0648-0620 Supporting Statement A_BL41

SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic & Atmospheric Administration

Pacific Coast Groundfish Trawl Rationalization Program

Permit and License Information Collection

OMB Control No. 0648-0620

Introduction

This request is for revision and extension of a current information collection pursuant to proposed rule 0648-BL41 to incorporate form modifications to reflect the adoption of the following council adopted preferred alternatives:

1. Move the season start date for the primary whiting season start date north of 40 degrees 30 minutes north latitude from May 15th to May 1st.  Move all administrative deadlines associated with the season start date to 45 days prior to May 1. 

2. Remove the mothership processor obligation deadline from regulation.

3. Remove the mothership processor cap from regulation.

4. Allow a vessel to be registered to a mothership and catcher-processor endorsed permit in the same year, with unlimited transfers.

The trawl rationalization program was implemented in January 2011 and continues to operate consistent with regulations given at 50 CFR 660. Since that time, the Council and NMFS have been addressing implementation issues as they arise, through the public Council process.

Under the trawl rationalization program, new permits, accounts, endorsements, and licenses were established. These consist of: QS permits/accounts, vessel accounts, FRSLs, MS endorsements on certain limited entry trawl permits, MS/CV endorsements on certain limited entry trawl permits, C/P endorsements on certain limited entry trawl permits, one or more MS coop permits, and a C/P coop permit.

NMFS collects information from program participants required to: establish new permits, accounts, and licenses; renew permits, accounts, and licenses; allow trading of QS percentages and QP in online QS and vessel accounts and allow transfer of catch history assignments between limited entry trawl permits; track compliance with program control limits; and implement other features of the regulations pertaining to permits and licenses.

In conjunction with the proposed rule 0648-BL41, NMFS is removing a few reporting requirements for trawl fishery participants. This is because these reporting requirements only exist to allow administration and enforcement of regulatory provisions that are being proposed to be eliminated. The revisions include removing the requirement for mothership permit holders to submit an ownership identification form when they annually renew the permit (a reduction of 6 respondents, the form remains for other participant types). Additionally, NMFS is removing the mutual agreement exception collection and the processor obligation collection for the Mothership sector, as they are no longer needed due to the changes proposed in 0648-BL41 that remove the requirement for catcher vessels in the mothership sector to obligate to a mothership processor.

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.

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), 16 U.S.C. 1801 et seq., authorizes Fishery Management Councils to prepare and amend fishery management plans (FMP) for any fishery in waters under its jurisdiction. The National Oceanic and Atmospheric Administration (NOAA) National Marine Fisheries Service (NMFS) manages the groundfish fishery in the Exclusive Economic Zone (EEZ), the area 3-200 miles off the coasts of Washington, Oregon, and California.

The Pacific Fishery Management Council (Council) began developing a trawl rationalization program, a catch share program, for the Pacific coast groundfish limited entry trawl fishery in 2003. The Council developed and NMFS approved the trawl rationalization program with the intent to increase net economic benefit to the nation and to provide participants with economic stability in the fishery, full utilization of the trawl sector allocation, improved safety, improved product quality and value, increased accuracy, and mitigated or decreased environmental impacts than occurred under previous fishing practices and regimes.

The Council established the trawl rationalization program through two amendments to the Pacific Coast Groundfish FMP: Amendment 20, which established the trawl rationalization program, and Amendment 21, which set formal intersector allocations of groundfish species. The Council took final action on Amendment 20 at their November 2008 meeting, with subsequent related actions at the March 2009, April 2009, June 2009, November 2009, and April 2010 meetings. The Council took final action on Amendment 21 at their April 2009 meeting, with trailing actions at the March 2010 meeting.

NMFS implemented the program in January 2011 as a limited access privilege program (LAPP) under the MSA, as reauthorized in 2007. An LAPP is considered a grant of permission to the holder of the limited access privilege to participate in the program. The privilege may be revoked, limited, or modified by the Secretary of Commerce at any time. In other words, under this program, catch shares are a conditional privilege to harvest a specified amount of fish. NMFS issued permits, as described below, for this conditional privilege.

The trawl rationalization program is composed of three sectors, as follows: 1) the shorebased individual fishing quota (IFQ) sector, 2) the at-sea whiting mothership (MS) sector, and 3) the at-sea whiting catcher/processor (C/P) sector. The shorebased IFQ sector consists of quota share (QS) permit owners, catcher vessels that are registered to limited entry trawl permits, have vessel accounts, and fish for quota pounds (QP), and first receiver site license (FRSL) holders who receive the shorebased IFQ landings. The at-sea trawl fleets catch and process Pacific whiting (whiting) with midwater trawl gear. In the MS sector, mothership catcher vessels (MS/CVs) harvest the whiting and deliver the catch to large MS vessels, where it is sorted and processed at-sea. One or more MS coops may form and/or vessels may choose to fish in a non-cooperative fishery. For both the coop and non-coop fishery, vessels pool their harvest together. In the C/P sector, C/P vessels catch and process whiting at-sea under a single C/P coop.

Sector Descriptions

In the shorebased IFQ sector, QS permit owners hold percentages, or shares, for each of 30 IFQ species groups. Each year, based on the shorebased IFQ sector allocation, NMFS allocates QPs to QS accounts in proportion to each QS permit owner's QS percentages. The permit owner must then move these QP to a vessel account in order for the QP to be fished. The QS permit/account is like an investment account where the QP accrue, while a vessel account is like a checking account, where the QP can be "spent", or used to offset IFQ catch (landed or discarded). Any participant who owns a vessel and registers it to a trawl limited entry permit (LEP) can request a vessel account and fish in the IFQ program; they do not need to also own a QS permit. Vessel account owners can buy QP from any QS permit owner or any other vessel account. Likewise, QS permit owners do not need to also own a vessel to hold QS. They can sell all of their QP without fishing them.

Vessels fishing in the shorebased IFQ program must have a human observer or electronic monitoring cameras installed on board to monitor catch and account for discards. IFQ vessels must deliver landings to a buyer with a FRSL, and a catch monitor (CM) must be present for the offload to monitor sorting and independently account for landings. All three reports (discards, landings recorded by the first receiver, and landings recorded by the CM) are submitted to the online vessel account system, and are debited from the vessel account. Typically, the first receiver and CM will record the same landed values, but if there is a discrepancy, the higher value is debited until the discrepancy can be resolved and updated. All fish caught in the IFQ program (landings and discards) are counted against the vessel account, and vessel owners must obtain QP to cover all catch. Vessels that incur a deficit cannot fish in the IFQ program until the deficit is cured, and the deficit must be cured within 30 days to avoid a violation.

In order to comply with the MSA, NMFS tracks the ownership interest (OI) of all entities who own a QS permit/account or a vessel account. QS permit owners are held to set accumulation and control limits, both at the initial allocation stage and during the operation of the program, and vessel owners must comply with vessel limits for each account. These ownership and control limits were adopted by the Council as part of Amendment 20.

In the MS sector, MS/CVs were allocated catch shares of whiting, called catch history assignments (CHA), which were attributed to qualifying limited entry trawl permits based on MS/CV at-sea whiting delivery history in the qualifying years. These limited entry trawl permits were issued an MS/CV endorsement and individual catch history assignment, expressed as a percentage. MS/CV-endorsed LEP owners may choose to participate in the coop or non-coop fishery. The whiting associated with the CHA on the MS/CV-endorsed LEP is caught by catcher vessels registered to trawl LEPs, and landed at-sea to vessels registered to MS permits. As with the shorebased IFQ sector, NMFS tracks the OI of all entities who own an MS/CV-endorsed trawl LEP or MS permit.

In the C/P sector, NMFS did not make an allocation of catch shares to the individual vessels. Instead, the C/P coop receives a total allocation of Pacific whiting and other non-whiting groundfish species, and organizes independently as a cooperative to harvest the allocation.

Rulemakings that have Affected the Collection of Information

NMFS implemented the trawl rationalization program through two initial sets of rulemakings. NMFS published the initial issuance portion of the final rule 0648-AY68 on October 1, 2010 (75 FR 60868). This rule restructured and clarified the Pacific coast groundfish regulations to more closely track the organization of the management measures that establish the allocations and procedures set forth under Amendment 21 for initial issuance of permits, endorsements, quota shares, and catch history assignments under the IFQ and coop programs. NMFS published the program components portion of the final rule 0648-AY68 on December 15, 2010 (75 FR 78344) to implement the key components of the trawl rationalization program for the start of the 2011 fishery. The key components included: IFQ gear switching, observer programs, retention requirements, equipment requirements, CMs, catch weighing requirements, coop permits, coop agreement requirements, FRSL, QS accounts, vessel accounts, further tracking and monitoring components, and economic data collection (EDC) requirements. Most of the information collections under OMB Control No. 0648-0620 stemmed from this rulemaking.

