Supporting Statement A

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SUPPORTING STATEMENT
U.S. Department of Commerce
National Oceanic & Atmospheric Administration
West Coast Region Groundfish Electronic Fish Ticket Program
OMB Control No. 0648-0738

Abstract
This request is for extension for the information collection known as the West Coast Region Groundfish Electronic Fish Ticket Program. Electronic fish tickets are submissions of landings data from the first receiver to the Pacific States Marine Fisheries Commission (PSMFC) and National Marine Fisheries Service (NMFS). Electronic fish tickets are required in all of the shore based commercial groundfish fisheries, including the shore based Individual Fishing Quota (IFQ) program, the limited entry fixed gear fishery, and the open access fixed gear fishery. 
Since the start of the shore based IFQ Program in 2011, electronic fish tickets have been required for landing IFQ species. Electronic fish tickets have allowed vessel owners/operators, buyers and dealers, and fishery managers timely access to catch information for IFQ species. Many of the proposed regulations that expand the required use of electronic fish tickets to the limited entry fixed gear and open access fisheries are similar to those put in place for the Shore based IFQ Program.

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.
Electronic fish tickets are required in all of the shorebased commercial groundfish fisheries, including the shorebased Individual Fishing Quota (IFQ) program, the limited entry fixed gear fishery, and the open access fixed gear fishery. The electronic fish ticket program is vital to: 1) adequately track the landings of commercially caught groundfish; 2) be able to assign landings of sablefish to a tier permit if fishing in the primary fishery; and 3) enhance the ability of enforcement to deal with issues more effectively and efficiently. Electronic fish tickets provide real time data to enforcement and managers, to address issues that arise within the fishery.
The Pacific Coast Groundfish Fishery Management Plan (FMP), created under the authorization of the Magnuson-Stevens Fishery Conservation and Management Act, 16 USC 1801 et seq., was approved by the U.S. Secretary of Commerce on January 4, 1982, and implemented on October 5, 1982. Throughout the next two decades, there were several amendments to the FMP. Amendment 9 modified the limited entry (LE) program by establishing a sablefish endorsement for long line and pot permits. Amendment 14, implemented in 2002, built on Amendment 9 to further refine the LE permit system for the economically important, fixed gear sablefish fishery. It allowed a vessel owner to “stack” up to three LE permits on one vessel, along with associated sablefish catch limits. This, in combination with a concurrent action to extend the season length, in effect established a limited tradable quota system for participants in the primary sablefish fishery.
Since implementation of the permit stacking program in 2002, in-season management of the primary and daily trip limit (DTL) sablefish fixed gear fisheries has been based on two types of information: (1) paper landing receipts that typically have a two- to four-month time lag between the date of landing and when the landing data is available in the Pacific Fishery Information Network (PacFIN), and (2) the Quota Species Monitoring (QSM) Best Estimate Report, which fills in the three-month time lag based on estimates from the previous years’ landings. Both of these data sources estimate which landings are attributed to the primary (tier) fishery, and which are attributed to the DTL fishery. Thus, the current catch accounting system is subject to inaccuracy and time delays and is incapable of distinguishing between landings in the primary (tier) and DTL fisheries for management or enforcement purposes.
Additionally, at the time of implementation of Amendment 14, no Federal regulations existed requiring fish ticket documentation of the groundfish permit number associated with sablefish landings in the primary (tier) sablefish fishery. Documentation of catch against tier limits and documentation of permit numbers was left to the states to implement. Currently, with the E-Tix portal managed by PSMFC, Federal LE permit numbers, IFQ vessel account numbers, management areas, and sablefish tiers are now being recorded consistently on state landing receipts associated with sablefish landings.
Since the start of the shorebased IFQ Program in 2011, electronic fish tickets have been required for landing IFQ species. Electronic fish tickets have allowed vessel owners/operators, buyers and dealers, and fishery managers timely access to catch information for IFQ species. Many of the proposed regulations that expand the required use of electronic fish tickets to the limited entry fixed gear and open access fisheries are similar to those put in place for the Shorebased IFQ Program.

