0648-0016 Supporting Statement Part A 2019-1112

SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic & Atmospheric Administration

Federal Fisheries Logbooks

Southeast Family of Forms

OMB Control No. 0648-0016

A. JUSTIFICATION

Introduction

The National Marine Fisheries Service (NMFS) has been delegated the authority and responsibility for stewardship of the Nation’s marine resources. This authority was first granted in the Magnuson-Stevens Fishery Conservation and Management Act (FCMA) of 1976. The reauthorization of the FCMA in 2006 continued and in some ways extended this authority. Under this authority the Secretary of Commerce and his designee, NMFS, have promulgated separate rules that require specific types of record keeping and data submissions. These data collection/submission regulations are intended to provide reliable and accurate information from the fishing industry and communities that support scientifically based management actions to achieve the stewardship responsibilities.

Currently, there are five separate logbook forms included in the Southeast family of forms and actively being used by the NMFS to collect data from fishermen. It should be noted that several of the forms are used for multiple fisheries regulations. For example, the data required by the South Atlantic snapper grouper, the shark, the migratory coastal pelagic and the Gulf reef fish management plans have been combined and are reported on a single form. The Colombian Treaty Waters logbook form was included in this family in the past, but was removed from this collection in the 2016 renewal .

The five reporting forms in the logbook family of forms are:

• Gulf of Mexico reef fish, South Atlantic snapper-grouper, mackerel, shark, Atlantic dolphin / wahoo logbook with cost-earnings data section (coastal logbook)

• Annual fixed cost survey for vessels required to use the coastal logbook

• Supplemental discard form for use with the coastal logbook

• Wreckfish logbook form

• Golden crab logbook form

In addition to the five forms, one data collection program (headboat survey trip report) uses an electronic data collection.

A brief description of the 7 active data collection programs follows.

Headboat Survey Trip Report

Fishing from headboats is considered recreational fishing; however, because this type of fishing represents a relatively small, but specialized sector of recreational fishing and the data collection of information from this sector by the Southeast Fisheries Science Center (SEFSC) predates the NOAA Fisheries’ Marine Recreational Information Program (MRIP) methodology, it has not been included in the MRIP data collection, OMB Control No. 0648-0052. To collect catch and effort data from this fishery, a separate logbook program has been established in the Southeast Region to capture more precise information than the MRIP for this fishery. Total catch and participation estimates for all headboat fishing activity are made from the headboat survey. The need for good quality, representative catch per unit effort (CPUE) and species composition data from this sector of the recreational fishery is the primary reason that this program was implemented.

NOAA Fisheries is a partner in two state-federal cooperative data collection programs. One program, the Atlantic Coastal Cooperative Statistics Program (ACCSP), covers the Atlantic coast and the other program, the Fisheries Information Network (FIN), covers the fisheries in the Gulf of Mexico. A goal of both programs is to standardize and improve collection of data in both geographic areas).

Trip reports, now collected electronically as part of the Headboat Survey, have been used to collect catch and fishing effort data from the headboat portion of the for-hire sector since 1972. These trip report data have been extremely valuable in stock assessments of reef fishes and pelagic species in the southeast region (North Carolina through Texas).

Gulf of Mexico Reef Fish, South Atlantic Snapper-Grouper, king and Spanish Mackerel, Shark, Atlantic Dolphin / Wahoo logbook (coastal logbook)

The program to collect logbook data in the Gulf of Mexico was initiated in April 1990. The purpose of the program is to provide critically needed data on individual fishing trips for species in this important management unit. The diversity of gear in this fishery (i.e., longline, hook and line, traps, spears, and buoy) and the variety of species increases the need to have detailed CPUE and species composition data. Furthermore, because species in this management unit are not migratory, it is important that detailed information on the CPUE and species composition are collected by area, so that assessments can be made for major reef complexes to determine how fishing effort is affecting these complexes over time.

This logbook program includes only fishermen who have been issued a Federal vessel permit and are required to sell their catches to established (permitted) seafood dealers. Consequently, for-hire recreational fishermen do not submit logbooks for the Gulf reef fish fishery (see the description for the for-hire headboat catch reports above).