Since the initial implementation of the trawl rationalization program in January 2011, the Council and NMFS have been addressing implementation issues as they develop; and trailing actions and subsequent rulemakings have revised or added to the program. NMFS published the program improvement and enhancement (PIE) 1 final rule on December 1, 2011 (76 FR 74725). This rulemaking included an FMP amendment to further revise Amendment 21 (Amendment 21–1). Regulatory revisions included: the Pacific halibut trawl bycatch mortality limit; clarification that Amendment 21 supersedes limited entry/open access allocations for certain groundfish species; revisions to the observer coverage requirement while a vessel is in port and before the offload is complete; revisions to the electronic fish ticket reporting requirements; revisions to the FRSL requirement; further clarification on moving between limited entry and open access fisheries; a process for end-of-the-year vessel account reconciliation; and an exemption from processing at sea for qualified participants in the shorebased IFQ program.

With the PIE 1 rulemaking, NMFS requested a revision to OMB Control No. 0648-0620, which was approved without change on December 2, 2011. The collection revision included a change to the definition of a first receiver under the IFQ program, and therefore a change to the pool of applicants, and updated the application requirements for FRSL holders to exclude the unnecessary request for a site inspection. NMFS removed account managers from QS and vessel accounts/applications, and clarified regulations to explain what would constitute a change in ownership for QS permit and vessel account owners. In addition, a new provision allowed permit owners to request a change in the registration of the MS/CV endorsement and associated CHA from one trawl LEP to another (termed severability in Council documents) and clarified MS/CV-endorsed permit combinations, which resulted in a new collection to document these registration changes. This new provision also affected the MS coop permit application collection, because a permit owner could now have multiple, distinct MS/CV endorsements and associated CHA amounts registered to one trawl LEP and must obligate each separately. The updated form provided a new space for applicants to designate the specific MS/CV endorsements and associated CHA amounts separately.

NMFS requested a non-substantive change to OMB Control No. 0648-0620, which was approved without change on February 15, 2012, and did not align or result from any rulemakings. The collection was changed to include a required form for vessel account registration, in contrast to the previously optional form. This helped to standardize the information NMFS received from new vessel account applicants. The non-substantive change also added a small business certification section to the existing trawl OI form and FRSL form, in order to assist with Regulatory Impact Reviews (RIR)/Initial Regulatory Flexibility Analysis (IRFA) for the trawl rationalization program.

Two additional rulemakings, referred to as Reconsideration of Allocation of Whiting (RAW), Rules 1 and 2 (RAW 1 and RAW 2, respectively), were the outcome of a lawsuit, Pacific Dawn v. Bryson, No. C10-4829 TEH (N.D. Cal.) (Pacific Dawn), which challenged the initial allocations of whiting under the trawl rationalization program. NMFS published the RAW 1 final rule on August 1, 2012 (77 FR 45508). This was a temporary, emergency action rule, which delayed transfers of QS between QS permits/accounts and delayed the change in the registration of the MS/CV endorsements and associated CHAs from one trawl LEP to another (severability). The rule also delayed divestiture requirements, and modified issuance provisions for QP for the beginning of the 2013 fishing year to preserve NMFS’ ability to deposit the appropriate final amounts into IFQ accounts based on any recalculation of QS allocations. The emergency action rule was extended on January 17, 2013 (78 FR 3848).

NMFS published the RAW 2 final rule on March 28, 2013 (78 FR 18879). After reviewing the entire record, including the Council’s record and comments received on the proposed rule (78 FR 72), NMFS determined that the existing initial whiting allocations provided for a fair and equitable allocation and were consistent with the MSA, the Pacific Coast Groundfish FMP, the court’s order in Pacific Dawn, and other applicable law. The final rule did not make any changes to initial allocations but did revise several provisions of the trawl rationalization program and supersede regulatory delays and/or revisions established through temporary emergency action and extension. Changes in the final rule included: transfer of QS or individual bycatch quota (IBQ) (except for widow rockfish QS) between QS permit holders in the shorebased IFQ fishery beginning January 1, 2014; a requirement that QS permit holders in the shorebased IFQ fishery holding QS or IBQ in excess of the accumulation limits divest themselves of excess QS (except for widow rockfish QS) or IBQ by November 30, 2015; limited entry trawl permit holders in the MS fishery to request a change (or transfer) of MS/CV-endorsement and CHA beginning September 1, 2014; a requirement that MS/CV-endorsed trawl LEP owners divest themselves of ownership in permits in excess of the accumulation limits by August 31, 2016; and extension of the divestiture period delay and moratorium on transfer of widow rockfish QS in the shorebased IFQ fishery indefinitely. These rulemakings did not affect or change the previously approved collections under OMB Control No. 0648-0620, but instead further delayed QS transfer and change of registration for MS/CV endorsement and associated catch history assignment.

At its April 2012 meeting, the Council took final action to refine the trawl rationalization program, resulting in a second program improvement and enhancement (PIE 2) rulemaking, 0648-BD31 (78 FR 68764). The rule implemented specific QS permit application and QS transfer regulations, clarified exemptions for lenders from control rules, eliminated the double-filing of coop reports for the at-sea whiting coops, revised FRSL requirements, including site inspection and expiration date, removed the year-end ban on QP transfers between vessel accounts, and clarified that the MS/CV processor obligation could be to more than one MS permit. With the PIE 2 rulemaking, NMFS requested an extension and revision to OMB Control No. 0648-0620, which was approved without change on November 15, 2013. The collection revision included items that had always been in the collection but were not fully developed under the initial program, such as QS permit applications and QS transfers.

At its April 2015 meeting, the Council took final action for the IFQ sector to clarify revocation protocols for cases where QS permit owners who exceeded an accumulation limit did not voluntarily divest to these limits by the November 30, 2015 divestiture deadline. As part of this action, the Council identified a situation where QS permit owners who were over the aggregate non-whiting control limit (a limit for the total amount of QS that can be owned across IFQ species) may not be able to find a willing recipient to take their excess QS. The Council recommended that QS permit owners in this situation could abandon unwanted excess QS to NMFS if they were unable to find another recipient. In order to implement this and other provisions relating to divestiture, NMFS published the divestiture rule, 0648-BF11 (80 FR 69138), allowing a process by which QS permit owners over the aggregate limit could abandon excess shares to NMFS by November 1, 2015 or, in 2016 and beyond, within 90 days if found to exceed the limit after the divestiture deadline. With the divestiture rulemaking, NMFS requested a revision to OMB Control No. 0648-0620 to add an abandonment form, which was approved without change on November 12, 2015.

At its November 2018 meeting, the Council took final action to recommend setting an accumulation limit on the number of C/P endorsed permits to a maximum of five permits that any one individual or entity may own. This accumulation limit would only take effect in the event the current cooperative structure for the sector dissolves. Currently owners of shorebased IFQ and Mothership vessel categories are required to provide ownership interest information when applying for or renewing permits. This information is not collected for C/P permit owners under the current C/P coop structure. The recommended action would create similar collection of ownership information requirements for C/P permit owners that would take effect January 1, 2020.

At its March 2022 meeting, the Council took final action for the purpose of increasing utilization of available MS quota that has previously been unrealized. This objective was accomplished by adopting the following preferred alternatives:

1. Move the season start date for the primary whiting season start date north of 40 degrees 30 minutes north latitude from May 15th to May 1st.  Move all administrative deadlines associated with the season start date to 45 days prior to May 1. 

2. Remove the mothership processor obligation deadline from regulation.

3. Remove the mothership processor cap from regulation.

4. Allow a vessel to be registered to a mothership and catcher-processor endorsed permit in the same year, with unlimited transfers.

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.

Each collection item below is numbered, and the number corresponds to the burden estimate table under Question 12.

(1) QS Permit/Account Application Form

This form must be submitted on paper, by mail, one time, by new QS permit applicants who want to own QS in the shorebased IFQ fishery. The applicant will also be required to submit a trawl identification of OI form, which is described separately (see #10). For each approved application, NMFS will mail a QS permit with zero QS for each species and will establish an associated online QS account (also with zero QS for each species). Initial QS permit owners were allocated percentages of each IFQ species group based on their catch history during the qualifying period, but new entrants receive zero starting QS on their permits and in their QS accounts, and must to obtain QS percentages from other existing QS permit owners by transferring QS percentages through the QS account. The purpose for the information collection is to gather name and contact information for new entities, include the name and contact information on the physical QS permit, and to verify that the entity is eligible to own a QS permit as outlined in regulation and as certified on their application. NMFS expects an average of 1 new applicants each year.

(2) QS Permit/Account Renewal - Online

This pre-filled form will be submitted online once annually by current QS permit owners who wish to renew their QS permit for the following year. The QS permit owner will be required to make any changes necessary to their contact information. The applicant will also be required to review their pre-filled OI form as part of the online renewal, which is described separately (see #11). The purpose of the renewal is to maintain current QS permit owner contact information and retain only the pool of permit owners who actively own shares and participate in the IFQ program. NMFS expects an average of 181 online QS permit renewals annually.

