0648-0674 Supporting Statement A

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Atlantic Herring Amendment 5 Data Collection

OMB: 0648-0674

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SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic & Atmospheric Administration

Atlantic Herring Amendment 5 Data Collection

OMB Control No. 0648-0674



Abstract

This request is for an extension of the information collection to support regulatory requirements in the Atlantic Herring Fishery Management Plan. Federally permitted fishing vessels participating in the Atlantic herring fishery in the Northeast Region of the U.S. are subject to certain information collection requirements for the National Marine Fisheries Service to improve the collection of real-time and accurate catch information for the Atlantic herring fishery, enhance the monitoring and sampling of catch at-sea, and address bycatch issues. Extending this information collection would support ongoing monitoring and sampling of catch in the Atlantic herring fishery necessary for sustainable management of the Atlantic herring resource and fishery.


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 National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service (NMFS) is requesting an extension of OMB Control No. 0648-0674, to continue management of the Atlantic Herring Fishery Management Plan (FMP) developed under the authority of the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq, Section 303). This extension would enable NMFS to continue to collect information necessary for ongoing monitoring and sampling of catch in the Atlantic herring fishery necessary for sustainable management of the Atlantic herring resource and fishery.


In 2014, NMFS implemented Amendment 5 to the Atlantic Herring FMP (Amendment 5) to improve the collection of real-time and accurate catch information for the Atlantic herring fishery; enhance the monitoring and sampling of catch at-sea; and address bycatch issues, in particular bycatch of river herrings and shads, through responsible management.


In 2020, NMFS implemented the New England Industry Funded Monitoring (IFM) Omnibus Amendment to increase monitoring, above levels required by the Standardized Bycatch Reporting Methodology (SBRM), in certain FMPs, to assess the amount and type of catch and to reduce variability around catch estimates. This amendment created a structure by which industry funding would be used in conjunction with available Federal funding to pay for additional monitoring to meet FMP-specific coverage targets and required industry-funded monitoring in the Atlantic herring fishery.


The items outlined in this information collection include:

  • Observer notification requirement for permitted herring vessels to facilitate SBRM and IFM coverage;

  • Requirement for vessel captains to submit a Released Catch Affidavit form documenting the discarding of unsampled catch;

  • A requirement that Category A and B Atlantic herring permit holders pay for vessel at-sea monitoring costs, estimated to be up to $710 per sea day, on trips selected for IFM coverage (50% coverage target);

  • The option for Category A and B Atlantic herring permit holders that fish with midwater trawl gear to obtain an IFM observer allowing the vessel to fish in groundfish closed areas and pay for the vessel’s at-sea monitoring costs, estimated to be up to $818 per sea day; and

  • Requirements for IFM monitor service providers to submit reports to NMFS on behalf of Category A or B Atlantic herring permitted vessels or for meeting service provider responsibilities for service provider approval and to facilitate accurate catch monitoring.


Regulations implementing the Atlantic Herring FMP are specified at 50 CFR part 648 and the recordkeeping and reporting requirements at § 648.11 form the basis for this collection of information.


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.


The information collection is used by NMFS, the New England Fishery Management Council, state fishery management agencies, academic institutions, and other fishery research and management organizations (consistent with MSA confidentiality restrictions as noted in answer to paragraph 10 below) to evaluate current management programs and future management proposals. All information collections are necessary for improved monitoring of the Atlantic herring fishery.


Observer Notification Requirements

Herring vessels are required to notify NMFS at least 48 hours in advance of a fishing trip to request monitoring coverage. This requirement assists NMFS in scheduling and deploying of observers and at-sea monitors (ASMs) across the herring fleet to help to ensure that monitoring coverage targets for the herring fishery are met.


Released Catch Affidavits

Herring vessels (Category A, B, C) carrying an observer or ASM are required to bring all catch aboard the vessel and make it available for sampling. This requirement improves the quality of monitoring data by reducing the discarding of unsampled catch. If catch is discarded before it has been made available to the observer or ASM, that catch is defined as slippage. If slippage occurs, the vessel operator must notify the observer or ASM the amount discarded and complete a Released Catch Affidavit form within 48 hours of the end of the fishing trip. The Released Catch Affidavit details: (1) Why catch was slipped; (2) an estimate of the quantity and species composition of the slipped catch; and (3) the time and location of the slipped catch.


Monitoring Funding Contribution

Herring vessels (The IFM Amendment would implement ASM coverage on Category A and B) are required to carry an ASM if requested by NMFS to help ensure monitoring coverage requirements for the herring fishery are met. The target maximum industry contribution for ASMs is $710 per day. The cost of monitoring would likely vary among providers, but the maximum target for ASM coverage is $710 per day.