The logbook program for the South Atlantic snapper-grouper fishery was initiated in January 1992. The purpose of this program, as for the Gulf reef fish program, is to collect data on fishing effort, CPUE and species composition. The snapper-grouper fishery is similar to the fishery for reef fish in the Gulf of Mexico; consequently, the logbook forms used for the two fisheries are the same.

Although sharks are part of the Highly Migratory Species fishery management plan, and the reporting burden for these species are covered by OMB Control No. 0648-0371, the fishing operations for large and small coastal sharks are very similar to the fishing methods for Gulf reef fish and South Atlantic snapper-grouper species. Thus, the coastal logbook form (OMB Control No. 0648-0016) includes space for fishermen to report the catch, effort and area of catch for coastal sharks. The Pelagic shark fisherman will continue to report using the highly migratory species logbook (OMB Control No. 0648-0371).

As with the fisheries in OMB Control No. 0648-0016, the purpose of the logbook program for king and Spanish mackerel is to collect catch, effort and area for this fishery in both the Gulf of Mexico and the South Atlantic. The assessments for king and Spanish mackerel were improved by the availability of this CPUE data. There are other species in this fishery management plan; however, logbook reporting for these species is not required at this time.

Cost-earnings data section (20% sample size)

The purpose of this data collection is to provide economic information about commercial fishermen in Federal waters, which is necessary for the agency to address National Standard 8 of the FCMA. The reporting form requests information about operating costs associated with the individual fishing trips. The intent is to use the cost information associated with the effort data for individual trips to better understand how the cost of fishing varies with changes in fishing effort and the impacts of management measures on fishing communities. With a better (quantitative) understanding of these relationships, NMFS can provide better estimates of the potential impacts of management regulations on fishing effort.

Annual fixed cost survey for vessels required to use the coastal logbook

This survey is associated with the cost-earnings data collection. The purpose of this data collection is to provide information on the annual fixed costs (i.e., expenditures that are made infrequently throughout the year or only once per year) incurred by the commercial fishermen in Federal waters. The survey instrument is sent to the same fishermen that are required to report their cost data for each trip.

Supplemental discard reporting logbook for vessels required to use the coastal logbook

This form was developed and initiated in August 2001, as a supplemental form to the Gulf of Mexico reef fish, South Atlantic snapper-grouper, shark and mackerel logbook form. The purpose of this instrument is to have the fishermen record the species and numbers of discards that they had for each trip. The form also asks the fishermen to report any interactions with marine mammals, endangered species or sea birds that they incurred on each trip. The purpose of this data collection is to collect information on the types and numbers of animals (species) that fishermen in these coastal fisheries discard or in the case of endangered species and marine mammals with which they interact, so the agency is able address National Standard 9, which deals with bycatch. This data collection is conducted as a supplement to the regular logbook reporting so that the catch, effort and area of fishing can be associated with the discards and/or interactions.

Wreckfish logbook

The wreckfish fishery is part of the South Atlantic snapper-group management unit, but because there were concerns about the status of the wreckfish stock, specific management measures were implemented to collect data from vessels that harvest this species. Although separate logbooks are used for this fishery, they require the same basic CPUE and fishing location data as the other logbooks in the family, but the program also collects information on shares of the Individual Transferable Quota used during each trip.

Golden Crab logbook

Fisheries for this species of deep water crabs occur in both the Gulf of Mexico and the South Atlantic. Logbook reporting requirements have been implemented at the request of the South Atlantic Fishery Management Council under advice from their Advisory Panel. This logbook program is designed to collect the quantity of golden crab that are caught in designated areas. The form is distinct from the other forms authorized by regulations (50 CFR Part 622) because lines of traps are used to catch these species and the amount of catch needs to be reported by line instead of for an entire trip.

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

The catch, effort and landings statistics that will be collected by the vessel logbooks are necessary to provide NMFS with comprehensive and accurate data to estimate fishing mortality. Without these data, a significant increase in the uncertainty of stock assessment analyses is likely to occur and the error bounds around the stock benchmarks, such as maximum sustainable yield, will be unacceptably large.