Since QS permits and the QPs allocated to renewed permits have high value, NMFS expects all QS permit owners to have significant incentive to renew during the renewal period (October 1 –

November 30, online only). Although we expect all QS permit owners to renew online in order to receive their QP allocation for the year, we wanted to build in the possibility that, especially with new QS permit entrants, we might not always see 100% of the renewals submitted on time (see #3).

(3) QS Permit/Account Renewal Form

Each year QS permit owners are responsible for renewing their QS permit and account online through their QS account during the renewal period, October 1 – November 30 (see #2). The online account renewal portal was set up to service the majority of renewals during the renewal period and does not appear in accounts outside of the renewal period. Those permit owners who do not renew their QS permit during the renewal period will have their account inactivated by NMFS at the end of the calendar year, and NMFS will not issue QP to the inactive QS account associated with the non-renewed QS permit for that year. Additionally, QS permit owners with non-renewed permits/accounts are not able to transfer their QS percentages.

NMFS allows QS permit owners who did not renew their QS permit/account during the online renewal period (October 1 – November 30) to renew by paper, using the QS permit/account renewal form. Although QS permit owners who renew their permits outside of the online renewal period will not be issued any QP to their QS account for the remainder of the calendar year, submitting this paper application form would reactivate their QS account and allow them to transfer QS percentages once their permit is renewed. Because NMFS anticipates so few renewals outside of the renewal period, and because there is a high cost associated with creating an online renewal option outside of the renewal period, a paper form is a simple alternative.

This QS permit/account renewal form will be submitted on paper, by mail, one time, by QS permit renewal applicants who failed to renew on time, but who want the ability to transfer QS percentages. The applicant will also be required to submit a trawl identification of OI form, which is described separately (see #11). The purpose for the information collection is the same as the online renewal (see #2): to maintain current QS permit owner contact information and retain only the pool of permit owners who actively own shares and participate in the IFQ program. NMFS estimates that at most, only 1 QS permit owner will complete this form per year because the QP allocated to renewed permit owners has such high value, and because NMFS has seen such high compliance with QS permit renewals in the past.

(4) QS Transfer

QS permit owners own QS percentages (divisible to the thousandth of a percentage, 0.001%) for 30 IFQ species groups. Initially, these percentages were not transferrable, in order to allow the participants a few years to gain greater understanding and confidence with the new program. Beginning in January 2014, QS permit owners have been able to permanently transfer those QS percentages to other QS permit owners (either existing owners or new entrants) from January 1 to November 30 each year through their online QS account, with the exception of widow rockfish QS, for which QS transfers have been postponed indefinitely. QS transfers must be initiated by the transferor and accepted by the transferee to be finalized. QP associated with the QS being transferred will not be part of the QS transfer. QS transfers are completely separate from QP transfers. QS can only be transferred between QS accounts, and not to vessel accounts, while QP can only be transferred from QS accounts to vessel accounts, and between vessel accounts.

NMFS allocates QP throughout the year and will allocate QP based on the QS percentages listed on a renewed QS permit. For example, if a QS permit owner started the year with 3.000% of a certain species and transferred 1.000% to another QS permit owner in that year, s/he would continue to be allocated QP based on the 3.000% until the start of the following year. Essentially, QS permit owners can transfer QS at any time and as many times and in as many increments as they want between January 1 and November 30. Whatever remains in their QS account on November 30 at midnight will be printed on their renewed permit for the following year. NMFS will allocate QP for the remainder of the following year based on the QS percentages given on the QS permit.

To initiate a QS transfer, the user must log in to the QS account associated with their QS permit, preview their current QS percent ownership, select the species and amount of QS% to transfer, indicate the nature of the transaction (i.e., cash sale, barter), provide the overall cost for the transaction, and select the QS permit/account to transfer to, up to the accumulation limits of the receiving QS permit/account. The cost information collected helps NMFS to understand the nature of the QS sale and relative price information. The burden estimate in Question 12 includes both the time for the transferor to initiate the transfer, and the time for the receiving party to review and accept the QS transfer in their QS account. NMFS programmed the QS percentage transfer functionality in online QS accounts so that QS permit owners could trade all species in a single transaction, reducing the burden for those participants who do wish to transfer more than one species in a single transaction.

The ability to transfer QS is an important component of the program, allowing NMFS to implement the program as intended by the Council and industry, and allowing for new entrants and a changing fishery. The transfer of QS also allows for individual business flexibility and allows QS permit owners to shape their business strategies through a portfolio of QS. In 2014, there were 14 QS transfers total. In 2015, there were 69 QS transfers, largely because one QS permit owner didn’t understand they could transfer all 30 species on one transfer, and transferred each species separately. From 2017–2019 there were 10, 13, and 10 QS transfers, respectively, however, in 2020 and 2021 there was only one transfer each year, this could potentially be related to the COVID-19 pandemic. Based on these numbers, NMFS estimates that there will be an average of 1 QS transfer per year. This is a user-controlled voluntary function so there will be variability and given the widespread changes in the industry caused by the COVID-19 pandemic, it may be difficult to predict going forward what the QS transfer amount will be.

(5) QP Transfer from QS Account to Vessel Account

The QP transfer function from QS account to vessel account will be completed online approximately five times each year by QS permit owners who are moving QP from their QS account to a vessel account (average of 181 QS permit owners x 3.81 QP transfers = 690 responses per year). Because NMFS allocates pounds to QS accounts at different times throughout the calendar year, the QS permit owner must login to their QS account several times per year to move the QP to a vessel account. While some QS owners may wait until the spring when most QP has been allocated to the shorebased IFQ sector to transfer their QP to vessel accounts (decreasing the average number of transfers), others may make QP transfers to multiple vessels directly from their QS accounts (increasing the average number of transfers).

To initiate a QP transfer from a QS account, the user must log in to the QS account associated with their QS permit, preview their current available QP, enter the species and amount of QP to transfer (in pounds), indicate the nature of the transaction (i.e., cash sale, barter), provide the overall cost for the transaction, and select the vessel account to transfer to (up to the vessel limits of the receiving vessel account). The cost information collected helps NMFS to understand the nature of the QP sale and relative price information. The burden estimate in Question 12 also includes the time for the receiving party to review and accept the QP transfer in their vessel account. QP transfer functionality is an important accounting tool for both NMFS and industry. The QS account system provides accurate balances of QPs available for use (to transfer to a vessel account) in real time, and documents the initiation and acceptance of individual QP transfer transactions. Currently, users may print the transfer summary PDFs in their accounts to demonstrate a transfer has been made to brokers or receiving parties.

(6) Vessel Account Registration Request

This form will be submitted on paper, by mail, one time, by new vessel account applicants who own a vessel registered to a trawl LEP, and want to harvest or hold QP in the shorebased IFQ fishery. The applicant will also be required to submit a trawl identification of OI form, which is described separately (see #10). For each approved vessel account registration request, NMFS will establish a vessel account with zero QP for each species, and the vessel owner will obtain QP from a QS permit owner’s QS account or other vessel account. The purpose for the information collection is to gather name and contact information for new entities, and to correctly establish the vessel name/number and vessel owner name on the account for correct catch accounting by first receivers, CMs, and observers in the shorebased IFQ fishery. NMFS expects, on average, to have about 3 new applicants each year.

(7) Vessel Account Renewal – Online

This pre-filled form will be submitted online once annually by current vessel account owners who wish to renew their vessel account for the following year. The vessel account owner will be required to make any changes necessary to their contact information on the renewal form. The applicant will also be required to review their pre-filled OI form as part of the online renewal, which is described separately (see #11). The purpose of the renewal is to maintain current vessel owner contact information and retain only the pool of vessel owners who actively participate in the IFQ program. NMFS expects an average of 144 online vessel account renewals annually.

There are currently 150 active, renewed vessel accounts. While new applicants may request a registration at any time (see #6), NMFS expects this number to remain fairly constant, as we’ve seen throughout the past 6 years. While we do receive approximately 10 new vessel registration requests per year, those are often to replace existing accounts, or based on the sale of an active vessel to a new owner, so about the same number of accounts exists from year to year.

Since these vessel owners that renew their accounts can fish in the shorebased IFQ fishery at the start of the year and may receive carryover of any surplus pounds from the previous year, NMFS expects vessel account owners to have significant incentive to renew during the renewal period (October 1 – November 30, online only) if they intend to continue their participation in the program. If for any reason they don’t renew online during the renewal period, vessel owners can renew their vessel account by paper after the renewal period (see #8). In past years, we have seen an average of 6 vessel owners not renew their account online, but instead renew after the renewal deadline by paper, which is why we expect 144 (not 150) online renewals.

(8) Vessel Account Renewal Form

Each year vessel account owners are responsible for renewing their vessel account online through their vessel account during the renewal period, October 1 – November 30 (see #7). The online account renewal portal was set up to service the majority of renewals during the renewal period and does not appear in accounts outside of the renewal period. Those account owners who do not renew their vessel account during the renewal period will have their account inactivated by NMFS at the end of the calendar year, cannot fish in the shorebased IFQ fishery, cannot transfer QP (except in the case of a deficit), and will not be issued any carryover of surplus QP from the previous year, if eligible.