    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.
Shoreside first receivers, defined as persons who receive, purchase, or take custody, control, or possession of catch onshore directly from a vessel, are required to use a web-based, NMFS-approved electronic fish ticket program to send catch reports within 24 hours from the date of the landing. The electronic fish tickets are based on information currently required in state fish receiving tickets or landing receipts. The required information varies slightly from state to state, as indicated in the parentheses, and includes the following:

    • Individual Fishing Quota (IFQ) Landing (Y/N)
    • IFQ Vessel Account #
    • IFQ Management Area
    • Sablefish Tier
    • Federal Limited Entry (LE) Permit
    • Directed Open Access Groundfish (D.O.A.G.) Permit
    • Permit
    • Date of Landing
    • Commercial License #
    • Fisherman I.D. (CA only)
    • Vessel I.D. (Name) (CA only)
    • Coast Guard (CG) Vessel # (CA only)
    • CG/WA Vessel # (WA only)
    • WDFW Vessel # (WA only)
    • Boat Number (Name) (OR only)
    • Boat Number (Owner) (OR only)
    • Operator (OR only)
    • Dealer # (Name)
    • Buyer (WA state only)
    • Port of 1st Landing / Port Code
    • Primary Gear / Gear Used
    • # of Days Fished (OR & WA)
    • State Permit # (CA only)
    • Inside/Outside (i.e., fish caught inside/outside 3 miles EEZ or both)
    • Fishing Block (CA only)
    • (Primary) Catch Area (OR & WA)
    • Subunit (WA only)
    • Primary Data Source (WA only)
    • Transport (Ticket) # (CA & WA)
    • Trip Type (OR only)
    • Unloading Station (OR only)
    • Fish Code (Description) (i.e., actual species or species groups of fish caught) 
    • Gross Lbs
    • Price Per Lb
    • Amount
    • # of Fish
    • Condition
    • Grade
    • Gear
    • Type (OR only)
    • Data Source (WA only)
    • Use (CA & OR)
    • GF #
    • IFQ Area
The information gathered from fish tickets has great utility and will be used to track catch allocations, bycatch limits, and prohibited species catch during the season. The state Departments of Fish and Wildlife (i.e., California Department of Fish and Wildlife, Oregon Department of Fish and Wildlife, and Washington Department of Fish and Wildlife) have partnered with PSMFC to use their E-Tix application as a pass through for all state required commercial fisheries electronic fish tickets and associated data. Each state DFW stores and maintains the official, final commercial landings data gathered in their respective state on the Pacific Fisheries Information Network (PacFIN) database. The information is safeguarded from improper access, modification, and destruction. 
The respective state DFWs and PSMFC can make certain commercial landings data available via the PacFIN database, while ensuring the confidentiality of these data, for the use of authorized individuals in their role to analyze data and prepare Fishery Management Plans necessary to co-manage certain fisheries under the purview of the Pacific Fishery Management Council. 

    3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology, 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 electronic fish tickets are based on information currently required by the states on paper fish receiving tickets or landing receipts (fish tickets). Under the electronic fish ticket program, first receivers will use a web-based system to provide all information required (see Question 2 for a list of information included). First receivers will be required to have a personal computer system, which could include a tablet or mobile device, with an internet browser. The internet browser must be set up to allow cookies and JavaScript, and the default security settings must be used.  

    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.
Measures were taken to minimize duplication of the catch accounting requirements by generating an electronic fish ticket program that is based on the existing state systems and does not require additional data gathering. When state law allows, the electronic fish ticket can be printed and used as a paper copy for submission to the state. In Oregon and Washington, specified information may be submitted either on a paper fish ticket provided by the state or on a computer-generated ticket provided specified data fields are included. In California, standard paper forms provided by the state must be used.



    5.  If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
Measures were taken to minimize the costs of the catch accounting requirements by providing: 1) a web-based program so that no additional software is needed and the program is accessible wherever there is an internet connection; 2) an electronic fish ticket program that is compatible with the existing fish ticket requirements in each of the three states; and, 3) a program that can be used to print a paper copy for submission to the state, when state law allows.
NMFS assumes that all first receivers have access to a personal computer and/or a tablet where they can access the web-based program. Additionally, because the information is already being gathered by the states, there is no requirement that additional data be gathered. Some applicants are individuals or small companies and as such are considered small businesses. Given the relatively small numbers of applicants, separate requirements based on size of business have not been developed. Only the minimum data required to meet the permit objectives are requested from all applicants.
    6.  Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
If this information collection is not conducted or is conducted less frequently, NMFS and the Pacific Fishery Management Council (PFMC) would be unable to maintain real-time catch accounting across West Coast commercial groundfish fisheries, severely compromising the sustainable management and statutory enforcement mandated by the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.). 
Indirect biological impacts could result if catch data were inaccurate or delayed so that fishery specifications, including bycatch limits, species allocations, optimum yield (OY), and biological opinion thresholds could not be adequately monitored. If bycatch limits of the most constraining overfished species were greatly exceeded due to delayed catch reporting, the risk of exceeding rebuilding based OYs is increased.
Specifically, discontinuing or reducing the frequency of electronic fish ticket submissions would result in the following consequences:
    • Impaired Catch Accounting & Quota Tracking: The shorebased Individual Fishing Quota (IFQ) program relies on electronic fish tickets submitted within 24 hours of landing to track real-time vessel account balances and species allocations. Without near-real-time data, fishery managers and vessel operators could not verify whether quota holdings have been exceeded, exposing overfished and constraining groundfish species to severe overages. 
    • Inability to Administer the Tiered Sablefish Fishery: Under Amendment 14 to the Pacific Coast Groundfish FMP, limited entry permit stacking allows vessels to harvest specific sablefish tier limits. Paper landing receipts traditionally resulted in a 2- to 4-month reporting lag, making it impossible to distinguish between primary tier landings and Daily Trip Limit (DTL) landings in-season. Electronic fish tickets provide the only mechanism to link federal LE permit numbers, IFQ vessel accounts, and sablefish tiers directly to state landing receipts. 
    • Ecological & Biological Risks: Lacking timely landing data forces managers to rely on historical estimates (such as the Quota Species Monitoring Best Estimate Report), creating significant time delays and catch inaccuracies. Delayed reporting increases the risk of exceeding Annual Catch Limits (ACLs), Optimum Yield (OY) targets, and biological opinion thresholds for protected and overfished species, potentially triggering emergency fishery closures. 
    • Compromised Enforcement & Compliance: Electronic fish tickets deliver immediate landing records to NOAA Office of Law Enforcement (OLE) and state wildlife officers. Less frequent collection would eliminate the real-time oversight necessary to detect illegal landings, unpermitted catch, or quota fraud, leaving enforcement agencies unable to respond effectively to fishery violations.