Another compelling reason for NMFS’ logbook program is to provide comprehensive, consistent catch and effort data throughout the entire Southeast Region (i.e., North Carolina to the Texas-Mexican border). As will be discussed in the response to Question 4, landings statistics by vessel and trip are collected by state trip ticket program. The logbook data are also collected at the trip level; however, because only some of the states in the SE Region have fully operational trip ticket programs or require the detailed effort information necessary for calculation of CPUE, it is necessary for NMFS to institute a comprehensive program that assures the collection of consistent CPUE data throughout the jurisdiction of the respective fishery management plans.

Overall, the data collection for stock assessments is authorized as part of the Magnuson-Stevens Fishery Conservation and Management Act, as amended. Specifically, the reporting and record keeping requirements for OMB Control No. 0648-0016 are authorized in 50 CFR 622.5, Fisheries of the Caribbean, Gulf of Mexico and South Atlantic. The authority for South Atlantic snapper-grouper, Gulf reef fish, king/Spanish mackerel, golden crab, and wreckfish reporting is in section 622.5(a); for the headboat catch reporting, section 622.5(b).

All vessels with permits required in 50 CFR 622.4 are considered for selection, but reporting is required only when the vessel is selected by NMFS’ Science and Research Director, Southeast Fisheries Science Center. For some of the reporting forms, all permit holders are selected, while for other forms, statistical selections are made.

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 data requested on logbooks are used by various offices of NMFS, Regional Fishery Management Council staff, the U.S. Coast Guard and state fishery agencies under contract to NMFS to develop, implement and monitor fishery management strategies. Analyses and summarizations of logbook data are used by NMFS, the Regional Councils, the Departments of State and Commerce, OMB, the fishing industry, Congressional staff and the public to answer questions about the nature of the Nation’s fishery resources. Information on endangered species or marine mammals and their incidental take is requested in those fisheries where such interactions are likely to occur. These data assist NMFS meet its requirements under the Marine Mammal Protection Act and the Endangered Species Act. If reports of such occurrences are common, NMFS can proceed to minimize the harvest of such species through the promulgation of regulations.

These data serve as input for a variety of uses, such as: biological analyses and stock assessments; E.O. 12291¹ regulatory impact analyses; quota and allocation selections and monitoring; economic profitability profiles; trade and import tariff decisions; allocations of grant funds among states; and the identification of ecological interactions among species. NMFS would be significantly hindered in its ability to fulfill the majority of its scientific research and fishery management missions without these data.

The logbook family of forms has evolved as a means of collecting data from specific user groups within fisheries that are managed under federally implemented fishery management plans (FMP). The Southeast Fisheries Science Center has the responsibility for both preparation of stock assessments (estimation of maximum sustainable yield and/or other indexes of biomass) and collection of the scientific data that are required to perform the assessments. A secondary data collection responsibility is to provide information that is necessary to routinely monitor and evaluate the conditions in the fisheries under Federal management.

Similar data elements are required for most of the logbook forms and/or electronic reporting systems in this family, although a few variables may be specific to one fishery or type of management technique controlling harvest.

a) Information such as name and address of operator and owner is used to identify the respondent and the legal entity controlling the fishing practices of the vessel. The legal entity requirement is essential in monitoring the compliance of the reporting requirement, where revocations of the operators permit or fines are involved. Because many vessels are owned by corporations, identification of owner and operator on the logbook form allows NMFS to sanction the company as well as the individual vessel operator as necessary or required by the regulations. Information on the permit is obviously essential to monitoring reporting compliance.

b) Data on date of departure, date returned, days fished, duration of tows or sets, units of gear and mesh size used are all designed to quantify actual fishing effort. Fishing effort is needed to standardize differences in productivity among vessels or fishing grounds by establishing a rate of catch per unit time. These data allow comparisons over time, area and gear type of catches made by a variety of harvesters. Comparisons of catch and CPUE over time are significant indicators of the biological status of the fisheries. Declining CPUE, especially if data on fishing effort are sufficiently detailed to adjust for changes in effort, can provide critical information on the status of the stock, i.e., that the level of harvest is beyond the level that is sustainable by growth and reproduction of the stock.