NMFS allows vessel account owners who did not renew their vessel account during the online period (October 1 – November 30) to renew by paper, on the vessel account renewal form. Although vessel account owners who renew their accounts outside of the online renewal period are not issued any carryover of surplus QP from the previous year, submittal (and NMFS acceptance) of this paper renewal form would reactivate their account and allow them to fish in the shorebased IFQ fishery and transfer QP. Because NMFS anticipates so few renewals outside of the renewal period, and because there is a high cost associated with creating an online renewal option outside of the renewal period, a paper form is a simple alternative.

This vessel account renewal form will be submitted on paper, by mail, one time, by vessel account renewal applicants who failed to renew online on time, but who want the ability to fish in the shorebased IFQ fishery and transfer QP. NMFS estimates that at most, 6 vessel account owners will complete this form per year because we expect so many to renew on time online, and because we have seen high compliance with vessel account renewals in the past. This estimate is based on the average number of vessel owners who have renewed their account by mail after the renewal period in previous years. The vessel account owner would also be required to submit a trawl identification of OI form, which is described separately (see #11). The purpose for the information collection is the same as the online renewal (see #7): to maintain current vessel owner contact information and retain only the pool of vessel owners who actively participate in the IFQ program.

(9) QP Transfer from Vessel Account to Vessel Account

The QP transfer function allows vessel owners to transfer QPs online from their vessel account to another vessel account. Based on actual vessel account transfer activity during the first five years of the program, NMFS estimates that vessel account owners will average 11 transfers of QP from their vessel account to another vessel account each year (average of 88 vessel account owners x 11 transfers of QP = 968 responses per year). Many vessel owners do not make any QP transfers to other vessel accounts during the year, but others, such as vessel accounts being used for risk pool and broker purposes, make many. To initiate a QP transfer from a vessel account, the user will login to their vessel account, preview their current available QP, enter the species and amount of QP to transfer (in pounds), indicate the nature of the transaction (i.e., cash sale, barter), provide the overall cost for the transaction, and select the vessel account to transfer to (up to the vessel limits of the receiving vessel account). The cost information collected helps NMFS to understand the nature of the QP sale and relative price information. The burden estimate in question 12 also includes the time for the receiving party to review and accept the QP transfer in their vessel account.

QP transfer functionality is an important accounting tool for both NMFS and industry. The vessel account system provides accurate balances of QPs available for use (to cover catch or to transfer) in real time, and documents the initiation and acceptance of individual QP transfer transactions. Currently, users may print the transfer summary PDFs in their accounts to demonstrate a transfer has been made to brokers or receiving parties.

(10) Trawl Identification of Ownership Interest Form: New Entrants

This form is identical to the form used under collection #11 below, however new entrants will likely take longer to complete the form since it will not be pre-filled for them, and it will be their first time completing the form, so we separated the collections. This form will be submitted on paper, by mail, one time, by an estimated 24 respondents each year, including:

• 8 new QS permit applicants (trawl identification of ownership form submitted with collection #1),

• 10 new vessel account registrants (trawl identification of ownership form submitted with collection #6),

• 1 applicant who plans to purchase an existing trawl LEP with MS/CV endorsement/CHA (trawl identification of ownership form submitted with change in permit ownership form for the trawl LEP, collected under OMB Control No. 0648-0203), or who owns a trawl permit and plans to purchase an existing MS/CV endorsement/CHA to register to their trawl permit (trawl identification of ownership form submitted with collection #17),

• 1 lender (trawl identification of ownership form submitted with letter of intent to collateralize assets under the trawl rationalization program, and therefore be exempt from accumulation and control limits).

• 3 C/P endorsed permit owners (change). Prior to January 1, 2020, C/P endorsed permit owners were not required to complete the trawl identification of ownership interest form. There are currently three fishing companies that own the ten existing C/P permits. Since none of these owners have completed the form previously, it is expected that the first instance of completing the form will require more time than in subsequent years. Since 2011, only two C/P endorsed permits have changed ownership, once in 2013 and once in 2019. As a result, subsequent years are likely to have fewer than one new change in C/P permit ownership.

The trawl identification of OI form is collected from new entrants to verify their eligibility to participate in the program, to monitor compliance with accumulation and control limits in the IFQ and MS programs, and to gather small business information to assist with RIR/IRFA for new rulemakings. In the previous submissions of this collection, we have required this form be notarized, but are removing that requirement with this extension to minimize reporting burden. This requirement has been removed for vessels registered exclusively as MS participants with proposed rule 0648-BL41.

(11) Trawl Identification of Ownership Interest Form: Renewal

This form is identical to the form used under collection #10 above, however NMFS separated the collections because the forms are pre-filled for renewals and take significantly less time to complete, on average. For renewals where there has been no change to the OI, most applicants (QS permit and vessel account owners) will submit this form online, while some MS/CV-endorsed LEP owners, and lenders will be sent a pre-filled paper form if they do not also own a QS permit or vessel account where they can approve the OI online. This is a change from our previous collection, because we used to require all MS/CV and MS permit owners to complete a paper form, even if they completed a form online through their QS or vessel account renewal, and now we have removed duplication. For any renewal where there was a change to the OI, the participant will need to complete a new form. We have factored the average response time for all response types into our estimated time burden of five minutes: (1) no change, review online; (2) no change, review on paper; and (3) with change, submit new paper form = [(356 respondents x 3 minutes) + (10 respondents x 10 minutes)] ÷ 368 total respondents = 3.2 (3) minutes/respondent.

This form will be submitted as a part of the renewal application by an estimated 368 respondents each year, including:

• 182 QS permit owners (trawl identification of ownership form submitted with collection #2 or #3),

• 150 vessel account owners (trawl identification of ownership form submitted with collection #7 or #8),

• 34 MS/CV-endorsed LEP owners (trawl identification of ownership form submitted with MS/CV-endorsed LEP renewal, collected under OMB Control No. 0648-0203),

• 2 lenders (trawl identification of ownership form submitted with letter of intent to have continued exemption from accumulation and control limits).

The trawl identification of OI form is collected during renewals to maintain verification of eligibility to participate in the program, to monitor compliance with accumulation and control limits, and to gather small business information to assist with RIR/IRFA for new rulemakings. In the previous submissions of this collection, we have required this form be notarized, but are removing that requirement with this extension to minimize reporting burden. Additionally, this reporting requirement is being completely removed for vessels exclusively registered as a MS.

(12) First Receiver Site License Application Form: New Entrants

This form is identical to the form used under collection #13 below, however, NMFS separated the collections because initial applicants have an increased burden estimate when compared to re-registering applicants. A first receiver is a person or company who receives, purchases, or takes custody, control, or possession of catch onshore from a vessel that harvested fish under the IFQ program. All buyers must hold a FRSL for each physical landing site in order to receive a landing of IFQ species. A single company may have multiple landing sites, each of which requires its own license. This form will be submitted online by new first receiver applicants who want to receive shorebased IFQ landings from vessels with IFQ vessel accounts. NMFS estimates about 2 responses per year, based on new applications submitted during the first five years of the program.

In addition to the application form, the applicant will also be required to submit an application fee, a copy of their current state buyer's license for the state in which the license will be held, and a catch monitor plan (CMP), which will be followed by a site visit. All of these application requirements are included in the burden estimate. The CMP is the most time-consuming component of the application, because it requires a write-up of the operations of the receiving facility, including information on offloading, sorting, weighing, and labeling catch, as well as information for CM safety. NMFS provides guidelines and a template for the CMP to each applicant to ease some of the time burden. The CM coordinator also visits the site for approximately one hour, but longer if necessary, to ensure that the CMP accurately represents the receiving process in the facility. After a site inspection, the applicant may be required to revise their CMP.

The information on the FRSL application form is collected to gather name and contact information for new FRSL holders, name and contact information at the physical site listed on the license to ensure that the name on the application matches the name on the fish tickets for accounting and enforcement purposes, and to register the name and contact information on the physical FRSL. The application fee is collected to cover costs associated with processing FRSLs, as calculated in the unit cost computation. The copy of the state buyer's license is collected in order to ensure that the first receiver is eligible to receive fish in that state, and is complying with state requirements.

(13) First Receiver Site License Application Form: Re-Registration

This form is identical to the form used under collection #12 above, however, NMFS separated the collections because the application process takes significantly less time to complete, on average, for re-registering applicants. This form will be submitted online once yearly by each first receiver applicant who wants to re-register their existing FRSL in order to continue receiving shorebased IFQ landings from vessels with IFQ vessel accounts. NMFS estimates about 41 responses per year, based on the current number of FRSL holders and re-registrations submitted during the first five years of the program.

