Supporting Statement A

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SUPPORTING STATEMENT
U.S. Department of Commerce
National Oceanic & Atmospheric Administration
Antarctic Marine Living Resources Conservation and Management Measures
OMB Control No. 0648-0194

Abstract
This request is for extension of a current information collection.
Established by the 1982 Convention, the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR) employs an ecosystem-based approach to protect and conserve Antarctic marine life. This framework ensures the preservation of individual species and the broader ecosystem while balancing responsible resource harvesting with the maintenance of vital ecological relationships. 

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 1982 Convention on the Conservation of Antarctic Marine Living Resources1 (Convention) established the Commission for the Conservation of Antarctic Marine Living Resources2 (CCAMLR) for the purpose of protecting and conserving the marine living resources in the waters surrounding Antarctica. The Convention is based upon an ecosystem approach to the conservation of marine living resources and incorporates standards designed to ensure the conservation of individual populations and species and the Antarctic marine ecosystem as a whole. Under this framework, conservation measures are developed to manage harvesting responsibly while preserving broader ecological relationships.
The United States is a contracting party to the Convention and an active member of CCAMLR and the Scientific Committee established by the Commission. In this role, the United States participates directly in evaluating scientific data, establishing conservation measures, and ensuring international compliance across marine management initiatives.
On November 8, 1984, the President signed Public Law 98-623, the Antarctic Marine Living Resources Convention Act3 (the Act). The Act directs and authorizes the United States to take actions necessary to meet its treaty obligations as a contracting party to the Convention through its implementing regulations. As such, the United States requires the collection of certain information from members of the public to fulfill its obligations as a Member of CCAMLR, monitor resource utilization, and ensure the legality of any harvesting activities.

2.	Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. 
This collection of information covers reporting requirements for CCAMLR Ecosystem Monitoring Program (CEMP) endeavors, scientific research conducted within the CAMLR Convention Area, U.S. vessel permit applicants and operators, and U.S. entities importing or re-exporting Antarctic marine living resources (AMLR).
Under U.S. regulations, any individual subject to U.S. jurisdiction seeking to harvest, transship, or import AMLR, or to enter and conduct activities within a CEMP site, must apply for and hold a valid permit. Additionally, individuals participating in specified scientific research in the CAMLR Convention Area are required to submit particular reports as outlined below.
The Act and its implementing regulations enforce the Convention. To enable the compilation of reliable catch and effort statistics, Convention Members must submit information regarding harvesting activities—including fishing areas and vessels—in the manner and at intervals prescribed by the Commission.
Pursuant to Article XX of the Convention, Members agree to take advantage of opportunities to assess harvesting impacts. Members must also report to the Commission on actions taken to implement adopted conservation measures. Furthermore, Article XXI mandates that Contracting Parties take appropriate measures to ensure compliance with the Convention and its conservation measures, transmitting information on these actions—including any imposed sanctions—to the Commission.
Following a review of the Convention and Commission conservation measures, the Department of Commerce (DOC) determined that a permitting system offers the most effective mechanism to track activities involving Antarctic resources, supply treaty data to the Commission, fulfill international obligations, and maintain compliance without placing undue burdens on harvesting and importing operations.
U.S. regulations govern the harvesting and importation into the United States of any AMLR, part, or product by persons subject to U.S. jurisdiction, including U.S. citizens and prospective importers.
Under the Antarctic Conservation Act of 1978, the National Science Foundation (NSF) holds permitting authority for collecting native mammals, birds, and certain plants south of 60 degrees South latitude. To reduce paperwork burdens on the public, regulations at 50 CFR 300 Subpart G exempt Antarctic harvesters or importers holding an NSF permit or award letter—or a National Marine Fisheries Service (NMFS) marine mammal or endangered species permit—from obtaining a separate NMFS AMLR permit. Although exempt from obtaining a separate NMFS AMLR permit, NSF permit or award holders remain subject to data reporting requirements under both their NSF or NMFS authorization and CCAMLR guidelines. 

