/floats	2	4	8	0.0833	0.6664
	Traps/pots	1	300	300	0.0333	9.99
	Tag Sewn into Net (Trawl gear)	2	3	6	0.0333	0.1998
II G)	Request for Observer	5*	1	5	0.0833	0.4165	$35
II H)	Transshipment Notification	1*	5	5	0.25	1.25
III A)	First Receiver Permit Applications (includes designating a registered agent)	1	1	1	0.25	0.25	$35
III B)	Toothfish Import/Export	82*	7.8536	644	0.25155	162	$5,670.00
	Shipments of Fresh Toothfish	2*	2	4	0.5	2	$70
	Pre-Approval Applications	80*	8	640	0.25	160	$5,600
III C)	Re-Export of Toothfish	10*	40	400	0.25	100	$3,500
III D)	Import Tickets	2*	4	8	0.25	2	$70
	TOTALS			1415.2		363	$12,731

* Respondents in this column are not additive: unique respondents are the CEMP applicant, 5 vessels/vessel representatives, 1 first receiver applicant, and 80 dealers. All asterisked figures indicate the same set or a subset of one of these three respondent categories.

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).

SSA Part	Requirements	Respondents	Annual # of Responses / Respondent	Total # of Annual Responses	Burden Hrs / Response	Total Annual Burden Hrs	Cost Burden / Response	Total Annual Cost Burden
Ia)	5-year CEMP permit application	1	1 / 5 years	0.2	0.2	0.2	0.55	$0.55
Ib)	CEMP annual report	1*	1	1	1	1	0.55	$0.55
II A)	Applicants for new or exploratory fishery	2*	1	2	28	56	0.55	$1.10
II B)	Harvest and/or transshipment applications	5	1	5	2	10	0.55	$2.75
II C)	Radio transmissions	5*	2	10	0.0833	0.833	N/A	N/A
II D)	Centralized VMS	5*	1	5	6.0833	14.0833	3201.1	$7,003.30
	Installation (burden averaged over 5 years)	5*	1	5	4	4	$2,250.00	$2,250.00
	VMS certifications (burden averaged over 5 years)	5*	1	5			$0.55	$0.55
	Maintenance	5*	1	5	2	10	$350.00	$1,750.00
	Installation & Activation Checklist (burden averaged over 5 years)	5*	1	5	0.0833	0.0833	0.55	$2.75
	Annual VMS transmission costs	5*	1	5	N/A	N/A	$600	$3,000.00
II E)	Vessel Marking	5*	3	15	0.25	3.75	$25	$125
II F)	Gear Marking (2 Longline vessels, 1 Crab Vessel, 2 Trawl Vessels)	5*	307	314	0.1499	11	$25	$125
	Buoys/floats	2	4	8	0.0833	0.6664
	Traps/pots	1	300	300	0.0333	9.99
	Tag Sewn into Net (Trawl gear)	2	3	6	0.0333	0.1998
II G)	Request for Observer	5*	1	5	0.0833	0.4165	$1.50	$7.50
II H)	Transshipment Notification	1*	5	5	0.25	1.25	N/A	N/A
III A)	First Receiver Permit Applications (includes designating a registered agent)	1	1	1	0.25	0.25	0.55	0.55
III B)	Toothfish Import/Export	82*	7.8536	644	0.25155	162	$199.31	$128,354.20
	Shipments of Fresh Toothfish	2*	2	4	0.5	2	0.55	$2.20
	Pre-Approval Applications	80*	8	640	0.25	160	$200.55	$128,352
III C)	Re-Export of Toothfish	10*	40	400	0.25	100	0.55	$220.00
III D)	Import Tickets	2*	4	8	0.25	2	0.55	$4.40
	TOTALS			1415.2		363		$135,844.90

Total = $ 135,844.90

14. Provide estimates of annualized cost to the Federal government.
Requirement	Hours
a) Processing one CEMP application @ 1 hour	1
Requirement	Hours
b) Processing two new/exploratory fishery application @ 2 hours.	4
c) Processing five harvest/transship applications @ 2 hours each	10
d) Receiving radio transmissions (negligible costs)	0
e) Receiving VMS transmissions (negligible cost)	0
f) Gear marking (no cost)	0
g) Vessel marking (no cost)	0
h)
i) Completing DCDs and E-DCDs, 8 @ 30 minutes each	4
j) Processing 640 pre-approval applications @ 2hours each	1,280
k) Processing 400 re-export catch documents @ 30minutes each	200
l) Processing 20 import tickets @ 30 minutes each	10
Total hours	1,509
Data processing @ $14.00 per hour for 1,509 hours	$ 21,126.00
Overhead/benefits @ 35%	$ 7394.00
Total	$ 28,520.00

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

The sponsor and NOAA PRA Clearance Officer collaborated to perform a thorough scrub of the IC information contained in ROCIS.

Program Change:

The Dealer import and/or re-export permit applications is no longer a valid collection and was removed. This is a decrease of 92 responses, 23 burden hours, and 42 cost burden.

Adjustments:

The Pre-approval of toothfish catch documents/reporting docs if fresh/importing was merged with the Shipments of Fresh Toothfish collection as more appropriate.

Merging the Pre-approval of toothfish catch documents/reporting docs if fresh/importing with the Reporting Form for Shipments of Fresh Toothfish increases the burdens as follows: responses increase by 640; Total annual burden hours increase by 160; and total annual cost burden increases by $128,352.

The remaining adjustments were to costs of supplies and postage. Adjustments were also made to VMS transmission costs, which accounts for $2,678 of the $3,359 in increased cost burden.

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

The Ecosystem Monitoring and Management Working Group of the CCAMLR Scientific Committee compiles the research and required permit reports submitted by Member States on CEMP site activity and presents these findings in a published form to the Commission. These published reports are available to Member delegations and to interested individuals from the Commission. NMFS does not plan to make available results of any of the information collections discussed above on the Internet. The Executive Secretary of CCAMLR publishes information on harvesting vessel licenses, harvesting activity, and toothfish trade on password protected sections of the CCAMLR website.

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.

No OMB expiration date will be displayed on the DCD because it is a CCAMLR form.

18. Explain each exception to the certification statement.

Not applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

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