The re-registering applicant will also be required to submit an application fee, a copy of their current state buyer's license for the state in which the license will be held, and a CMP. A site inspection will only be required once every three years in order to reduce the burden for re-registering applicants (site inspections were required every year when the program started, but NMFS relaxed the requirement through the PIE 2 rulemaking). All of these application requirements are included in the burden estimate. For re-registering applicants, the CMP takes less time to submit (as compared to new entrants) because they have their plan from the previous year saved. The first receiver simply needs to update any information that has changed, and resubmit.

The information on the FRSL application form is collected to maintain name and contact information for new first receivers, and to be able to include the name and updated contact information on the physical FRSL. NMFS requires re-registration in order to ensure the pool of participants are still actively participating and complying with program requirements. The application fee is collected to cover costs associated with processing FRSLs, as calculated in the unit cost computation. The copy of the state buyer's license is collected in order to ensure that the first receiver is still eligible to receive fish in that state, and is complying with state requirements. The CMP is required as part of the collection to ensure that every IFQ species is accurately sorted and counted to a vessel account under the IFQ program, and that the site follows proper safety procedures while a CM is present. Re-registering applicants must submit the CMP each year to recertify that the plan is accurate, and in order to submit any changes to the operating procedures, if applicable.

(14) Mothership Permit Renewal Form

Each year MS permit owners are responsible for renewing their MS permit during the renewal period, October 1 – November 30. MS permit owners must submit the renewal application online with the renewal fee. This revision removes the requirement for these permit owners to submit a completed trawl identification of OI form (see #11), which is pre-filled and sent to MS permit owners with their renewal package (only if they do not also own a QS permit or vessel account through which they can certify their OI online). There are 6 MS permit owners, and no new MS permits will be given since this is an LEP. NMFS anticipates that all 6 will submit their renewal application each year, based on previous behavior and because of the extremely high value of the permits and the business arrangements associated with the MS permits/vessels registered to the permits in the MS coop. This is a limited entry fishery, and no new MS permits/applications will be allowed. New entrants may become MS permit owners only by transferring an existing permit (see #15). The purpose for the information collection is to maintain current MS permit owner contact information. Ownership information is no longer required.

(15) Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form

If an MS permit owner would like to change the vessel registered to their MS permit, change the permit owner on their MS permit, or notify NMFS of a change in vessel owner of the vessel registered to their MS permit, they must submit the MS permit change of vessel registration, permit owner, or vessel owner application form on paper, by mail. This form can be submitted at any time during the calendar year. NMFS anticipates a maximum of 1 MS transfer per year, based on permit transfers in the first five years of the program.

The purpose for this collection of information is to gather accurate information about the MS permit ownership and the vessel registered to the permit. The form provides formal certification and documentation of the request and allows NMFS to review the request for compliance with permit regulations.

(16) Mothership Cooperative Permit Application Form

The MS coop permit application form may be completed by one or more MS coops, or not at all if a coop doesn't organize in a given year. For the first five years of the program, there has been a single coop with all MS/CV-endorsed LEP owners given as members, with no non-coop fishery. For the purposes of this collection, NMFS estimates that there will be 1 coop completing this form per year.

The MS coop permit application must be completed by the coop manager, and is submitted on paper, by mail. A complete application includes the MS coop permit application form and a copy of the MS coop agreement. Additionally, the MS coop must provide an annual coop report. Through the application form, the MS coop identifies their members (MS/CV-endorsed LEP owners), the individual CHAs associated with each MS/CV-endorsed permit and to which MS permit the CHAs are obligated, the total CHA for the coop, and the vessels that will harvest the whiting as part of the coop. The MS coop agreement provides further detail about the terms and conditions agreed to by coop members, and how the allocation of whiting to the MS sector will be fished. The annual coop report details the status of the MS coop fishery during the prior year.

This annual collection provides NMFS the information necessary to allocate whiting and bycatch to the MS sector. Whether there is a single coop, multiple coops, and/or a coop and non-coop fishery in a given year, the MS coop permit application provides the formal process to convey the structure of the at-sea MS sector, and therefore determines the allocation mechanism.

(17) Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form

Since 2014, MS/CV endorsements and their associated CHA are severable from a limited entry trawl permit, and eligible to be registered to any other limited entry trawl permit, up to the accumulation limits. If an MS/CV-endorsed LEP owner would like to change the registration of the MS/CV endorsement and associated CHA to another limited entry trawl permit, they must submit the MS/CV-endorsement and CHA registration application form on paper, by mail. This form can be submitted during the registration period, September 1 – December 31 each year. If a new entrant obtains an MS/CV endorsement and CHA, they must submit this form with a trawl identification of OI form (#11) to verify ownership of the permit to which the endorsement and CHA will be registered. NMFS estimates 1 MS/CV-endorsement/CHA transfer per year, based on the number of transfers we’ve seen since 2014.

The purpose for this collection of information is to allow the transfer of MS/CV endorsements and CHA among limited entry trawl permits, and to gather accurate information about MS/CV-endorsed permit ownership. The form provides formal certification and documentation of the request by the permit owner (transferor) and allows NMFS to review the request for compliance with the accumulation limits and with other permit regulations.

As part of this revision, we are removing the following requirements as they are no longer necessary with the proposed changes to regulations governing the mothership fishery: the mutual agreement exception (18) and the mothership withdrawal (19).

(18) Catcher/Processor Cooperative Permit Application Form

The C/P coop permit application form must be submitted by the single C/P coop each year (one form submitted each year), so NMFS expects 1 response per year. The C/P coop permit application is completed by the coop manager, and is submitted on paper, by mail. A complete application includes the C/P coop permit application form and a copy of the C/P coop agreement. Additionally, the C/P coop must provide an annual coop report. The C/P coop identifies their members (owners of CP endorsed permits) through the application form, and provides further detail about the terms and conditions that coop members have through the C/P coop agreement. The annual coop report details the status of the C/P coop fishery during the prior year.

This annual collection provides NMFS the information necessary to allocate whiting and bycatch to the C/P sector, and allows for updated contact information to be printed on the permit. Failure to provide this information would require that NMFS to change the fishery from a coop based fishery to an IFQ fishery. In the previous submissions of this collection, we have required this form be notarized, but are removing that requirement with this extension to minimize reporting burden.

(19) Material Change

If there are any changes to a coop agreement, the coop manager of either an MS coop or a C/P coop must notify NMFS in writing of any material change to the coop agreement within seven calendar days of such changes. Within 30 calendar days, the designated coop manager must submit to NMFS a revised coop agreement with a latter that describes such changes. There is not a form for this collection, and NMFS estimates 1 response per year. NMFS will review the material changes and provide a response letter to the coop manager that either accepts the changes as given, or does not accept the revised coop agreement. If the changes are not accepted, the letter from NMFS will explain why. The coop will be required to resubmit the coop agreement with further revisions that respond to NMFS’ concerns. NMFS requires this notification because the coops serve to manage the harvest of whiting through a coop agreement with their members, and NMFS relies on the coops for effective management of the MS and C/P sectors. The coop agreement is the mechanism to effectively manage the fishing activities, including the monitoring and enforcement activities within the coop. Any changes must be provided to NMFS to ensure that the written agreement matches the practice of the coops.

(20) QS Abandonment Request

At the time of initial QS allocation in 2011, several eligible QS permit owners received QS percentages that exceeded the shorebased IFQ program’s accumulation limits. These permit owners were provided an adjustment period where they could continue to hold these excess shares, but were required to completely divest of QS in excess of the accumulation limits by November 30, 2015 (see 50 CFR 660.140 (d)(4)(v)). Through the divestiture rule, NMFS established an abandonment form where QS permit owners who exceeded the aggregate non-whiting control limit could permanently abandon shares of their choosing to NMFS. No one used the provision, and the divestiture period has ended, but NMFS kept this form in place (through the divestiture rule) should any QS permit owner be found to exceed the aggregate nonwhiting QS limit in 2016 or beyond.

Permit owners utilizing this provision in the future would submit a written request identifying their QS permit number, the IFQ species they wish to abandon, and the percentage of each species to abandon. NMFS will notify the permit owner that s/he has 90 days to divest of the QS in excess of the nonwhiting aggregate control limit. The permit owner may abandon QS to NMFS within 60 days of NMFS’ notification, by submitting the written request described above. According to NMFS OI records, no companies currently exceed the aggregate nonwhiting control limit, and the online IFQ system will prevent transfers that would exceed the limit, but should a QS permit owner acquire QS in excess of the aggregate limit by any other method, they may utilize the abandonment request option within 60 days of NMFS notification of the excess. NMFS has never encountered an abandonment request, but estimates 1 per year on the burden estimate table.