Optional IFM Monitoring Funding Contribution to Access Groundfish Closed Areas

Herring vessels fishing with midwater trawl gear may access groundfish closed areas provided they carry an observer to ensure monitoring coverage in the closed areas. These vessels have an option to purchase an observer in order to fish in groundfish closed areas. If not selected for SBRM coverage or IFM ASM coverage, midwater trawl vessels may call a service provider to request an observer for a trip in order to fish in the closed areas at an estimated cost of $818 per day.


Service Provider Requirements

The following set of requirements facilitates coordination between NMFS and approved IFM service providers. IFM service providers supply observers or ASMs (also collectively referred to as monitors) to the industry upon selection/request for coverage. These requirements are based on those included in the overall observer provider collection (OMB Control No. 0648-0546), but feature the additional burden required to certify and collect information from IFM service providers for the Atlantic herring fishery.


  1. Monitor deployment report: The deployment reports are used to inform NMFS when, where and to whom a monitor has been deployed within 24 hours of the monitor’s departure. The reports also help NMFS track if a monitor provides trip data within 12 hours of landing.


  1. ASM Availability Report: The availability reports are used to inform NMFS of any occurrence of a service provider’s inability to respond to an industry request for ASM coverage due to the lack of available ASMs by 5:00 pm, Eastern Standard Time, on any day with an industry request for monitor coverage.


  1. Safety Refusals: The safety refusal reports are used to inform NMFS of any trip that a monitor has refused due to safety issues (e.g., failure to hold a valid USCG Commercial Fishing Vessel Safety Examination Decal or meet the safety requirements of the monitor’s pre-trip vessel safety checklist) within 24 hours of the refusal.


  1. Raw monitor data: The submission of raw (unedited) monitor data (via courier service e.g., FedEx, DHL, etc.) to the NMFS within 72 hours of trip landing is necessary for NMFS to administer the IFM program. These data are also used to monitor bycatch in the Atlantic herring fishery.


  1. Monitor debriefing: The service provider ensures that the monitor remains available to the NMFS for debriefing for two weeks following any monitored trip. Monitor debriefings ensure the data collected by the monitor are as accurate as possible and any potential issues are addressed. A monitor that is at sea during the two-week period contacts NMFS upon his or her return if requested.


  1. Other reports: Reports of possible monitor harassment, discrimination, concerns about vessel safety or marine casualty, monitor illness or injury, and any information, allegations, or reports regarding monitor conflict of interest or breach of the standards of behavior are submitted to NMFS in a timely manner.


  1. Biological samples: The service provider ensures that biological samples, including whole marine mammals, turtles seabirds, and fish be stored/handled properly and transported to NMFS within 7 days of landing.


  1. New permit application for monitor provider: Any third party service provider that wishes to operate in the Atlantic herring IFM program would submit a thorough application and gain approval from NMFS.


  1. Applicant response to a denial: If a service provider application for approval is incomplete or does not meet the requirements of an approved service provider, the application would be provided with a written denial. Each applicant may present additional information to NMFS to rectify the deficiencies specified in the written denial within 30 days of the applicant’s receipt of the denial notification.


  1. Request for monitor training: The service provider submits a request for a certified training class at least 30 days prior to the beginning of the proposed training class to ensure that NMFS is provided with the necessary time and information to prepare for the training of candidate monitors.


  1. Rebuttal of pending removal from list of approved monitor providers: A service provider that fails to meet the requirements, conditions, and responsibilities of an approved monitor service provider is notified in writing that it is subject to removal from the list of approved service providers. A monitor service provider that has received notification that it is subject to removal from the list of approved service providers may submit information to rebut the reasons for removal from the list within 30 days and give written evidence that clearly disproves the reasons for removal.


  1. Request to service provider to procure an ASM: When a vessel is selected for IFM coverage, a service provider is contacted through the pre-trip notification system (PTNS) with the request to provide an ASM.


  1. Notification of unavailability of ASM: A service provider may not have ASMs available for a trip selected for coverage. Providers are required to respond through the PTNS indicating they do not have an ASM available for coverage.


  1. Request to service provider to procure an IFM observer to fish in Groundfish Closed Areas: If a vessel is not selected for SBRM or IFM ASM coverage, they may choose to purchase an observer to order to fish in groundfish closed areas. Vessels call service providers to request an observer.


  1. Notification of unavailability of IFM observer: A service provider may not have an observer available for vessels requesting an observer. Providers are required to contact the vessels to notify them that coverage is not available.


