0648-0401 Supporting Statement A

SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic & Atmospheric Administration

Alaska American Fisheries Act Reports

OMB Control No. 0648-0401

Abstract

The National Marine Fisheries Service (NMFS), Alaska Regional Office (AKRO), requests extension of this currently approved information collection.

This information collection contains the annual and periodic reporting requirements for AFA cooperatives. These requirements include reports about on-going fishing operations of the cooperatives and reports specifically focused on efforts to minimize salmon bycatch in the Bering Sea pollock fishery.

This information is used to manage the Bering Sea pollock fishery, to evaluate the salmon bycatch management measures, and to provide the public with information about how the program operates and information about bycatch reduction under this program. This information collection provides the Council and NMFS with information about the organization and fishing operations of the AFA cooperatives, allocations to the AFA cooperatives, and the effectiveness of the Chinook salmon and chum salmon bycatch management measures. This information is necessary to ensure long-term conservation and abundance of salmon and pollock, maintain a healthy marine ecosystem, and provide maximum benefit to fishermen and communities that depend on salmon and pollock.

No changes or were made to this collection.

Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

NMFS AKRO manages the groundfish fisheries of the Bering Sea and Aleutian Islands (BSAI) Management Area in the Exclusive Economic Zone off Alaska. The North Pacific Fishery Management Council (Council) prepared the Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area (FMP) under the authority of the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act) and other applicable laws. Regulations implementing the FMP are at 50 CFR part 679.

The Bering Sea pollock fishery is managed under the American Fisheries Act (AFA). The AFA was signed into law in October 1998. The purpose of the AFA was to tighten U.S. ownership standards for U.S. fishing vessels under the Anti-reflagging Act and to provide the Bering Sea pollock fleet the opportunity to conduct its fishery in a more rational manner while protecting non-AFA participants in the other fisheries. The AFA established sector allocations in the Bering Sea pollock fishery, determined eligible vessels and processors, allowed the formation of cooperatives, set limits on the participation of AFA vessels in other fisheries, and imposed special catch weighing and monitoring requirements on AFA vessels.

Ten cooperatives were developed as a result of the AFA: seven inshore cooperatives, two offshore cooperatives, and one mothership cooperative. In recent years, two of the inshore cooperatives have consolidated to operate as a single cooperative. Therefore, six inshore cooperatives are actively participating in the Bering Sea pollock fishery. The two offshore cooperatives are Pollock Conservation Cooperative (PCC) representing offshore catcher/processors and High Seas Catcher Vessel Cooperative (HSCC) representing catcher vessels that traditionally delivered to catcher/processors. PCC and HSCC join together to submit a single AFA cooperative report, so they are considered a single cooperative for purposes of respondents in this information collection. Mothership Fleet Cooperative (MFC) represents catcher vessels that deliver to motherships. This brings the total number of active AFA cooperatives for purposes of this information collection to eight.

More information on the AFA Program is on the NMFS AKRO website at https://www.fisheries.noaa.gov/alaska/sustainable-fisheries/american-fisheries-act-pollock-fisheries-management-alaska.

This information collection contains the annual and periodic reporting requirements for AFA cooperatives. These requirements include reports about on-going fishing operations of the cooperatives and reports specifically focused on efforts to minimize salmon bycatch in the Bering Sea pollock fishery. These reporting requirements are located at 50 CFR 679.21 and 679.61.

This information is used to manage the Bering Sea pollock fishery, to evaluate the salmon bycatch management measures, and to provide the public with information about how the program operates and information about bycatch reduction under this program. This information collection provides the Council and NMFS with information about the organization and fishing operations of the AFA cooperatives, allocations to the AFA cooperatives, and the effectiveness of the Chinook salmon and chum salmon bycatch management measures. This information is necessary to ensure long-term conservation and abundance of salmon and pollock, maintain a healthy marine ecosystem, and provide maximum benefit to fishermen and communities that depend on salmon and pollock.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

This information collection contains the components listed in the table below. There are no forms associated with this information collection. The information is usually submitted in a report or letter, and in an oral presentation to the Council.