c) Area fished, depth of fishing, latitude and longitude are variables that are used to establish fishing locations. This information can be related to other oceanographic and biological information to predict species availability and likely future abundance. For example, location of capture can be correlated to sea surface temperature measured by satellite to predict possible migration patterns. In addition, area or zone fished is used to cross reference locations where fishing is not permissible (such as closed spawning areas).

d) Species information such as landings, discards and sizes of fish is the basic measure of fishing success, from which fishermen, biologists and economists infer conclusions about the status of the fishery. Landings information is also needed because controlling the quantity of fish harvested is often the means for ensuring that harvests can be replenished over time.

e) Name of buyer, dealer number and port of landing are data used to cross reference the quantity of fish caught with the quantity that is handled (processed) by the market. The important cross reference is between the total amount of catch, and the respective sizes of individual fish. It would be impossible for fishermen to measure individual fish as they are being caught and stored on board the vessels. However, many species of fish, especially the large pelagic species, are individually weighted by the dealers and these weights are recorded as part of the sales transactions. By knowing the dealer that purchased the fish, cross references can be made between data submitted by the dealers and the data from the logbooks. Combining the data in this manner provides greater precision on the CPUE estimates and more information on the sizes of catches by location and time.

f) Trip cost information such as fuel, tackle, bait, ice, labor, and miscellaneous expenses associated with the effort data for individual trips is use for evaluating regulatory proposals and to better understand how the cost of fishing varies with changes in fishing effort. With a better (quantitative) understanding of these relationships, the NMFS can provide better estimates of the potential impacts of management regulations on fishing effort.

g) A separate form is required for many of the logbook reporting forms in 0648-0016 when a vessel does not fish during an entire calendar month. These “no-fishing” forms are necessary to assure the NMFS that the vessel did not fish instead of failing to report. The information on the no-fishing form is minimal - i.e., only the vessel ID, vessel name, the month in which the vessel did not fish and the permits that vessel has been issued (a check box is provided for ease of identifying the permits). The no-fishing forms are located in the back of the logbook booklets and are to be submitted via mail in the self-addressed, stamped envelopes provided by the NMFS SEFSC.

NMFS and the respective state fishery agency 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 #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 subject to quality control measures and a pre-dissemination review pursuant to Section 515 of the 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.

Currently electronic reporting is being utilized to report the detailed, trip level data for one of the five active logbook programs of the SEFSC (Headboat survey trip report). A second web-based electronic reporting program is being used to report months that do not involve fishing in the coastal fisheries logbook. The SEFSC is investigating various methods of recording and reporting CPUE data from vessels of the other six fisheries. However, the large number of vessels involved in the affected fisheries and the cost per participant for the electronic and telecommunication equipment must be considered before mandating its use by fishermen. These costs significantly limit the options available for electronic reporting by vessels. The SEFSC will accept any data in an electronic format that can be easily read and inputted into the existing data base management system employed by the SEFSC.

4. Describe efforts to identify duplication.

The Magnuson-Stevens Act's operational guidelines 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. Each Fishery Management Council membership is comprised of state and federal officials responsible for resource management in their area. This joint participation enables identification of other collections that may be gathering the same or similar information. In addition, each FMP undergoes extensive public comment periods where potential applicants review the proposed permit application requirements. Therefore, NMFS is confident it would be aware of similar collections if they existed.

Detailed information on CPUE, effort and species composition by gear and area is not available from other sources. Some states, notably Florida, Georgia, Louisiana and North Carolina, have programs to collect landings by species for individual fishing trips (i.e., operational trip ticket programs), but these programs do not include the detailed information on location and effort that are required in the reporting requirements for this OMB request. Furthermore, these programs collect the data from seafood processors, and not fishermen, whereas logbooks are submitted directly by the fishermen.