  1. Monitor contact list updates: An updated monitor contact list facilitates NMFS ability to contact a monitor when necessary. This list is updated by the service provider as necessary.


  1. Monitor availability updates: The monitor status report facilitates NMFS ability to confirm monitor availability, or the lack thereof, when a provider notifies NMFS of instances when no monitors are available for deployment. This list is updated by the service provider as necessary.


  1. Service provider material submissions: NMFS may request service providers supply it with copies of materials that service provided gave to the fishing industry. This enable NMFS to ensure such materials are accurate and consistent with the objectives of the IFM program.


  1. Service provider contracts: NMFS may request service providers to provide a copy of each type of signed and valid contract between providers and the fishing industry. This helps NMFS to ensure provider contracts are consistent with the objectives of the IFM program.


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.


Herring vessels and service providers submit information to NMFS via web portal, email, fax, or mail. Whenever possible, NMFS encourages information to be submitted electronically. Instructions for vessels are located here.


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.


Information submissions for herring vessels and service providers are unique to the Atlantic herring fishery, thus direct duplication with other collections does not exist.


The requirement to carry and pay for an ASM on a trip only applies to vessels that are not selected for SBRM coverage on that trip, therefore, vessels would not be required to pay for monitoring on trips with SBRM coverage.


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


Only the minimum data needed to meet the objectives of the IFM Amendment are requested from all respondents. Since the respondents are small businesses, separate requirements based on the size of business have not been developed.


PTNS is designed to be a user-friendly system that will notify vessels of any mandatory coverage requirements for a trip. The system is accessible from any computer with internet access and at any time of day. The system notifies service providers of the selection of coverage for a trip, and vessels are notified that a trip will be monitored, provided the trip is selected for coverage and coverage is available.


NMFS certifies several service providers (best estimate: 4) to offer monitoring services to vessels with Category A or B herring permits. Each vendor offers comparable equipment and services over a range of prices. This reduces the burden on the public by increasing competition among vendors, thereby decreasing costs to the fishing industry to obtain additional monitoring.



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.


To the extent practicable, frequency of information collection under this family of forms has been minimized. To reduce the frequency any further would compromise the intent of each collection of information requirement.


All information would be required to meet the requirements of the IFM Amendment, and must be submitted in the time frame requested. Collecting this information less frequently would jeopardize the goals and objectives of the IFM Amendment and the observer program.



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


The data collection is consistent with 5 CFR 1320.6 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 notice (87 FR 59402) announcing a 60-day comment period on the extension of this collection published on September 30, 2022, and no comments were received.


Additionally, NMFS reached out to several stakeholders in an effort to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.  No responses were received.


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


No payment or gift has been or will be made to respondents.


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


All data would be handled in accordance with NOAA Administrative Order 216-100, Confidentiality of Fisheries Statistics, and would not be released for public use except in aggregate statistical form (and without identifying the source of data, i.e., vessel name, owner, etc). In addition, any information collected under the Permit Family of Forms would be considered confidential and would not be disclosed except as provided in Section 402(b) of the Magnuson-Stevens Act.


COMMERCE/NOAA-19, Permits and Registrations for United States Federally Managed Fisheries covers this information. An amended SORN was published on August 7, 2015 (80 FR 47457).



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.


There are no questions of a sensitive nature involved in this collection of information.

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

For wage costs: use www.bls.gov/oes , then click on OES Data in the left-hand column, then National to find Occupational Employment Wage Rates for the current year. Find the appropriate Occupational Title of the Respondent completing the Information Collection and use the Mean hourly wage.


Information Collection

Type of Respondent (Occupational Title)

# of Respondents

Annual # of Responses / Respondent

Total # of Annual Responses

Burden Hrs / Response

Total Annual Burden Hrs

Mean Hourly Wage Rate (for Type of Respondent)

Total Annual Wage Burden Costs

Observer/Monitor Reporting for Vessels









Pre-trip notification to observer program

Ship and Boat Captains and Operators 

134

25

3350

5 min

279

$38.43

$10,721.97

Trip cancellation notification to observer program


Ship and Boat Captains and Operators 

134

25

3350

1 min

56

$38.43

$2,152.08

Call to service provider to request IFM observer to access Groundfish Closed Areas

Ship and Boat Captains and Operators 

12

84

5 min

7

$38.43

$269.01

Trip cancellation notification to service provider for Groundfish Closed Area

Ship and Boat Captains and Operators 

12

7

84

1 min

1

$38.43

$38.43

Industry contribution for IFM ASM Coverage

General and Operations Managers

42

19

798

0

0

$55.41

$0.00

Industry contribution (MWT vessels) for optional IFM observers to enter Groundfish Closed Area