Requirement	Regulation 50 CFR	Who submits the information?	How Frequently?	How submitted?	Who is it submitted to?
Requirements Related to On-going Operations of the Cooperatives
AFA Cooperative Contract	§ 679.61(d) and (e)	AFA Cooperative representative	annually	Mail, courier, or email	Council and NMFS
AFA Annual Cooperative Report	§ 679.61(f)	AFA Cooperative representative	annually	Mail, courier, or email; and voluntary oral report to the Council	Council
Requirements Related to Minimizing Salmon Bycatch
Incentive Plan Agreement (IPA)	§ 679.21(f)(12)	IPA representative	Once, then amended as needed	Mail, courier, or email	NMFS
Administrative appeals to disapproved IPA	§ 679.21(f)(12)	IPA representative	As needed	Mail, courier, or fax	NMFS
IPA Annual Report	§ 679.21(f)(13)	IPA representative	annually	Mail, courier, or email; and voluntary oral report to the Council	Council

Dissemination of Information

This 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 (the Information Quality Act), which requires NMFS to ensure the quality, objectivity, utility, and integrity of information it publicly disseminates. Public dissemination of data collected by this information collection is governed by NOAA's information quality guidelines, which were issued on October 30, 2014.

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NMFS and the National Appeals Office 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 Question 10 of this Supporting Statement for more information on confidentiality and privacy. See Question 16 of this Supporting Statement for information from this collection that is posted on the Council and NMFS websites.

Changes to this Collection Since the Last Extension

This information collection has been changed once since the last extension. In 2019, OMB approved a revision to this collection to remove the AFA inshore cooperative weekly catch report from this information collection. This report was no longer needed because NMFS obtains the necessary information through its catch accounting system and through data collected by observers under the North Pacific Observer Program. Removing this reporting requirement reduced costs for the public and for NMFS to process this report.

Sections a and b, below, present the information collection requirements related to the formation and on-going operations of the AFA cooperatives.

1. AFA Cooperative Contract

Any fishery cooperative formed under section 1 of the Fisherman’s Collective Marketing Act 1934 (15 U.S.C. 521) (FCMA) for the purpose of cooperatively managing directed fishing for Bering Sea subarea pollock must submit to NMFS an annual cooperative contract. The AFA cooperatives that meet this requirement are the MFC, the catcher/processor sector cooperative consisting of PCC and HSCC, and the six permitted AFA inshore cooperatives, for a total of eight respondents.

Annually, each AFA cooperative must file with the Council and NMFS—

• a signed copy of its fishery cooperative contract;

• any material modifications to the cooperative contract;

• a copy of a letter from a party to the contract requesting a business review letter on the fishery cooperative from the Department of Justice; and

• any response to such letter of request.

The Council and NMFS will make this information available to the public upon request.

The requirement to submit information about the cooperative contract was included by Congress in section 201(a)(1)(A) of the AFA and further defined in regulations at 50 CFR 679.61(d) and (e). The purpose of this requirement is to provide the public, Council, and NMFS with information about the organization and fishing operations of the AFA cooperatives. Making this information public provides transparency about the AFA cooperatives.

If the cooperative contract was previously filed with NMFS and the Council, a renewal letter may be submitted to NMFS and the Council by the filing deadline in lieu of the cooperative contract and business review letter. The renewal letter must provide notice that the previously filed cooperative contract will remain in effect for the subsequent fishing year. The renewal letter also must detail any material modifications to the cooperative contract that have been made since the last filing including, but not limited to, any changes in cooperative membership.

The cooperative contract or renewal letter and the required supporting materials are submitted to NMFS and the Council by mail, courier, or email and must be received at least 30 days prior to the start of any fishing activity conducted under the terms of the contract. In addition, an inshore cooperative that is also applying for an allocation of Bering Sea subarea pollock under 50 CFR 679.62 must file its contract, any amendments hereto, and supporting materials no later than December 1 of the year prior to the year in which fishing under the contract will occur.

The AFA cooperative contract must include the following information:

Requirements for all fishery cooperatives.

List parties to the contract.

List all vessels and processors that will harvest and process pollock harvested under the cooperative.