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

Because all applicants are considered small businesses, separate requirements based on size of business have not been developed. Only the minimum data to meet the analytical needs of the SEFSC's assessment scientists are requested from all applicants.

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

The consequence of not having detailed CPUE and species composition data is to increase the uncertainty associated with the stock assessments that are the basis for sound management decisions. As with any statistical analysis, the confidence limits (bounds) for specific points will be large if there is significant uncertainty in the data. With the availability of the logbook data, the sample sizes for the various stratifications of gear and area are sufficiently large to reduce the uncertainty in the data to acceptable levels.

The logbook data also provide critical information on the type and amount of effort. Without these data, there is no way of knowing whether changes in total catch are due to changes in fishing effort or changes in the abundance of the resource, or both.

If the economic data (cost, earnings, and fixed cost) were collected less frequently or not at all, then economists would be less able to estimate the effects of regulations on financial performance or fishermen’s expected reactions to additional regulations. Proposed regulations for the snapper-grouper and mackerel fisheries would continue to be debated with limited economic information. Another consequence of not having representative economic data could be judicial remand of conservation regulations challenged on grounds of inadequate analysis of economic impact to individual firms.

Not having discard data would also to increase the uncertainty associated with the stock assessments. Furthermore, there is a lack of scientifically collected information on discards in many of these fisheries and consequently, it is difficult to determine whether discarding is a significant problem. Clearly, the data from observers in other fisheries, notably the pelagic longline fishery, show that discards are substantial and that their occurrence is variable. Consequently, NMFS feels that it is necessary to increase the collection of discard data for coastal fisheries.

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

The reporting regulations require fishermen to submit completed logbooks for all trips or sets for several reasons. First, it is critical that these data be timely. For fisheries that are significantly overfished, it is important to monitor changes in fishing mortality. Secondly, the renewal of Federal vessel permits is predicated on compliance with the reporting requirements, and timely data are needed to determine whether fishermen are complying on a regular basis. Thirdly, quality control of the logbook data is better when the review and verification process is closer to the actual time that fishing occurred.

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 July 17, 2019 (FR 34164) solicited public comment on this collection. One response was received.

Comment: The National Oceanic and Atmospheric Administration (NOAA) should continue to require that vessels report gear type and effort data in catch logbooks, which are critical to implementing effective fisheries management, enhancing sea turtle and marine mammal protections, and providing critical catch documentation demonstrating the fish was caught in a legal fishery.

Response: NOAA appreciates this comment.

Comment: Oceana recommends that NOAA prioritize transitioning to electronic catch reporting to enhance data collection methodologies and expand current electronic catch reporting pilot programs.

Response: NOAA thanks Ocean for this suggestion and we will explore the feasibility of transitioning to electronic catch reporting and expanding current electronic catch reporting pilot programs.

Because these data collection programs are part of fishery management plans, all aspects of the programs have been reviewed by both statistical and constituent advisory committees. Furthermore, comments and suggestions from fishermen required to report are routinely submitted and these are reviewed and considered. Experience with the various programs, some of which have been operating since 1981, provides a continual feedback mechanism to NMFS on issues and concerns to the applicants. NMFS directly asked and received comments from our partners at the South Atlantic and Gulf of Mexico fisheries management councils, summarized below, on (a) whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility; (b) the accuracy of the agency's estimate of the burden (including hours and cost) of the proposed collection of information; (c) ways to enhance the quality, utility, and clarity of the information to be collected; and (d) ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology.

(A) Collection of commercial statistics on landings, fishing effort and trip expenses is critical to the Council fishery management program. The Council is obligated to manage by landings-based limits and to implement accountability measures that ensure these limits are not exceeded. Further, it is expected that such limits are derived through quantitative stock assessments and best available science. Since modern assessment methods rely upon catch statistics it is impossible to conduct such analyses without accurate statistics. These data are of clear utility, as every assessment conducted through SEDAR has incorporated commercial landings data. Such data have also been used by the Council SSC in setting catch limits for unassessed stocks. Without this information the Council cannot comply with its mandates under the Magnuson Act.