(21) Catch Monitoring Plans/ First Receivers – Preparation and Submission,

(22) Catch Monitoring Plans/ First Receivers – Inspection,

(23) Shorebased scales/ First Receivers – Inspection,

(24) Shorebased scales/ First Receivers – Reports

CMPs are prepared by the shorebased IFQ first receivers and submitted to annually to NMFS as part of the first receiver site license application (see collections #12 and #13 above). The CMP is required as part of the collection to ensure that CMs are onsite to observe and ensure that all catch is offloaded from a vessel, accurately sorted (by IFQ species or species groups), weighed, and debited to a vessel account under the IFQ program, and that the site follows proper safety procedures while a CM is present. Essentially, the CMP allows NMFS to understand the layout, delivery process, and sorting procedures at the given site before the CM arrives to work at the site. The CMP allows NMFS to determine the site safety and suitability for the CM, as verified at the site inspection prior to formal acceptance of a CMP.

During a first receiver site inspection, a catch monitor coordinator goes over the CMP with the site contact, provides any necessary notes, checks the scales and scale test dates, and answers questions from the first receivers. The catch monitor coordinator also updates the first receivers if there are new requirements for the year (e.g., sorting requirement changes, e-ticket submittal information, etc.) or if there are any issues that have occurred recently specific to that site.

Scales used to weigh fish at IFQ first receivers are subject to in-season scale testing and inspection by NMFS staff and NMFS-authorized personnel upon request. A scale that does not pass an in-season test may not be used to weigh IFQ fish until the scale passes an in-season test or is approved for continued use by the weights and measures authorities of the State in which the scale is located (see 50 CFR 660.15 (c)(4)(i)).

IFQ first receivers must ensure that scale reports (i.e., printouts of the scale weights) are made available to the catch monitor and, upon request, to NMFS. For scales used to weigh catch at IFQ first receivers, all scales identified in a CMP must produce a printed record for each delivery, or portion of a delivery, weighed on that scale, unless specifically exempted by NMFS (i.e., scales not designed for automatic bulk weighing may be exempted from part or all of the printed record requirements). A first receiver must maintain printed scale reports on site until the end of the fishing year during which the printouts were made and make them available upon request by NMFS for 3 years after the end of the fishing year during which the printout was made. See printed scale requirements for IFQ first receivers at 50 CFR 660.15 (c)(3)(i) and (ii).

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.

The collection involves the use of mostly online/electronic collection of information. The numbers used below corresponds to the collection in Question 2 and the burden estimate table under Question 12.

These collections are conducted online exclusively:

(2) QS Permit/Account Renewal – Online

(4) QS Transfer

(5) QP Transfer from QS Account to Vessel Account

(7) Vessel Account Renewal – Online

(9) QP Transfer from Vessel Account to Vessel Account

(12) First Receiver Site License Application Form: New Entrants

(13) First Receiver Site License Application Form: Re-Registration

(14) Mothership Permit Renewal Form

This collection is conducted mostly online, with a few paper submissions:

(11) Trawl Identification of Ownership Interest Form: Renewal

These collections are conducted by paper:

(1) QS Permit/Account Application Form

(3) QS Permit/Account Renewal Form – only necessary if the permit owner misses the 2-month online renewal period

(6) Vessel Account Registration Request

(8) Vessel Account Renewal Form – only necessary if the permit owner misses the 2-month online renewal period

(10) Trawl Identification of Ownership Interest Form: New Entrants

(15) Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form

(16) Mothership Cooperative Permit Application Form

(17) Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form

(18) Catcher/Processor Cooperative Permit Application Form

(19) Material Change

(20) QS Abandonment Request

(21) Catch Monitoring Plans/ First Receivers – Preparation and Submission

(22) Catch Monitoring Plans/ First Receivers – Inspection

(23) Shorebased scales/ First Receivers – Inspection

(24) Shorebased scales/ First Receivers – Reports

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

This is a unique information collection and does not duplicate other collections. The trawl rationalization program was developed by the Pacific Fishery Management Council and is unique to the commercial Pacific coast trawl fisheries. The program was, and continues to be, reviewed in many public meetings and is subject to public comment. The program and associated information collection is specific to a section of the Pacific coast commercial fishing industry. The information collected is required to implement and administer the program.

Additionally, NMFS strives to share the information internally to avoid duplication. Various internal NMFS groups such as the office of law enforcement (OLE), EDC team, the observer program, the CM program, etc. use the contact information collected by the Fisheries Permit Office as part of this collection, rather than collecting this information again.

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

Many of the respondents are small businesses. NMFS minimizes burden by having instant QS and QP transactions online, that do not involve mailing paperwork, and provides pre-filled forms wherever possible so that small business owners and others only need to correct information if something has changed rather than fill out the same information each time.

Wherever possible, NMFS tries to pair information collections (such as renewals and OI) to be mailed and due on the same date to minimize burden on affected entities.

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.

QS Permit/Account Application Form (1), QS Permit/Account Renewal - Online (2), QS Permit/Account Renewal Form (3), Vessel Account Registration Request (6), Vessel Account Renewal Form (7), Vessel Account Renewal – Online (8), Mothership Permit Renewal Form (14), First Receiver Site License Application Form: New Entrants (12), First Receiver Site License Application Form: Re-Registration (13)

Initial application information and annual renewal/re-registration information collection is necessary to confirm current address, contact and ownership information, and to maintain accurate registrations of the permits/licenses and/or accounts. If the collection is not conducted, or conducted less frequently, over time the permit information would become outdated. Often, permit and/or account owners will make a change to their entity name and forget to notify NMFS. The initial registration and subsequent renewal period has become the time to update all of our records and maintain a high quality of data. Many line offices rely on the contact information that the Fisheries Permit Office collects as a part of registrations/renewals, and less accurate or less frequent information collection would negatively impact other offices. NMFS strives to make significant outreach efforts and a high quality data set is essential to ensuring communication and compliance. Additionally, in the case of the FRSL, if the collection was not conducted or conducted less frequently, it would hinder NMFS' ability to effectively examine the safety of a site for a CM, and know where IFQ landings would occur.

Trawl Identification of Ownership Interest Form: New Entrants (10), Trawl Identification of Ownership Interest Form: Renewal (11)

OI forms must be submitted as part of the initial registrations and subsequent renewals listed above, as well as with initial registrations and renewals of MS/CV-endorsed LEPs (both of which are part of a separate collection, OMB Control No. 0620-0203). The OI information is collected to determine compliance with the accumulation limits. If NMFS was not able to conduct such collections, or to conduct such collections less frequently, NMFS would not be able to track changes in shareholders or shareholder OI amounts over time, and participants would have less motivation to stay within the accumulation limits. The accumulation limits are provided to meet the legal mandate under MSA, which requires that individuals and/or entities should not receive access to a disproportionate amount of the resource. It makes sense to collect this information in tandem with the annual renewals of permits/accounts because participants are accustomed to submitting information to NMFS at this time of year as part of renewals.

QS Transfer (4), QP Transfer from QS Account to Vessel Account (5), QP Transfer from Vessel Account to Vessel Account (9)

The transfer of assets (QS and QP) under the trawl rationalization program is important for business entities and the government. Collecting this information less frequently, by perhaps setting short periods during the year when these transfers could be made, would hinder the flexibility the shorebased trawl program intended to create for ease of business transactions. QS and vessel accounts function just like savings and checking accounts, and while these transfers are a collection of information by a Federal agency, they are also a necessary business function for fishing and purposes, just like the transfer of money between bank accounts. The QS/QP accounting system is critical to the execution of the fishery and the benefits of the trawl rationalization program cannot be realized without a real-time accounting system that allows for the transfer of QS and QP. Business owners need confirmation of transactions for their private business agreements, and NMFS needs the information to track in-season balances and compliance with regulations.

Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form (15), Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form (17)

Because permits and endorsements convey a conditional privilege given by NMFS, any transfer of such privilege to another permit owner or vessel owner must be formally registered with NMFS. Permit owner, vessel owner, vessel registration, and endorsement registration information is important in enforcing management regulations, providing authorized participants with notice of fishery information during the season, and providing analysts with high quality permit data.

Mothership Cooperative Permit Application Form (16), Catcher/Processor Cooperative Permit Application Form (18), Material Change (19)

The MS and C/P coops serve to manage the harvest of whiting through a coop agreement with all members, and NMFS relies on the coops for effective management of the at-sea sectors. The coop permits, and specifically the coop agreements that must be submitted with the coop permit applications, are the mechanism to effectively manage the fishing activities, including the monitoring and enforcement activities within the coop. Any changes must be provided to NMFS to ensure that the written agreement matches the practice of the coops. These collections are essential to managing the participants and any changes in the fishery. Any removal of these collections would result in an undocumented at-sea fishery, while any reduction of these collections would allow for a situation in which the information collected by NMFS may not match the practice in the coops.

QS Abandonment Request (20)

If this collection was not conducted, QS permit owners would not have as much flexibility for abandoning QS percentages in excess of the control limit for aggregate nonwhiting QS holdings, as provided for in regulation. This information collection is completely voluntary.