Specify the amount or percentage of pollock allocated to each party to the contract.

Specify a designated representative and agent for service of process.

Include a contract clause under which the parties to the contract agree to make payments to the State of Alaska for any pollock harvested in the directed pollock fishery that are not landed in the State of Alaska, in amounts which would otherwise accrue had the pollock been landed in the State of Alaska subject to any landing taxes established under Alaska law. Failure to include such a contract clause or for such amounts to be paid will result in a revocation of the authority to form fishery cooperatives under section 1 of the Fisherman’s Collective Marketing Act of June 25, 1934 (15 U.S.C. 521 et seq.).

Obligations of AFA cooperative members to ensure full payment of cost recovery fees

Additional required elements in all fishery cooperatives that include AFA catcher vessels

Adequate provisions to prevent each non-exempt member catcher vessel from exceeding an individual vessel sideboard limit for each BSAI or Gulf of Alaska sideboard species or species group that is issued to the vessel by the cooperative in accordance with the following formula:

The aggregate individual vessel sideboard limits issued to all member vessels in a cooperative must not exceed the aggregate contributions of each member vessel towards the overall groundfish sideboard amount as calculated by NMFS under § 679.64(b) and as announced to the cooperative by the Regional Administrator, or

In the case of two or more cooperatives that have entered into an inter-cooperative agreement, the aggregate individual vessel sideboard limits issued to all member vessels subject to the inter-cooperative agreement must not exceed the aggregate contributions of each member vessel towards the overall groundfish sideboard amount as calculated by NMFS under § 679.64(b) and as announced by the Regional Administrator.

The inshore cooperatives file a copy of their contract or the renewal letter with their AFA inshore cooperative permit application (approved under OMB collection 0648-0393). NMFS does not process the inshore cooperative permit application unless it has received a copy of the contract or renewal letter.

2. AFA Annual Cooperative Report

The AFA annual cooperative reports are required to provide information about how each cooperative allocated pollock, other groundfish species, and prohibited species among the vessels in the cooperative; the catch of these species by area by each vessel in the cooperative; information about how the cooperative monitored fishing by its members; and a description of any actions taken by the cooperative to penalize vessels that exceeded the catch and prohibited species catch allocations made to the vessel by the cooperative. The purpose of the reports is to provide the Council with information about the on-going operations and performance of the cooperatives on which to base its decisions about management of the Bering Sea pollock fishery.

Each AFA cooperative must submit a final AFA annual cooperative report on fishing activity to the Council. The report must be postmarked or received by the Council by April 1 of the following year. The reports are almost always submitted by email. The report is also provided voluntarily to the Council during its April meeting.

The AFA annual cooperative reports are posted on the Council’s website (https://www.npfmc.org/cooperative-reporting/) and are retained for historical purposes once removed from the website.

The AFA annual cooperative report must include the following information:

Cooperative’s allocated catch of pollock and sideboard species

Any sub-allocations of pollock and sideboard species made by the cooperative to individual vessels on vessel-by-vessel basis

Cooperative’s actual retained and discarded catch of pollock, sideboard species, and PSC on an area-by-area basis and on a vessel-by-vessel basis

Method used to monitor fisheries in which cooperative vessels participated.

Actions taken in response to any vessels that exceed their allowed catch and bycatch in pollock and all sideboard fisheries.

Total weight of pollock landed outside the State of Alaska on a vessel-by-vessel basis

Number of salmon taken by species and season

List each vessel's number of appearances on the weekly “dirty 20” lists for non-Chinook salmon

Sections c through e, below, present the information collection requirements related to minimizing salmon bycatch in the Bering Sea pollock fishery.

3. Incentive Plan Agreement (IPA)

An IPA is an industry-developed contractual agreement that establishes an incentive program to minimize Chinook salmon and chum salmon bycatch at all levels of salmon abundance. Participation in an IPA is voluntary; however, any vessel or Western Alaska Community Development Quota Program (CDQ) group that chooses not to participate in an IPA is subject to a restrictive opt-out allocation (also called a backstop cap).