I.  CEMP Entry Permits
Under AMLR regulations, anyone planning to enter or conduct research at a CEMP site must apply to NMFS for an entry permit. Permit holders must comply with all permit terms, including submitting an annual report detailing their activities and any instances of non-compliance with the site's management plan. These permits remain valid for five years. If a CEMP site is also designated as a specially protected area under the Antarctic Conservation Act of 1978, applicants are directed to the National Science Foundation to apply for a dual permit. While a single permit covers both designations, annual reports must be submitted separately to each agency for areas within its jurisdiction.

II.  Harvest or Transshipment
A.  New and exploratory fisheries
In 1991, the United States granted a harvesting permit within the Convention Area to a single U.S. fisher for an inaugural crab fishery. Upon receiving notice of this authorization, CCAMLR voiced unified concern that the fishery had proceeded without adequate understanding of the target species' demographic profile, despite the U.S. requiring a Research and Data Collection Plan during the application process.
Emphasizing the vital need for member states to meet their obligations to submit biological, statistical, and supplementary data under the treaty, the Commission subsequently established targeted conservation measures governing new and exploratory fisheries.
1. New fisheries
The Commission adopted a measure which requires Members to notify the Commission when it is considering initiating a new fishery in the Convention Area. The Commission must receive the notification not less than 3 months in advance of the next regular meeting of the Commission. The Member may not initiate the new fishery pending Commission review. The notification to the Commission must be accompanied by as much of the following information as the Member is able to provide: 
    • The nature of the proposed fishery including target species, methods of fishing, proposed region and maximum catches levels proposed for the forthcoming season;
    • Biological information on the target species from comprehensive research/survey cruises, such as distribution, abundance, demographic data and information on stock identity;
    • Details of dependent and related species and the likelihood of them being affected by the proposed fishery;
    • Information from other fisheries in the region or similar fisheries elsewhere that may assist in the evaluation of potential yield;
    • If the proposed fishery will be undertaken using bottom trawl gear, information on the known and anticipated impacts of this gear on vulnerable marine ecosystems, including benthos and benthic communities.
2. Exploratory fisheries
The Commission established a regulation governing exploratory fisheries, which are defined as fisheries previously designated as new fisheries and reviewed by both the Scientific Committee and the Commission before commencing operations.
A fishery retains its exploratory classification until adequate data are gathered to assess its potential yield and examine its effects on associated and dependent species. This data collection enables the Scientific Committee to formulate guidance for the Commission regarding suitable gear specifications, effort limits, and catch levels.
To supply sufficient data for Scientific Committee reviews throughout the exploratory phase, the Scientific Committee formulates and revises a Data Collection Plan every year. Participating Member nations are required to report the details requested in this plan to CCAMLR annually. Additionally, fishing effort and capacity are controlled via precautionary catch limits set close to the minimum amount required to satisfy the Data Collection Plan's requirements.
As applicable, the Data Collection Plan incorporates the following elements:
    • Detailed information on catch, effort, and relevant biological, ecological, and environmental data needed to evaluate the fishery;
    • A strategy to guide fishing effort throughout the exploratory phase, facilitating data collection to assess fishery potential, ecological interactions among harvested, dependent, and related stocks, and potential adverse impacts;
    • A framework for gathering additional research data via fishing vessels—including collaborative operations between vessels and scientific observers—necessary for the Scientific Committee to analyze fishery potential, ecological dynamics, and adverse impact risks; and
    • An assessment of the timeframes required to observe population responses among harvested, dependent, and related species to fishing operations.