(21) Catch Monitoring Plans/ First Receivers - Preparation and Submission,

(22) Catch Monitoring Plans/ First Receivers – Inspection,

(23) Shorebased scales/ First Receivers – Inspection,

(24) Shorebased scales/ First Receivers – Reports

Data collected by certified observers and catch monitors are necessary for the conservation and management of the Pacific Coast groundfish fishery. Maintaining the integrity of the data collections is an important aspect of the trawl rationalization program and assuring that individual catch accountability is maintained. The trawl fishery is a multispecies fishery in which the allowable harvest levels for some stocks (potentially including overfished species) constrain access to harvest of the full allocations of many targeted stocks. If the integrity of the monitoring program is not maintained, the elimination of individual accountability could generate an incentive to alter fishing behavior such that vessels targeted stocks that are more difficult to catch without encountering high levels of constraining species. The high level of quality monitoring under the trawl rationalization program has helped the fleet make tremendous bycatch reductions.

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

This collection will be conducted in a manner 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 proposed rule, RIN 0648-BL41, will be published coincident with this submission. Comments on the proposed rule will be considered and, as appropriate, be addressed in the final rule.

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

No payments or gifts are provided under this program at this time.

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.

Some of the information collected above is confidential under section 402(b) of the MSA. It is also confidential under NOAA Administrative Order 216-100, Protection of Confidential Fisheries Statistics. NMFS 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.

All collections of phone numbers, fax numbers, and email addresses are not released to the public. Transfer amount and price, tax identification number (TIN), date of birth (DOB), the names of individuals who have an OI in an entity and the percentage of ownership, and cooperative agreements provided with coop permit applications are considered business confidential information. DOB is also protected under the Privacy Act. A statement of the confidentiality of this information is provided on each form.

The information collected is part of a Privacy Act System of Records (SORN), COMMERCE/NOAA #19, Permits and Registrations for United States Federally Regulated Fisheries. A notice was published in the Federal Register on April 17, 2008 (73 FR 20914) and became effective on June 11, 2008 (73 FR 33065). An amended SORN was published on August 7, 2015 (80 FR 47457) and became effective on September 15, 2015 (80 FR 55327).

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 require the submission of 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 Rate* (for Type of Respondent) (f)	Total Annual Wage Burden Costs (g) = (e) x (f)
1. QS Permit/Account Application Form (a)(b)	New QS Permit Applicants	1	1	1	20min	0.33	19.08	6.30
2. QS Permit/Account Renewal - Online (a)(d)	QS Permit Owners	181	1	181	10 min	30.17	19.08	575.64
3. QS Permit/Account Renewal Form (a)	QS Permit Owners	1	1	1	15 min	0.25	19.08	4.77
4. QS Transfer (d)(e)	QS Permit Owners	1	1	1	10 min	0.17	19.08	3.24
5. QP Transfer from QS Account to Vessel Account (d)(e)	QS Permit Owners	181	3.81	690	5 min	57.5	19.08	1,097.10
6. Vessel Account Registration Request (a)	New Vessel Account Applicants	3	1	3	15 min	0.75	19.08	14.31
7. Vessel Account Renewal - Online (a)(d)	Vessel Account Owners	144	1	144	10 min	24	19.08	457.92
8. Vessel Account Late Renewal Form (a)	Vessel Account Owners	6	1	6	15 min	1.5	19.08	28.62
9. QP Transfer from Vessel Account to Vessel Account (d)(e)	Vessel Account Owners	88	11	968	5 min	80.67	19.08	1,539.18
10. Trawl Identification of Ownership Interest Form: New Entrants	New QS Permit Applicants (8), New Vessel Account Applicants (10), New MS/CV-Endorsed LEP Owners (1), New MS Permit Owners (1), Lenders (1), C/P endorsed permit owners (3)	24	1	31 (there are three fishing companies that own the ten existing C/P permits, hence, 3 respondents, but 10 responses)	45 min	23.25	19.08	443.61
11. Trawl Identification of Ownership Interest Form: Renewal (c)	QS Permit Owners (182), Vessel Account Owners (150), MS/CV-Endorsed LEP Owners (34), MS Permit Owners (6), Lenders (2)	368	1	368	3.2 min	19.63	19.08	374.54
12. First Receiver Site License Application Form: New Entrants (f)	New First Receiver Site License (FRSL) Applicants	2	1	2	200 min	6.67	19.08	127.26
13. First Receiver Site License Application Form: Re-Registration (f)	FRSL Holders	41	1	41	100 min	68.33	19.08	1,303.74
14. Mothership Permit Renewal Form (c)	MS Permit Owners	6	1	6	10 min	1	19.08	19.08
15. Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form	MS Permit Owners	1	1	1	35 min	0.58	19.08	11.07
16. Mothership Cooperative Permit Application Form (g)	MS Coop Entity	1	1	1	230 min	3.83	19.08	73.08
17. Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form	MS/CV-Endorsed LEP Owners	1	1	1	35 min	0.58	19.08	11.07
18. Catcher/Processor Cooperative Permit Application Form (h)	C/P Coop Entity	1	1	1	110 min	1.83	19.08	34.92
19. Material Change (i)	MS Coop Entity, C/P Coop Entity	1	1	1	150 min	2.50	19.08	47.70
20. QS Abandonment Request	QS Permit Owners	1	1	1	10 min	0.17	19.08	3.24
21. Catch monitoring plans/ First receivers Preparation and Submission	New FFRSL Applicants and Current FRSL Holders	43 (same respondents as for 12 & 13)	1	43 (same responses as for 12 & 13)	Part of FRSL application (see 12 & 13)	-	19.08	0
22. Catch monitoring plans/ First receivers Inspection	New FFRSL Applicants and Current FRSL Holders	43 (same respondents as for 12 & 13)	1	43	120 min	86	19.08	1,640.88
23. Shorebased Scales/ First receivers Inspection	New FFRSL Applicants and Current FRSL Holders	43 (same respondents as for 12 & 13)	Variable	43	60 min	43	19.08	820.44
24. Shorebased Scales/ First receivers Reports	New FFRSL Applicants and Current FRSL Holders	43 (same respondents as for 12 & 13)	Variable	1,290	10 min	215	19.08	4,102.20
Totals		359 Unique		3,868		667.71	19.08	12,739.91

*Hourly rate based on 43-6010 Secretaries and Administrative Assistants. https://www.bls.gov/bls/blswage.htm

KEY
	- Paper form that is provided by NMFS
(a) - These collection types must be submitted with a trawl identification of OI form, but the burden estimates do not include the estimate for the trawl identification of OI form because it is listed separately.
(b) - This collection type includes new QS applicants and additional QS permit registrations required due to legal proceedings (i.e., death of a permit owner, permit conveyed to a beneficiary)
(c) - Online Optional
(d) - Online Only
(e) - Average time per response estimate includes the time required to initiate the transfer (transferor) and accept the transfer (transferee), as well as the time required to provide transaction price information.
(f) - Average time per response estimate includes the time required to prepare the CMP and the time for a designated contact person to be available for the site inspection. New applicants are required to have a site inspection before the license is issued. Re-registering FRSL sites are only required to have a site inspection once every three years.
(g) - Average time per response estimate includes the time required to complete the application form and submit supplemental documentation, including the mothership coop agreement and signatures from all coop members (36 total).
(h) - Average time per response estimate includes the time required to complete the application form and submit supplemental documentation, including the catcher/processor coop agreement and signatures from all coop members (10 total).
(i) - Average time per response estimate includes the time required to update the coop agreement and gather signatures from all coop members. We estimate that it would take the mothership coop about 4 hours on average and the catcher processor coop about 1 hour on average. We estimate one material change per year total and averaged the mothership and catcher processor time.
Note - The above time burden does not estimate the time required to report the dissolution of a cooperative. We anticipate that dissolution of a coop will be a very rare event, and if it occurs will require a short letter from the coop manager and/or members stating that the coop has dissolved as of a given date.

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).

The total estimated annual cost burden to the respondents or record-keepers resulting from this collection is $9,062.