Since 2010, three NMFS-approved IPAs have been in place: the Chinook Salmon Bycatch Reduction Incentive Plan and Agreement, the Mothership Salmon Savings Incentive Plan Agreement, and the Inshore Chinook Salmon Savings Incentive Plan Agreement. These IPAs include all participants in the Bering Sea pollock fishery. As all of the AFA and CDQ participants are part of an IPA, currently no new IPAs are expected.

The current, approved IPAs are posted on the NMFS AKR website at https://www.fisheries.noaa.gov/alaska/bycatch/chinook-salmon-bycatch-management-alaska.

An amendment to an approved IPA may be submitted at any time. However, once a member of an IPA, a vessel owner or CDQ group cannot withdraw from the IPA during the fishing year.

The IPA representative submits the proposed amended IPA to NMFS either electronically or by mail. Amendments to an IPA must include the identification number that was assigned by NMFS when it approved the IPA.

An amendment to an approved IPA is effective upon written notification of approval by NMFS to the IPA representative. Once approved, an IPA is effective until December 31 of the first year in which it is effective or until December 31 of the year in which the IPA representative notifies NMFS in writing that the IPA is no longer in effect, whichever is later.

An IPA must include an affidavit affirming that each eligible vessel owner or CDQ group, from whom the IPA representative received written notification requesting to join the IPA, has been allowed to join the IPA subject to the same terms and conditions that have been agreed on by, and are applicable to, all other parties to the IPA.

An IPA must identify at least one third party group. Third party groups include any organizations representing western Alaskans who depend on salmon and have an interest in salmon bycatch reduction but do not directly fish in a groundfish fishery.

An IPA must include the following information:

Affidavit

Name of the IPA

IPA representative name, telephone number, and email address

Third party group

Description of the IPA

Incentive(s) to ensure each vessel avoid Chinook salmon and chum salmon bycatch under any condition of pollock and Chinook salmon abundance in all years

How the incentives to avoid chum salmon do not increase Chinook salmon bycatch

Rewards for avoiding Chinook salmon and penalties for failure to avoid Chinook salmon at the vessel level

How IPA incentive measures will promote reductions in a vessel’s Chinook salmon and chum salmon bycatch rates relative to what would have occurred in absence of the incentive program

How the incentive measures in the IPA promote Chinook salmon savings and chum salmon savings in any condition of pollock abundance or Chinook salmon abundance in a manner that is expected to influence operational decisions by vessel operators to avoid Chinook salmon and chum salmon

How the IPA ensures that the operator of each vessel governed by the IPA will manage that vessel’s Chinook salmon bycatch to keep total bycatch below the performance standard for the sector in which the vessel participates

How the IPA ensures that the operator of each vessel governed by the IPA will manage that vessel’s chum salmon bycatch to avoid areas and times where the chum salmon are likely to return to western Alaska

A rolling hot spot program for salmon bycatch avoidance that operates throughout the entire A and B seasons and an agreement to provide notifications of closure areas and any violations of the rolling hot spot program to the third party organization representing western Alaskans who depend on salmon and do not directly fish in a groundfish fishery.

Restrictions or penalties targeted at vessels that consistently have significantly higher Chinook salmon PSC rates relative to other vessels fishing at the same time.

Require vessels to enter a fishery‐wide in‐season salmon prohibited species catch data sharing agreement

Require use of salmon excluder devices, with recognition of contingencies, from January 20 to March 31, and from September 1 until the end of the B season

Require for savings-credit-based IPAs that the salmon savings credits last for a maximum of three years.

Restrictions or performance criteria used to ensure that Chinook salmon PSC rates in October are not significantly higher than those achieved in the preceding months.

Compliance agreement.

IPA must include written statement that all IPA parties agree to comply with all provisions of IPA.

Signatures.

The names and signatures of the owner or representative for each vessel and CDQ group that is a party to the IPA. The representative of an inshore cooperative, or the representative of the entity formed to represent the AFA catcher/processor sector or the AFA mothership sector may sign a proposed IPA on behalf of all vessels that are members of that inshore cooperative or sector level entity

4. Administrative Appeals to Disapproved IPA

An IPA representative who receives an IAD disapproving a proposed IPA may appeal under the procedures set forth at 50 CFR 679.43. If the IPA representative fails to file an appeal of the IAD pursuant to § 679.43, the IAD will become the final agency action. If the IAD is appealed and the final agency action is a determination to approve the proposed IPA, then the IPA will be effective as described in 50 CFR 679.21(f)(12)(iv)(B).