Each Member actively engaged in the fishery or planning to authorize a vessel for entry must annually prepare and submit a Research and Fishery Operations Plan to CCAMLR. To assist the Scientific Committee in formulating the Data Collection Plan, this submission should incorporate as much of the following information as possible:
    • Proposed fishery operational scope: details regarding target species, harvest methods, designated region, and projected maximum catch limits for the upcoming season;
    • Fishing gear specifications: comprehensive descriptions and technical specifications of all gear types intended for deployment;
    • Biological data: insights derived from comprehensive survey/research cruises, covering demographic data, abundance, spatial distribution, and stock identity;
    • Ecological impacts: information concerning dependent and related species, including the potential impacts of the proposed fishing activities on these populations;
    • Yield evaluation context: data from existing fisheries in the area or comparable fisheries elsewhere to aid in potential yield assessments; and
    • Benthic impact assessment: for operations utilizing bottom trawl gear, details regarding known and anticipated effects on benthic communities, benthos, and vulnerable marine ecosystems.
B. Harvesting and/or Transshipment Permit 
CCAMLR mandates specific information for any vessel licensed by a member country to operate within the Convention Area:
    • Vessel identification: current fishing vessel name, any prior names (if known), IMO number, registration number, and previous flag (if applicable);
    • Registry and markings: port of registry, external markings, and three color photographs depicting the stern, port side, and starboard side;
    • Vessel specs and communications: vessel length, vessel type, place and date of construction, international radio call sign, and communication contacts and modalities;
    • Ownership details: full names and addresses of vessel owners, any known beneficial owners, and the license holder (if separate from the vessel owner);
    • Flag state authorization: terms of the fishing authorization, including issue date, authorized fishing windows, designated zones, target species, and permitted gear; and
    • VMS compliance: specifics regarding implementation of tamper-resistant protections on satellite-linked vessel monitoring equipment.
The Commission requested that the following supplemental vessel details be provided whenever practicable:
    • Operator name and address (if different from the vessel owner);
    • Name and nationality of the master and, if applicable, the fishing master;
    • Gross registered tonnage;
    • Vessel beam (in meters);
    • Main engine output power (in kilowatts);
    • Standard crew complement size;
    • Carrying capacity (in tonnes);
    • Fish hold count and respective volumetric capacity (in cubic meters);
    • Ice classification specifications, if relevant;
    • Freezing rate capacity metrics; and
    • Any additional information regarding licensed vessels deemed necessary to support the commission's conservation measures.
NMFS gathers these specifications through the Vessel Identification Form (VIF) during the AMLR harvesting and transshipment permitting process. Permit applications feature distinct sections for vessel owners seeking authorization to harvest AMLR or to transship toothfish, with applicants able to complete either or both sections. Depending on the requested activities—AMLR harvesting, receiving transshipments, or both—permits are issued in one of three corresponding formats.
The Harvesting Information Form (HIF) collects data to ensure proposed activities align with CCAMLR conservation measures. It requires a narrative description of target AMLR species, targeted catch tonnage, designated CCAMLR statistical fishing areas, intended gear types, and anticipated bycatch volumes. The issued harvesting permit explicitly obligates holders to submit catch data to both NMFS and CCAMLR. For proposed harvesting involving new or exploratory fisheries, applicants must also supply the specific narrative descriptions outlined above.
All information submitted through these application forms is utilized to fulfill reporting requirements to the Executive Secretary of CCAMLR.
The NMFS forms associated with applying for a harvesting and/or transshipment permit are: 
    • Application for Permit to Transship AMLR
    • Vessel Monitoring System Certification Statement
    • Harvesting Information Form
    • Vessel Identification Form
    • Additional Information for Vessels Participating in a New or Exploratory Fishery
C. Radio Contact
When requested by NMFS, the U.S. Coast Guard, an authorized officer, or a CCAMLR inspector, vessel operators may be required to communicate their position or other operational data via radio. This standard law enforcement procedure is necessary during at-sea operations. Typically, it involves transmitting the vessel's radio call sign and current geographic coordinates shortly before law enforcement personnel board to inspect the vessel and its activities. These radio transmissions occur infrequently and are brief.
D. Centralized Vessel Monitoring System
Conservation Measure 10-04, established by the Commission, mandates the implementation of a centralized vessel monitoring system (C-VMS). Vessels operating within CCAMLR-managed waters must carry a VMS unit that automatically transmits positional data to their Flag State's land-based fisheries monitoring center at least once per hour.