    7.  Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
Respondents are required to submit fish tickets as landings occur. Collecting landing receipts concurrently with the end of a fishing trip and transfer of fish to a first receiver is crucial to providing real-time data by which NMFS fisheries biologists and enforcement managers can monitor allocations, quotas, and various fishing limit parameters for the species which we are tasked to manage and protect.
The collection will be conducted in a manner consistent with all other OMB guidelines.

    8.  Provide a copy of the PRA Federal Register notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.
A Federal Register Notice published May 18, 2026 (91 FR 28579) solicited public comment. No comments were received.
NOAA consulted with 4 non-NOAA stakeholders to obtain their views on the need for, and practical utility of the data collected, the accuracy of the burden and frequency of collection, suggestions to minimize the burden, and ways to improve the clarity of instructions and forms. Non-NOAA stakeholders included staff from PSFMC, CDFW, ODFW, and WDFW. The IFQ Catch Monitor Program Coordinator, Kelsey Lawson, and Siobhan Oberg, the E-Tix contact at PSFMC suggested contacts at the state Departments of Fish and Wildlife (DFWs) and provided current screenshots for each of the state electronic fish tickets that users are required to submit. Email outreach was sent to CDFW, ODFW, and WDFW staff requesting they confirm or update NOAA's estimate of burden of the proposed collection of information and a copy of the burden table and answers from Qs 12-13 were included. Information solicited included Limited Entry Fixed Gear (LEFG) and Open Access (OA) Daily Trip Limit (DTL) participants, as well as any commercial fishers required to submit electronic fish tickets in each state, excluding those participating in the West Coast Groundfish IFQ fishery. Additionally, suggestions for ways to minimize the burden of the collection of information were solicited. 
All of the state DFWs responded to the request providing a summary of 2025 annual fish tickets with groundfish landings or the number of individual groundfish fish tickets submitted for the last 5 years by unique dealers (fish buyers and purchasing agents). Two data analysts from PSFMC worked to pull the specific numbers from PacFIN that this PRA information collection is focused on. After an in-depth discussion with them to validate the data, annual information from 2022 to 2025 was averaged to update the burden table in Q12. 

    9.  Explain any decisions to provide payments or gifts 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 assurance in statute, regulation, or agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
Electronic fish ticket data is submitted to PSMFC from the states and maintained on the PacFIN database. PacFin is run through a partnership between the Pacific States Marine Fisheries Commission (PSMFC), NOAA, Pacific Fishery Management Council (PFMC), and state wildlife agencies in California, Oregon, and Washington. The data is considered confidential under NOAA Administrative Order 216-100, Protection of Confidential Fisheries Statistics. NOAA and PFMC are generally data users able to access, query, and pull data through the PacFIN website.
    11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. 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 an estimate in hours of the burden of the collection of information.
There is a chance that some first receivers would need to fill out more than one ticket per landing. This could happen when a vessel fishes at the end of their primary (tier) quota and switches over to the DTL fishery. This would only happen once for each vessel, if at all, and would not substantially increase the burden on first receivers. The possibility of this occurring was taken into account when determining the time average.