5. IPA Annual Report

The IPA annual report is the primary tool through which the Council evaluates the effectiveness of IPAs in reducing Chinook salmon and chum salmon bycatch in the Bering Sea pollock fishery. Information gathered through the annual reports is necessary for the Council to evaluate the salmon bycatch management measures and to provide the public with information about how the program operates and information about bycatch reduction under this program.

The IPA representative must submit an IPA annual report to the Council. The IPA annual report must be received by the Council no later than March 15. The reports are almost always submitted by email. The report is also provided voluntarily to the Council during its April meeting.

The IPA annual reports are posted on the Council’s website (https://www.npfmc.org/cooperative-reporting/) and are retained for historical purposes once removed from the website.

The IPA annual report must include the following information:

Incentive measures in effect in the previous year, including rolling hot spot program and salmon excluder use

How incentive measures affected individual vessels

Were incentive measures effective in achieving salmon savings beyond levels that would have been achieved in absence of the measures, including effectiveness of the following:

Measures to ensure that chum salmon were avoided in areas and at times when chum salmon return to western Alaska

Restrictions or penalties that target vessels that consistently have significantly higher Chinook salmon PSC rates relative to other vessels

Restrictions or performance criteria used to ensure that Chinook PSC rates in October are not significantly higher than in previous months.

Amendments to the IPA terms that were approved by NMFS since the last annual report and the reasons that the amendments to the IPA were made

Sub-allocation to each participating vessel of the number of Chinook salmon PSC and amount of pollock (mt) at the start of each fishing season,

Number of Chinook salmon PSC and amount of pollock (mt) caught at the end of each season.

In-season transfer of Chinook salmon PSC and pollock among AFA cooperatives, entities eligible to receive Chinook salmon PSC allocations, or CDQ groups

Date of transfer

Name of transferor

Name of transferee

Number of Chinook salmon PSC transferred

Amount of pollock (mt) transferred

In-season transfers among vessels participating in the IPA

Date of transfer

Name of transferor

Name of transferee

Number of Chinook salmon PSC transferred

Amount pollock (mt) transferred

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

All of the collections may be submitted by email except for administrative appeals. Administrative appeals cannot be submitted electronically because the National Appeals Office requires submission of documents by fax, mail, or delivery to provide the appropriate record for legal proceedings.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Question 2.

Some of the information reporting requirements in this collection require industry members to report to NMFS or the Council about the catch and bycatch by individual vessels in a cooperative. This information is available to NMFS through data collected by the observers on these vessels and through the catch and production reports submitted by vessel operators. However, some of the vessel specific information requirements are specifically included in the American Fisheries Act, and others were implemented by the Council to require cooperative members to report vessel specific information to the Council and public that would be difficult for NMFS to report directly due to confidentiality considerations.

These reports are intended to be a resource for the Council to track the effectiveness of the cooperative and their ability to meet the Council’s goals. Additionally, they are a tool for the cooperatives to provide feedback on the programs. Regulation provides a framework for the minimum required information for most of the reports, while the Council has the flexibility to augment this framework with additional information requests that may be pertinent to current issues in the fishery.

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

None of the entities that participate in the AFA pollock fisheries are considered small entities due to cooperative affiliation.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

This information collection is required to manage commercial fishing efforts under section 201(a)(1)(A) of the AFA, under the Magnuson-Stevens Act (16 U.S.C. 1801, et seq.), and under 50 CFR part 679. This collection provides the Council and NMFS with information about the organization and fishing operations of the AFA cooperatives, allocations to the AFA cooperatives, and the effectiveness of the Chinook salmon and chum salmon bycatch management measures. This information is necessary to ensure long-term conservation and abundance of salmon and pollock, maintain a healthy marine ecosystem, and provide maximum benefit to fishermen and communities that depend on salmon and pollock. It would not be possible to carry out the mandates of the AFA and the Magnuson-Stevens Act if approval to continue this previously approved collection were denied.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.