(B) Estimate of burden hours appears to be high given the simple easy to answer questions on the forms, however, since NMFS must account for the rare case when a fisherman must gather and tally data from multiple sales receipts to complete the forms the estimate is accurate.

(C) Timeliness is a major impediment to improving use of data now collected. Any efforts to decrease the time necessary to enter and validate catch statistics will be worthwhile. The agency is also urged to continue efforts to reduce landings reported as an unidentified species or through unidentified gear types. Within fisheries such as Snapper Grouper, where there is considerable variation in how and where operations are conducted, it would be helpful to obtain set-level information on effort, species composition and catch characteristics.

(D) Electronic reporting programs are widely considered to hold promise of reducing data lags and errors as well as the reporting burden to fishermen. Efforts should be made to develop electronic reporting methods that will eliminate the need for multiple reports and make data available more quickly to both fishermen and managers. Efforts should also continue to develop onboard monitoring devices which allow determination of set-level catch and gear characteristics, and, importantly, provide data on discard levels and discard size composition that is otherwise unobtainable.

To address these views on timeliness and accuracy NMFS will be monitoring the submission of the reports and working with industry to encourage accurate and timely reporting. Procedures include notifying fisherman when reports were expected but not received, and quality control checks on the data received. Additionally NMFS is working with the developer of the electronic headboat reporting program to ensure better data entry constraints on future software versions thus reducing problems with unidentified species, gears, and areas. NMFS has been moving towards more electronic reporting and will continue to do so in the future. NMFS feels these steps will increase reporting accuracy and timeliness. There are no major problems that have not been resolved.

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

There are no payments or other remunerations to respondents.

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 and the logbook cover, data collected via this family of forms are treated in accord with NOAA Administrative Order 216-100, Confidential Fisheries Statistics. Reports are considered confidential under the Trade Secrets Act. In addition, landings statistics are considered to be in an entrepreneurial capacity and will be exempt from the Privacy Act concerns. It is the policy of the NMFS that confidential data are not to be released to non-authorized users, other than in aggregate form, as the Magnuson-Stevens Act protects (in perpetuity) the confidentiality of those submitting data. Whenever data are requested, the NMFS ensures that information identifying the pecuniary business activity of a particular vessel is not identified.

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.

No questions of a sensitive nature are asked.

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

To comply with the reporting requirements, fishermen are required to submit either a fishing log where they report the catch, effort and area data, or a no-fishing log, where they state that they did not fish during the specified calendar month. The number of respondents, the estimated number of responses, the time per response and the total burden for fishing and no-fishing forms for each of the seven fisheries for which logbook reporting is active are presented in the following table:

Fishery	Number of Respon-dents	Fishing Responses	Time per response	Total Time (Hours)	No-fishing Responses	Time per response	Total Time	Total Burden Hours
Headboat**	142	21,312	10 min.	3,552	2,408	2 min.	80	3,632
Golden Crab*	12	164	10 min.	27	67	2 min.	2	29
Coastal logbook*	3,466	36,535	10 min.	6,089	30,740	2 min.	1,025	7,114
Wreckfish**	6	48	10 min.	8	24	2 min.	1	9
Discard*	474^	12,933	15 min.	3,233	N/A	N/A	N/A	3,233
Economic cost/trip**	693^	14,224	10 min.	2,371	N/A	N/A	N/A	2,371
Annual fixed cost**	693^	693	45 min.	520	N/A	N/A	N/A	520
Total	3,484 (un-duplicated)	85,909		15,800	33,239		1,108	16,908

* 5 year average (2013-2017)

** Current estimate

^ Subset of respondents included with coastal logbook

The numbers of respondents, responses and burden hours in the above table are based on the actual reporting activity for these fisheries for the five year average during 2013-2017.

There are 17,038 burden hours in the current OMB inventory for this family of forms and the newly estimated burden is16,908 hours. Thus, there is a decrease of 130 hours from the current inventory. The increase can be attributed to seasonal fishing differences.

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 #12 above).

There are no anticipated costs beyond the opportunity cost of completing the logbook forms. The fishermen are provided with addressed, postage-paid envelopes that they use to return the completed forms.