General and Operations Managers

12

21

252

0

0

$55.41

$0.00

Monitor Provider Requirements







 

 

Monitor deployment report

Farmers, Ranchers, and Other Agricultural Managers

4

111

444

10 min

74

$37.71

$2,790.54

ASM availability report

Farmers, Ranchers, and Other Agricultural Managers

4

54

216

20 min

72

$37.41

$2,715.12

Safety refusals

Farmers, Ranchers, and Other Agricultural Managers

4

10

40

30 min

20

$37.41

$754.20

Raw monitor data

Farmers, Ranchers, and Other Agricultural Managers

4

111

444

5 min

37

$37.41

$1,395.27

Monitor debriefing

Farmers, Ranchers, and Other Agricultural Managers

4

31

124

2 hr

248

$37.41

$9,352.08

Other reports

Farmers, Ranchers, and Other Agricultural Managers

4

17

68

30 min

34

$37.41

$1,282.14

Biological samples

Farmers, Ranchers, and Other Agricultural Managers

4

129

516

1 hr

516

$37.41

$19,458.36

New application to be a service provider

Farmers, Ranchers, and Other Agricultural Managers

4

1

4

10 hr

40

$37.41

$1,508.40

Applicant response to denial

Farmers, Ranchers, and Other Agricultural Managers

1

1

1

10 hr

10

$37.41

$377.10

Request for monitor training

Farmers, Ranchers, and Other Agricultural Managers

4

3

12

30 min

6

$37.41

$226.26

Rebuttal of pending removal from list of approved monitor providers

Farmers, Ranchers, and Other Agricultural Managers

1

1

1

8 hr

8

$37.41

$301.68

Request to monitor service provider to procure an ASM

Farmers, Ranchers, and Other Agricultural Managers

90

4

360

10 min

60

$37.41

$2,262.60

Notification of unavailability of ASMs

Farmers, Ranchers, and Other Agricultural Managers

90

4

360

5 min

30

$37.41

$1,131.30

Call to service provider to procure an IFM observer in Groundfish Closed Area

Farmers, Ranchers, and Other Agricultural Managers

21

4

84

10 min

14

$37.41

$527.94

Notification of unavailability of IFM observers

Farmers, Ranchers, and Other Agricultural Managers

21

4

84

5 min

7

$37.41

$263.97

Monitor contact list updates

Farmers, Ranchers, and Other Agricultural Managers

4

12

48

5 min

4

$37.41

$150.84

Monitor availability updates

Farmers, Ranchers, and Other Agricultural Managers

4

12

48

5 min

4

$37.41

$150.84

Service provider material submissions

Farmers, Ranchers, and Other Agricultural Managers

4

2

8

30 min

4

$37.41

$150.84

Service provider contracts

Farmers, Ranchers, and Other Agricultural Managers

4

2

8

30 min

4

$37.41

$150.84

Totals




10,788


1,535

 

$58,131.81

Observer Reporting for Vessels







 

 

Released Catch Affidavit

Ship and Boat Captains and Operators 

93

38

3534

5 min

295

$38.43

$11,336.85

Vessel operator notification of species lb to Observer

Ship and Boat Captains and Operators 

42

25

1050

1 min

18

$38.43

$691.74

 Totals

 

 

 

4,584

 

313

 

$12,028.59 

Totals

 

 

 

15,372

 

1,848

 

 $70,160.40







13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).


Information Collection

# of Respondents

Annual # of Responses / Respondent

Total # of Annual Responses

Cost Burden / Respondent

Total Annual Cost Burden

Observer/Monitor Reporting for Vessels

 

 

 

 

 

Pre-trip notification to observer program

134

25

3350

0

0

Trip cancellation notification to observer program

134

25

3350

0

0

Call to service Provider to request IFM observer to access Groundpish Closed Areas

12

84

$0.50

$42

Trip cancellation notification to service provider for Groundfish Closed Area

12

7

84

$0.10

$8

Industry contribution for IFM ASM Coverage

42

19

798

$710.00

$566,580

Industry contribution (MWT vessels) for optional IFM observers to enter Groundfish Closed Area