This collection is conducted in a manner that is consistent with OMB guidelines.

8. If applicable, provide a copy and identify the date and page number of publications in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A Federal Register Notice published on October 21, 2020 (85 FR 66956), that solicited public comments. No comments were received. In addition to the Federal Register notice, NMFS contacted representatives of the cooperatives to request comments on the information collection requirements. One response was received of no comments at this time.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift is provided under this program.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

All information collections by NMFS AKRO are protected under confidentiality provisions of section 402(b) of the Magnuson-Stevens Act and under NOAA Administrative Order 216-100, which sets forth procedures to protect confidentiality of fishery statistics. None of the information submitted under this information collection contains confidential business information. Personally identifiable information and confidential business information submitted in an administrative appeal are not released to the public.

The System of Records Notice that covers this information collection is COMMERCE/NOAA-19, Permits and Registrations for United States Federally Regulated Fisheries. A notice was published in the Federal Register on August 7, 2015 (80 FR 47457), and became effective September 15, 2015 (80 FR 55327).

The Privacy Impact Assessment that covers this information collection is NOAA NMFS Alaska Region Local Area Network (NOAA4700).

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

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

12. Provide estimates of the hour burden of the collection of information.

Information Collection	Type of Respondent (e.g., Occupational Title)	# of Respondents/year (a)	Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Burden Hrs / Response (d)	Total Annual Burden Hrs (e) = (c) x (d)	Hourly Wage Rate1 (for Type of Respondent) (f)	Total Annual Wage Burden Costs (g) = (e) x (f)
AFA Cooperative Contract	Cooperative representative	8	1	8	8 hours	64	$75	4,800
AFA Annual Cooperative Report	Cooperative representative	8	1	8	16 hours	128	$75	9,600
Incentive Plan Agreement (IPA)	IPA representative	12	1	1	50 hours	50	$165	8,250
Administrative appeals to disapproved IPA	IPA representative	13	1	1	4 hours	4	$165	660
IPA Annual Report	IPA representative	3	1	3	80 hours	240	$165	39,600
Totals				21		486		$62,910

¹ NMFS has used these wage rate estimates for this information collection and updates and revises them when public comment supports doing so.

² One amended IPA was submitted in 2019, and none were submitted in 2018 or 2020. In the next three years, we do not expect revisions to the Bering Sea salmon bycatch management measures that will require the IPAs to be amended. As no new IPAs are currently expected, we estimate that we may receive one amended IPA per year over the next three years; therefore, one respondent is used for this analysis.

³ Since 2015, no IPAs or amended IPAs have been disapproved by NMFS, and no appeals have been filed. For purposes of this analysis, one response is used.

.

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

Information Collection	# of Respondents/year (a)	Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Cost Burden / Respondent1 (h)	Total Annual Cost Burden (i) = (c) x (h)
AFA Cooperative Contract	8	1	8	Operating costs - $5	40
AFA Annual Cooperative Report	8	1	8	Operating costs - $5	40
Incentive Plan Agreement (IPA)	1	1	1	Operating costs - $5	5
Administrative appeals to disapproved IPA	1	1	1	Operating costs - $5 Attorney - $5002	505
IPA Annual Report	3	1	3	Operating costs - $5	15
TOTALS	11		21		$605

¹ Operating costs account for the typical inclusive general office services packages that include expenses for email, fax, copying, mailing, printing, and internet.

² Attorney cost is included to reflect the assumption that most people would hire an attorney to prepare an appeal ($125/hour x 4 hours).

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

There are no costs to the government for the AFA Annual Cooperative Report or the IPA Annual Report because these are submitted to the Council.

There are no estimated costs to the Federal government for the AFA Cooperative Contract because the costs associated with processing and filing the inshore cooperative contracts are included in the Federal government time and cost estimates for the AFA inshore cooperative permit application approved under 0648-0393, and the costs of filing the information received annually from the other two respondents (PCC and HSCC, which file jointly, and MFC) are negligible.