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

The annual cost to the Federal government is estimated to be $1,750,000 per year. Many of these programs share resources such as program staff and computer support therefor these calculations were made for all the programs combined and include a) printing costs which includes the cost of the postage-paid envelopes of approximately $100,000 annually; b) program staff, site review, and data entry of approximately $1,100,000 annually that includes 10 full-time employees and 5 part time contractors; and c) form development, and program management costs of approximately $550,000 annually that includes 2 full-time employees and approximately 2 contracts for computer related support.

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

The difference of the current inventory of 17,038 and the new estimated burden hours of 16,908 is a net difference of 130 hours or approximately .8%. The number of annual burden hours is mainly driven by the number of fishing trips made by the fisherman each year. Seasonal differences are always noticed because many factors such as weather, fuel cost, dock side fish prices, fish migration patterns, the number of fisherman with active permits, and seasonal closures can influence how many fishing trip take place annually. Averages have been used to determine annual estimates from the 7 active data collection programs.

Please note in the past the Colombian Treaty Waters logbook form was included in this family and no past reporting burden is associated with this logbook form because fisherman have not been issued all the required permits by the Colombian government in time to conduct fishing trips in Colombian waters. The joint nation’s treaty is still in place and if the permitting situation changes the program may need to be restarted at a later date, since this collection was removed from this information collection request in the last renewal.

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

The results from this collection are expected to be published, but will be used as empirical input to stock assessments, economic analyses, and other analyses of proposed or existing fishery management regulations prepared by the NMFS/SEFC.

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.

The OMB number will be displayed.

18. Explain each exception to the certification statement.

NA.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS.

There are three data collection activities within OMB Control No. 0648-0016 in which statistical sampling methods are used: (1) the collection of cost and earnings data as an add-on to the coastal fisheries logbook, (2) Annual fixed cost survey, and (3) the collection of discard data as a supplement to the coastal logbook. The three data collection activities use the same potential respondent universe and two different sampling methods for sample selection. The two economic collections use the same sample, as the annual fixed cost survey complements the trip-level cost and earnings add-on.

1. Describe the potential respondent universe and any sampling or other respondent selection method to be used.

The population of boats to be sampled was determined from logbook reports submitted to the NMFS on an annual basis. Commercial fishermen are required to submit a trip report within seven days after the completion of each Gulf of Mexico reef fish, South Atlantic snapper-grouper, mackerel, shark and Atlantic dolphin / wahoo logbook trip. Fishermen who did not participate in these fisheries during a given month are required to submit a ‘no-fishing’ report at the end of the month.

Annually approximately 3,500 permitted boats take at least one fishing trip in one or more of these fisheries. Approximately 2,500 distinct vessels report fishing activity, i.e., one or more trips, during a typical year. To reduce the reporting burden on the fishermen, two 20% samples of the vessels with a Gulf of Mexico, South Atlantic snapper-grouper, king mackerel, Spanish mackerel or shark permit are selected to report economic information and discard information. To assure that the samples are representative of the total universe of vessels with Federal permits, stratified, random samples are selected from the universe of all vessels with the above types of Federal permits. The economic collections, the population is stratified by vessel activity during the last two years. The three strata are 1) inactive or new vessels, 2) active vessels with up to 20 days at sea per year, and 3) active vessels with more than 20 days at sea the active vessel strata are oversampled, while the (large) inactive stratum is undersampled, for a total of approximately 700 respondents annually. For Discard reporting, a 20% sample is selected randomly from vessels who fished during the previous calendar year, for a total of approximately 500 respondents annually.

2. Describe the procedures for the collection, including the statistical methodology for stratification and sample selection, the estimation procedure, the degree of accuracy needed for the purpose described in the justification, any unusual problems requiring specialized sampling procedures, and any specific use of periodic (less frequent than annual) data collection cycles to reduce burden.