Contracting Parties to the Convention are required to forward these VMS reports and messages to the CCAMLR Secretariat promptly—within one hour of receipt for exploratory longline fisheries, and no later than 10 working days after departing the Convention Area for all other fisheries. Alternatively, Contracting Parties may choose to stream C-VMS data directly to the Secretariat in parallel with the reports delivered to the Flag State.
Under AMLR regulations, all U.S. vessels harvesting AMLR in the CAMLR Convention Area must utilize centralized satellite-linked VMS. To maintain continuous coverage throughout the entire fishing operation, U.S. vessels are required to operate their VMS continuously from departure to return at their homeport.
The United States also mandates real-time, port-to-port C-VMS participation for foreign vessels harvesting toothfish included in shipments intended for the U.S. seafood market. Import pre-approval applications will be denied if the harvesting vessel's C-VMS was not operational as required. This measure was adopted following repeated issues involving toothfish shipments declared as harvested outside the Convention Area that were suspected of being taken illegally from within it.
Information gathered from individual vessel VMS transmissions is restricted strictly to compliance functions, such as active surveillance monitoring and boarding inspections. This includes verifying the details recorded on Dissostichus Catch Documents (DCDs), which CCAMLR Members utilize to validate the harvest, transshipment, or landing of toothfish (refer to subsection III.B below for additional details on DCDs).
E. Vessel marking
Vessels are required to clearly display their name and International Radio Call Sign (IRCS) amidships on both the port and starboard sides of the hull or superstructure, ensuring constant visibility from the air, other vessels, or inspection and enforcement craft. Additionally, the vessel’s IRCS must be marked on the deck in compliance with the criteria in 50 CFR 300.108. Displaying this official identifier enables inspectors and law enforcement officials to track fishing, at-sea processing, and associated operations to verify that all observed actions align with authorized activities. Identifying numbers are routinely relied upon by NMFS, the U.S. Coast Guard, and partner agencies when issuing violations, pursuing prosecutions, or initiating other regulatory enforcement.
Pursuant to the CCAMLR System of Inspection, designated CCAMLR Inspectors possess the authority to board and inspect any contracting party or member fishing and research vessels within the Convention Area for compliance with established conservation measures. Proper marking facilitates the prompt identification of member vessels, streamlines the prosecution of marking infractions, and yields more cost-effective enforcement. Furthermore, compliant fishers leverage these markings to report suspicious activities encountered at sea. Ultimately, clear vessel identification protects legitimate fisheries by deterring illegal and unauthorized operations, thereby sparing authorized vessels from more restrictive regulatory burdens.
F. Gear Marking 
Pursuant to 50 CFR 300.108, vessel operators fishing under an AMLR permit within the CAMLR Convention Area are required to mark all fishing gear with the vessel’s official identification markings. These markings allow International CCAMLR Inspectors to effectively monitor compliance with fisheries management rules and regulations. International agreements authorize CCAMLR Inspectors to board harvesting vessels operating in the Convention Area to verify adherence to conservation measures, including gear marking and restriction requirements. Proper gear identification ensures that operators harvest only from their own traps, pots, or other gear and deters the illegal deployment or placement of gear. Furthermore, NMFS, the U.S. Coast Guard, and partner agencies rely on these identifying numbers to issue violations, pursue prosecutions, and execute enforcement actions, with non-compliant gear subject to potential confiscation. By making fishing violations easier to prosecute, gear marking supports more cost-effective enforcement.
Although NMFS regulations do not require gear owners to confirm the precise markings used, and no gear marking records are maintained on file, these external identifiers help establish ownership during civil proceedings or incidents involving loss or damage. None of this information is disseminated to the public.