Cost Descriptions	Grade/Step	Loaded Salary /Cost	% of Effort	Fringe (if Applicable)	Total Cost to Government
Federal Oversight
Other Federal Positions
Fisheries Program Specialist	GS 12 step 9	169,545	0.1%		162
Appeals Attorney	GS 14 step 10	242,115	0.2%		464
Contractor Cost					—
Travel					—
Other Costs:					—
TOTAL					$626

GS 12 step 9 2021 salary (capped out ZP-3 in Juneau, AK) = $111,543. For loaded salary, add 52% of salary ($111,543 * 1.52 = $169,545). The approximate hourly loaded wage rate for fisheries program specialist is $81 ($169,545 / 2,087 hours in a Federal work year).

To calculate percent of effort: 2 hrs / 2,087 hrs = 0.00095 or about 0.1% of effort.

Total cost to government = $81 x 2 hrs = $162.

GS 14 step 10 2021 salary for Silver Spring = $159,286. For loaded salary, add 52% for benefits and other overhead costs ($159,286 * 1.52 = $242,115). The hourly loaded wage rate for attorneys handling appeals is $116 ($242,115 / 2,087 hrs in a Federal work year).  

To calculate percent of effort: 4 hrs / 2,087 hrs = 0.0019 or 0.2% of effort.

Total cost to government = $116 x 4 hrs = $464. 

15. Explain the reasons for any program changes or adjustments reported in ROCIS.

Information Collection	Respondents		Responses		Burden Hours		Reason for change or adjustment
	Current Renewal / Revision	Previous Renewal / Revision	Current Renewal / Revision	Previous Renewal / Revision	Current Renewal / Revision	Previous Renewal / Revision
AFA Cooperative Contract	8	8	8	8	64	64	No changes
AFA Annual Cooperative Report	8	8	8	8	128	128	No changes
Incentive Plan Agreement (IPA)	1	1	1	1	50	50	No changes
Administrative appeals to disapproved IPA	1	1	1	1	4	4	No changes
IPA Annual Report	3	3	3	3	240	240	No changes
Total for Collection	11*	8	21	21	486	486
Difference	3		0		0

* The total number of respondents for the collection has been corrected to 11. The previous supporting summary counted the three IPA respondents as part of the group of eight AFA respondents, and they are not the same respondents.

Information Collection	Labor Costs		Miscellaneous Costs		Reason for change or adjustment
	Current	Previous	Current	Previous
AFA Cooperative Contract	4,800	4,800	40	24	Misc. costs: Revised amount to account for typical inclusive general office services packages.
AFA Annual Cooperative Report	9,600	9,600	40	15	Misc. costs: Revised amount to account for typical inclusive general office services packages.
Incentive Plan Agreement (IPA)	8,250	8,250	5	1	Misc. costs: Revised amount to account for typical inclusive general office services packages.
Administrative appeals to disapproved IPA	660	148	505	502	Labor costs: The previous supporting statement used the wrong labor rate. The rate was corrected to match the rate used for the IPA and IPA Annual Report. Misc. costs: Revised amount to account for typical inclusive general office services packages.
IPA Annual Report	39,600	39,600	15	15	The miscellaneous costs were revised to account for typical inclusive general office services packages, but this resulted in no difference from the previous costs.
Total for Collection	$62,910	$62,398	605	557
Difference	512		48

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

At this time, no analyses are in development or are planned for future development that are anticipated to affect this existing information collection

AFA cooperative contracts are available to the public on request.

The AFA annual cooperative reports and the IPA annual reports are posted on the Council’s website at https://www.npfmc.org/cooperative-reporting/.

Proposed and approved IPAs and renewal letters are posted on the NMFS Alaska Region website at https://www.fisheries.noaa.gov/alaska/bycatch/chinook-salmon-bycatch-management-alaska.

Final administrative appeal decisions with redactions are posted on the NMFS National Appeals Office website (https://www.fisheries.noaa.gov/about/office-management-budget). Personally identifiable information and confidential business information submitted in an administrative appeal are not released to the public.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

There are no forms associated with this information collection. The information is submitted in a report or letter, and no specific format is required.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions."

The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

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