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 / Response1
(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)
Electronic Fish Tickets
Buyer & Purchasing Agent
181

4,475

149

$6,349
Electronic fish tickets (WA)
Buyer & Purchasing Agent
16
11.75
188
2 mins
6
$44.53
$279
Electronic fish tickets (OR)
Buyer & Purchasing Agent
38
12.66
481
2 mins
16
$38.53
$618
Electronic fish tickets (CA)
Buyer & Purchasing Agent
101
18.93
1,912
2 mins
64
$43.70
$2,785
Electronic fish tickets/IFQ First Receiver submissions
Buyer & Purchasing Agent
26
72.85
1,894
10 mins
63
$42.25
$2,667
Electronic fish tickets/IFQ First Receiver Pacific whiting disposition recordkeeping
Buyer & Purchasing Agent
82
41.8
334
1 min
6
$42.25
$254
Totals

189

4,809

155

$6,603
*Rounding is reflected in the chart at question 12 to correlate with the ROCIS calculations and automatic rounding.
*Occupational Code Used: Buyers and Purchasing Agents: 13-1020 (for each state)
WA - $44.53
OR - $38.53
CA - $43.70
Average rate:  $42.25 – this rate was used for the Electronic Fish Tickets/IFQ First Receiver Submissions and Pacific Whiting Disposition Recordkeeping.

The Hourly Mean Wage from the BLS Occupational Employment and Wage Statistics (https://www.bls.gov/oes/2025/may/oessrcst.htm) was used to determine applicable wage rates.

    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).

Electronic fish tickets should not result in additional expenses due to continuing reporting requirements. It is assumed that all the small businesses already have access to a technically suitable computer and internet connection to submit the electronic fish tickets.

Otherwise, there are no recordkeeping or reporting costs. This information is already collected and analyzed by the states, either through paper tickets or electronic tickets, so there will not be an added burden on the state or enforcement agencies.

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

There are no Federal staff costs incurred as a result of continued implementation of electronic fish tickets on the West Coast sablefish fisheries. Analysts already receive this data through both Federal and State requirements, allowing for efficient tracking of groundfish landings. Federal staff costs included here include only the preparation of the PRA request.

Cost Descriptions
Grade/Step
Loaded Salary /Cost
% of Effort
Fringe (if Applicable)
Total Cost to Government
Federal Oversight
ZP III/Step 1
$139,806
1.0%

$1,398
Other Federal Positions





Contractor Cost





Travel





Other Costs:





TOTAL




$1,398

The federal salaries were determined using the Department of Commerce Alternative Personnel Pay System (CAPS) pay tables under PPS: RUSZP, Path: ZP III Step 1. A multiplier of 1.5 was used to calculate the loaded salary.  https://www.commerce.gov/sites/default/files/2026-01/CAPS%20Standard%20Pay%20Tables%202026.pdf 
    15.  Explain the reasons for any program changes or adjustments.

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

Electronic Fish Tickets
181
182 
4,475
 14,503
149
2,098
 
     Electronic fish tickets (WA fish ticket reporting) 
16
15
188
218
6
7
Previous information was a rough estimate from the PacFIN’s publicly accessible user interface; current numbers are from a more accurate query performed by PSFMC Data Analysts
     Electronic fish tickets (OR fish ticket reporting)
38
17
481
113
16
4
Previous information was a rough estimate from the PacFIN’s publicly accessible user interface; current numbers are from a more accurate query performed by PSFMC Data Analysts
     Electronic fish tickets (CA fish ticket reporting)
101
109
1,912
2,063
64
69
Previous information was a rough estimate from the PacFIN’s publicly accessible user interface; current numbers are from a more accurate query performed by PSFMC Data Analysts
     Electronic fish tickets/IFQ First Receiver submissions
26
 41
1,894 
12,109 
 63
 2,018
Previous information included all First Receiver Site License Holders as respondents; current numbers are only those who received an IFQ Landings during the year and submitted E-Tix.
Electronic fish tickets/IFQ First Receiver Pacific whiting disposition recordkeeping
 8
 9
 334
 234
6 
 4
 No significant change.
Total for Collection
 189
 191
4,809
 14,737
155
2,102 
 
Difference
 -2
 -9,928
 -1,947
 


The number of respondents, annual responses, and burden hours have changed as a result of stakeholder feedback from the state Departments of Fish and Wildlife and PSFMC staff, which provided the most current and updated information available.
    16.  For collections whose results will be published, outline the 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.
NOAA National Marine Fisheries Service will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy. The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subjected to quality control measures, and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.  There are no plans for publishing this data.

    17.  If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons why display would be inappropriate.
The agency is seeking continued approval to not display the OMB expiration date on the (forms/surveys/questionnaires) associated with this information collection. The paper and electronic forms in this collection are requirements of the states of Washington, Oregon, and California and, as such, there are no requirements to display expiration dates for OMB approval.  NOAA has requested on multiple occasions that the OMB Control Number and Expiration Date be added to the E-Tix sites, but the states have not included this information to date.

    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).