12

21

252

$818.00

$206,136

Monitor Provider Requirements






Monitor deployment report

4

111

444

0

0

ASM availability report

4

54

216

0

0

Safety refusals

4

10

40

0

0

Raw monitor data

4

111

444

$24.85

$11,033

Monitor debriefing

4

31

124

$12.00

$1,488

Other reports

4

17

68

0

0

Biological samples

4

129

516

$7.37

$3,803

New application to be a service provider

4

1

4

0

0

Applicant response to denial

1

1

1

0

0

Request for monitor training

4

3

12

0

0

Rebuttal of pending removal from list of approved monitor providers

1

1

1

0

0

Request to monitor service provider to procure an ASM

90

4

360

0

0

Notification of unavailability of ASMs

90

4

360

0

0

Call to service provider to procure an IFM observer in Groundfish Closed Area

21

4

84

0

0

Notification of unavailability of IFM observers

21

4

84

0

0

Monitor contact list updates

4

12

48

0

0

Monitor availability updates

4

12

48

0

0

Service provider material submissions

4

2

8

0

0

Service provider contracts

4

2

8

0

0

Totals



10,788


$789,090

Observer Reporting for Vessels






Released Catch Affidavit

93

38

3534

$0.60

$2,120

Vessel operator notification of species lb to observer

42

25

1050

0

0

 Totals

 

 

4,584


$2,120

TOTALS

 

 

15,372

 

$791,210




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



Cost Descriptions

Grade/Step

Loaded Salary /Cost

% of Effort

Fringe (if Applicable)

Total Cost to Government

Federal Oversight

 

 

 

 

 

 Fishery Management Specialist

Band II/ Step 3

$81,658 

25% 

 

$20,415

Fisheries Monitoring Operations 

Band III/ Step 3

$107,542

26%


$27,960

Contractor Cost

 

 

 

 

 

 Fisheries Monitoring Operations

 

$60,000

75% 

 

$45,000 

Travel

 

 

 

 

Other Costs

 

 

 

 

TOTAL

 

 

 

 

$93,375 



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


The following tables show the changes in labor costs, and miscellaneous costs; and explains the reasons for these changes.


Information Collection

Labor Costs

Miscellaneous Costs

Reason for change or adjustment

Current

Previous

Current

Previous

Observer/Monitor Reporting for Vessels






Pre-trip notification to observer program

$10,722

$921

0

0

Updated wage information

Trip cancellation notification to observer program

$2,152

$37

0

0

Call to service provider to request IFM observer to access Groundfish Closed Areas

$269

$23

$42

$42

Trip Cancellation notification to service provider for Groundfish Closed Area

$38

$1

$8

$8

Industry contribution for IFM ASM Coverage

0

0

$566,580

$566,580

No change

Industry contribution (MWT vessels) for optional IFM observers to enter Groundfish Closed Area

0

0

$206,136

$206,136

No change

Monitor Provider Requirements






Monitor deployment report

$2,791

$474

0

0

Updated wage information

ASM availability report

$2,715

$922

0

0

Safety refusals

$754

$384

0

0

Raw monitor data

$1,395

$118

$11,033

$10,545

Updated wage and mailing cost information

Monitor debriefing

$9,352

$19,061

$1,488

$1,488

Updated wage information

Other reports

$1,282

$653

0

0

Biological samples

$19,458

$19,830

$3,803

$258

Updated wage and mailing cost information (the previous mailing cost was not accurate for the mailing of samples)

New application to be a service provider

$1,508

$15,372

0

$2

Updated wage and information transmission methodology

Applicant response to denial

$377

$3,843

0

$1

Updated wage and information transmission methodology

Request for monitor training

$226

$115

0

$22

Rebuttal of pending removal from list of approved monitor providers

$302

$2,460

0

$1

Request to monitor service provider to procure an ASM

$2,263

$384

0

0

Updated wage information

Notification of unavailability of ASMs

$1,131

$96

0

0

Call to service provider to procure an IFM observer in Groundfish Closed Area

$528

$90

0

$84

Updated wage and information transmission methodology

Notification of unavailability of IFM observers

$264

$22

0

$42

Monitor contact list updates

$151

$13

0

0

Updated wage information

Monitor availability updates

$151

$13

0

0

Service provider material submissions

$151

$77

0

$20

Updated wage and information transmission methodology

Service provider contracts

$151

$77

0

$20

Observer Reporting for Vessels






Released Catch Affidavit

$11,337

$974

$2,120

$1,944

Updated wage and mailing cost information

Vessel operator notification of species lb to observer

$692

$12

0

0

Updated wage information

Total for Collection

$70,160

$65,972

$791,210

$787,193


Difference

$4,188

$4,017




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.


Results from this collection could be used in scientific, management, technical, or general informational publications such as Fisheries of the United States, which follows prescribed statistical tabulations and summary table formats. Data are available to the general public on request in summary form only. Data are available to NMFS employees in detailed form on a need-to-know basis only.



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.


All information collection associated with this action is through non-standardized reports, web-based forms, and telephone calls which would be inappropriate to display the expiration date for the OMB approval.



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


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

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