The data collection method is comparable to a mail survey, as forms are filled out by respondents. The two samples---economic and bycatch---are selected by stratified random sampling. Many permits are on vessels that are not active commercial fishing vessels and hence they generate no useful data. At the other end of the activity spectrum, a few very active vessels are often responsible for the bulk of landings in any one fishery/gear segment. The intent of both sampling designs is to undersample inactive vessels and oversample active and highly active vessels. The economic sampling design breaks to population into three activity stata (inactive, <=20 days at sea, >20 days at sea) without further reference to region or gear. The discard sampling design breaks the population into multiple region-gear stata. A random sample will be selected from each stratum, and these vessel owners will be notified of their selection with the mailing of new year’s logbook. It is necessary for those selected to report bycatch or economic data to report all discards and interaction data of all cost and earnings data, respectively,for every trip where they occur. Annual reporting will result in poorer quality data because fishermen will not be able to remember their fishing activity for that length of time.

Data will be used for descriptive and analytical purposes. Descriptive uses include the estimation of average harvesting costs per boat per trip and average discard or interactions per boat trip in the sampling universe. Data collected from sampled boats will be expanded to all boats in the sampling universe based on equations available in statistical texts by Cochran and Thompson. Analytical uses include evaluations of regulatory proposals.

For the annual fixed cost survey, a separate form to collect information about annual fixed costs will be mailed early in a given year to the fishermen selected to report trip-level costs the previous year, with the timing established to take advantage of the availability of information about annual expenditures as recently compiled for end-of-year federal income tax purposes. Trip reports about routine harvesting costs and annual reports about fixed costs will be submitted to the NMFS/SEFSC logbook program in Miami, Florida.

3. Describe the methods used to maximize response rates and to deal with nonresponse. The accuracy and reliability of the information collected must be shown to be adequate for the intended uses. For collections based on sampling, a specialized justification must be provided if they will not yield “reliable” data that can be generalized to the universe studied.

Project staff obtained input on this proposed data collection program from commercial fishermen throughout the jurisdiction of the South Atlantic and Gulf of Mexico Fishery Management Councils. Input included fishermen’s opinions about the types of information that they can provide with minimum burden and the format for collecting data. Their input was used in the development of survey instruments so that they would be easier to complete, with questions revised for clarity and to obtain more accurate data. One of the reasons a sampling procedure is utilized is to provide additional report monitoring by SEFSC logbook staff. Consequently, the response rate and quality should be maximized by close interactions with fishermen. Renewal of permits will be delayed to insure compliance.

4. Describe any tests of procedures or methods to be undertaken. Tests are encouraged as effective means to refine collections, but if ten or more test respondents are involved OMB must give prior approval.

Because of the large universe and the anticipated variation it is not feasible to do a test with fewer than 10. However, interaction with and feedback from the fishermen that are using the forms will provide sufficient information about the forms and collection procedures to make whatever adjustments are needed. The SEFSC evaluates the data collection programs internally every year and makes minor adjustments to the reporting forms, instructions, database design, scanning and processing procedures, and the quality control procedures Furthermore, analyses of the data will provide information about the variations in the data to determine whether the strata and sample sizes are appropriate.

5. Provide the name and telephone number of individuals consulted on the statistical aspects of the design, and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

Dr. Christopher Liese, NMFS industry economist, identified the sampling universe to be studied and prepared the sampling design. Data will be collected in conjunction with the existing logbook data collection program, which is conducted from the NMFS Southeast Fisheries Science Center in Miami, Florida. Data will be used primarily in analyses of proposed regulations by NMFS, the South Atlantic Fishery Management Council, and the Gulf of Mexico Fishery Management Council.

The following Southeast Fisheries Science Center staffs also were consulted on the statistical aspects of this data collection activity:

Dr. David Gloeckner, chief of the Fisheries Monitoring Branch, is responsible for some of these data collection activities: (305) 361-4257.

Dr. Matthew McPherson, chief of the Social Science Research Group, is responsible for some of these data collection activities: (305) 365-4112.

Dr. David Gloeckner, acting chief of the Fisheries Statistics Division: (305)361-4257.

1 1981 Presidential requirement for cabinet-level Departments to conduct a benefit-cost analysis for major changes in rules.

16