Information Collection	# of Respondents/year (a)	Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Mailing Costs to Respondent (d)	Copy Costs to Respondent ($0.05/page) (e)	Application Fees (f)	Total Annual Cost Burden (h) = (c) x (d+e+f)
1. QS Permit/Account Application Form (a)(b)	1	1	1	$0.60	$0.15	$0.00	$0.75
2. QS Permit/Account Renewal - Online (a)(d)	181	1	181	$0.00	$0.05	$0.00	$9.05
3. QS Permit/Account Renewal Form (a)	1	1	1	$0.60	$0.05	$0.00	$0.65
4. QS Transfer (d)(e)	1	1	1	$0.00	$0.05	$0.00	$0.05
5. QP Transfer from QS Account to Vessel Account (d)(e)	181	3.81	690	$0.00	$0.05	$0.00	$34.50
6. Vessel Account Registration Request (a)	3	1	3	$0.60	$0.05	$0.00	$1.95
7. Vessel Account Renewal - Online (a)(d)	144	1	144	$0.00	$0.05	$0.00	$7.20
8. Vessel Account Late Renewal Form (a)	6	1	6	$0.60	$0.05	$0.00	$3.90
9. QP Transfer from Vessel Account to Vessel Account (d)(e)	88	11	968	$0.00	$0.05	$0.00	$48.40
10. Trawl Identification of Ownership Interest Form: New Entrants	24	1	31	Included With Other Applicable Forms	$0.35	$0.00	$10.85
11. Trawl Identification of Ownership Interest Form: Renewal (c)	368	1	368	Included With Other Applicable Forms	$0.35	$0.00	$128.80
12. First Receiver Site License Application Form: New Entrants (f)	2	1	2	$0.00	$0.00	$200.00	$400
13. First Receiver Site License Application Form: Re-Registration (f)	41	1	41	$0.00	$0.00	$200.00	$8,200
14. Mothership Permit Renewal Form (c)	6	1	6	$0.00	$0.00	$0.00	$0.00
15. Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form	1	1	1	$0.60	$0.15	$0.00	$0.75
16. Mothership Cooperative Permit Application Form (g)	1	1	1	$1.52	$3.00	$0.00	$4.52
17. Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form	1	1	1	$0.60	$0.15	$0.00	$0.75
18. Catcher/Processor Cooperative Permit Application Form (h)	1	1	1	$1.52	$2.50	$0.00	$4.02
19. Material Change (i)	1	1	1	$1.52	$0.10	$0.00	$1.62
20. QS Abandonment Request	1	1	1	$0.60	$0.05	$0.00	$0.65
21. Catch monitoring plans/ First receivers Preparation and Submission	43	1	43	Included with Other Applicable Forms	$0.00	$0.00	$0.00
22. Catch monitoring plans/ First receivers Inspection	43	1	43	Included with Other Applicable Forms	$0.00	$0.00	$0.00
23. Shorebased Scales/ First receivers Inspection	43	Variable	43	Included with Other Applicable Forms	$0.00	$0.00	$0.00
24. Shorebased Scales/ First receivers Reports	43	Variable	1,290	Included with Other Applicable Forms	$0.05	$0.00	$64.50
TOTALS			3,868				$8,923.15

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.

NMFS will charge application/renewal fees for certain collections (as outlined above under question 13, column f) to recover some administrative costs. In addition, NMFS will incur ongoing program costs related to the trawl rationalization program which includes staff time to: prepare application and renewal packages, review and process (enter data) incoming registration, transfer and renewal applications, prepare decision documents and permit documents, maintain and improve the IFQ accounting system (QS and vessel accounts), and respond to permit and vessel account owners questions about application, account, and the IFQ program. The estimated net administrative cost accruing to the Federal government is approximately $700,000.

Cost Descriptions	Grade/Step	Loaded Salary /Cost	% of Effort	Fringe (if Applicable)	Total Cost to Government
Federal Oversight	ZP-4/Interval 5	$230,707.50	50%		$115,353.75
Other Federal Positions	ZP-3/Interval 3 (x3)	$154,764	50% (x3)		$232,146.00
Contractor Cost		$350,000	100%		$350,000.00
Travel					0
Other Costs:					0
TOTAL					$697,499.75

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
1. QS Permit/Account Application Form (a)(b)	1	8	1	8	0.33	2.66	Change in respondents over time
2. QS Permit/Account Renewal - Online (a)(d)	181	181	181	181	30.17	30.17	No change
3. QS Permit/Account Renewal Form (a)	1	1	1	1	0.25	0.25	No change
4. QS Transfer (d)(e)	1	48	1	48	0.17	8	Historically variable response rate, decrease based on recent years which were likely impacted by COVID
5. QP Transfer from QS Account to Vessel Account (d)(e)	181	181	690	905	57.5	75.42	Change in responses over time
6. Vessel Account Registration Request (a)	3	10	3	10	0.75	2.5	Change in respondents over time
7. Vessel Account Renewal - Online (a)(d)	144	144	144	144	24	24	No change
8. Vessel Account Late Renewal Form (a)	6	6	6	6	1.5	1.5	No change
9. QP Transfer from Vessel Account to Vessel Account (d)(e)	88	150	968	1,650	80.67	137.5	Change in respondents over time
10. Trawl Identification of Ownership Interest Form: New Entrants	24	24	31	31	23.25	23.25	No change
11. Trawl Identification of Ownership Interest Form: Renewal (c)	368	374	368	374	19.63	19.95	CHANGE: MS respondent requirement removed pursuant to 0648-BL41
12. First Receiver Site License Application Form: New Entrants (f)	2	2	2	2	6.67	6.67	No change
13. First Receiver Site License Application Form: Re-Registration (f)	41	41	41	41	68.33	68.33	No change
14. Mothership Permit Renewal Form (c)	6	6	6	6	1	1	No change
15. Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form	1	1	1	1	0.58	0.58	No change
16. Mothership Cooperative Permit Application Form (g)	1	1	1	1	3.83	3.83	No change
17. Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form	1	1	1	1	0.58	0.58	No change
18. Catcher/Processor Cooperative Permit Application Form (h)	1	1	1	1	1.83	1.83	No change
19. Material Change (i)	1	1	1	1	2.5	2.5	No change
20. QS Abandonment Request	1	1	1	1	0.17	0.17	No change
21. Catch monitoring plans/ First receivers Preparation and Submission	43	43	43	43	0	0	No change
22. Catch monitoring plans/ First receivers Inspection	43	43	43	43	86	86	No change
23. Shorebased Scales/ First receivers Inspection	43	43	43	43	43	43	No change
24. Shorebased Scales/ First receivers Reports	43	43	1,290	1,290	215	215	No change
Mutual Agreement Exception	N/A	1	N/A	1	N/A	1	Removed from the collection pursuant to 0648-BL41
Mothership Withdrawal	N/A	1	N/A	1	N/A	2	Removed from the collection pursuant to 0648-BL41
Total for Collection	359	359	3,868	4,834	668	761
Difference	0		-966  (-8 change -958 adjustment)		-93 (-3 change - 90 adjustment)

*Note: respondent total for unique respondents

Information Collection	Labor Costs		Miscellaneous Costs		Reason for change or adjustment
	Current	Previous	Current	Previous
1. QS Permit/Account Application Form (a)(b)	6.30	Not previously calculated	0.75	5.60	Change in respondents over time Increase in postage costs.
2. QS Permit/Account Renewal - Online (a)(d)	575.64		9.05	9.05
3. QS Permit/Account Renewal Form (a)	4.77		0.65	0.60	Increase in postage costs.
4. QS Transfer (d)(e)	3.24		0.05	2.40	Historically variable response rate, decrease based on recent years which were likely impacted by COVID
5. QP Transfer from QS Account to Vessel Account (d)(e)	1,097.10		34.50	45.25	Change in responses over time
6. Vessel Account Registration Request (a)	14.31		1.95	6	Change in respondents over time
7. Vessel Account Renewal - Online (a)(d)	457.92		7.20	7.20
8. Vessel Account Late Renewal Form (a)	28.62		3.90	3.60	Increase in postage costs.
9. QP Transfer from Vessel Account to Vessel Account (d)(e)	1,539.18		48.40	82.50	Change in respondents over time
10. Trawl Identification of Ownership Interest Form: New Entrants	443.61		10.85	10.85
11. Trawl Identification of Ownership Interest Form: Renewal (c)	374.54		128.80	130.90	CHANGE: MS respondent requirement removed pursuant to 0648-BL41
12. First Receiver Site License Application Form: New Entrants (f)	127.26		400	403.44	Changed to online submission
13. First Receiver Site License Application Form: Re-Registration (f)	1,303.74		8,200	8,270.52	Changed to online submission
14. Mothership Permit Renewal Form (c)	19.08		0	3.90	Changed to online submission
15. Mothership Permit Change of Vessel Registration, Permit Owner, or Vessel Owner Application Form	11.07		0.75	0.70	Increase in postage costs.
16. Mothership Cooperative Permit Application Form (g)	73.08		4.52	4.52
17. Change of MS/CV-Endorsement and Catch History Assignment Registration Application Form	11.07		0.75	0.70	Increase in postage costs.
18. Catcher/Processor Cooperative Permit Application Form (h)	34.92		4.02	4.02
19. Material Change (i)	47.70		1.62	1.62
20. QS Abandonment Request	3.24		0.65	0.60	Increase in postage costs.
21. Catch monitoring plans/ First receivers Preparation and Submission	0		0	0
22. Catch monitoring plans/ First receivers Inspection	1,640.88		0	0
23. Shorebased Scales/ First receivers Inspection	820.44		0	0
24. Shorebased Scales/ First receivers Reports	4,102.20		64.5	64.50
Mutual Agreement Exception	N/A		N/A	1.62	Removed from the collection pursuant to 0648-BL41
Mothership Withdrawal	N/A		N/A	1.62	Removed from the collection pursuant to 0648-BL41
Total for Collection	12,739.91	N/A	8,924	9,063
Difference	12,739.91		-139 (-5 change -134 adjustment)

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.

There are no plans for publishing the results from this collection.

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.

The expiration date will be displayed on this information collection.

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).