G. Scientific Observers
At its 11th annual meeting in 1992, CCAMLR established the Scheme of International Scientific Observation. Under this framework, observers deployed aboard fishing vessels monitor and report on harvesting operations and catches of target and associated marine living resources. Using standard protocols and reporting forms supplied by the CCAMLR Secretariat, observers carry out duties such as:
    • Documenting vessel operational details;
    • Sampling catches and recording species-specific biological data;
    • Recording bycatch, as well as seabird and marine mammal entanglements or incidental mortalities;
    • Verifying the methodologies utilized to measure declared catch weights;
    • Gathering and reporting observational data on fishing vessels encountered in the Convention Area, including location, activity, and vessel type identification; and
    • Collecting details on lost fishing gear and shipboard waste disposal practices at sea.
In accordance with CCAMLR conservation measures and NMFS regulations, all U.S. vessels fishing within the Convention Area (including krill harvesting vessels), as well as U.S. vessels conducting pre-fishery longline testing outside the area, must embark one or more designated scientific observers. Once onboard, the observer collects vessel, catch, and fishing effort data for transmission to both NMFS and CCAMLR.
Within this established observer program, the sole information collection subject to Paperwork Reduction Act oversight is the request submitted by a vessel owner, operator, or fisher for observer coverage. To arrange deployment prior to a trip, the responsible party submits a request either directly to an observer provider or to the Southwest Fisheries Science Center/Antarctic Ecosystem Research Division.
H. Transshipment Notifications
To comply with CCAMLR mandates, vessel operators must report any intended transshipment of AMLRs, goods, or other materials within the Convention Area at least 72 hours in advance. This notification must be transmitted directly to the CCAMLR Secretariat, and a written confirmation of the notice must be submitted to NMFS Headquarters.
III. AMLR Trade Control and Monitoring
A. Permits
To fulfill its treaty obligations, the United States is required to monitor and regulate the import, export, and re-export of Antarctic marine living resources (AMLRs).
Anyone involved in importing, exporting, or re-exporting AMLRs in the U.S. must acquire an International Fisheries Trade Permit (IFTP). Valid for one year, this permit serves as a prerequisite for trading AMLR, though it does not constitute an authorization on its own. The IFTP requirements and the electronic submission of import/re-export filings are covered under a separate information collection (OMB No. 0648-0732).
Data collected through these permits helps NMFS construct and maintain a comprehensive database of all dealers importing or re-exporting product, ensuring NMFS can promptly inform dealers of any updated regulations. Presently, no U.S. vessels harvest AMLR, so all AMLR entering the United States is imported; as a result, there are no active U.S. exports of AMLR at the time of this PRA renewal.

B. Requirements for Toothfish Imports and Exports
To import frozen toothfish into the United States, dealers must secure a pre-approval certificate from NMFS and obtain documentation from CCAMLR's Dissostichus Catch Documentation Scheme (CDS). Release into U.S. customs territory requires a complete, validated, and electronically transmitted Dissostichus Catch Document (DCD) issued via the CCAMLR Secretariat's web-based E-CDS system. The Flag State issues a non-transferable DCD uniquely assigned to a vessel's fishing trip. Catch details are recorded by the vessel master, transmitted to the Flag State, and entered onto the unique DCD in the online system. During landing or transshipment, the landing State accesses the E-CDS portal to complete the required landing entries.
For exports, the exporting nation enters export information into the E-CDS system to issue a Dissostichus Export Document (DED). The NMFS CDS officer accesses the DCD and DED within E-CDS and compares the Electronic Catch Document to the import pre-approval application. NMFS approves the import provided all details match and additional requirements—including verification of port-to-port C-VMS tracking for the vessel trip—are satisfied.
Importers must acquire the document number and export reference number from the corresponding E-DED and include both identifiers in their pre-approval application.
Anyone importing frozen toothfish shipments into the U.S. must submit an Application for Pre-Approval Certificate to Import Frozen Toothfish to NMFS. Registered dealers may apply through the NMFS online seafood trade tracking system, with registration handled by NMFS upon request. Alternatively, applicants may complete a fillable PDF form.
Applications must include required information and fee payment, remitted via Pay.gov for online submissions or by check for paper forms. NMFS must receive applications at least 10 business days before the anticipated import date. Because some importers face difficulties acquiring U.S. Customs Form 7501 entry numbers 10 days in advance, NMFS permits submission of the Form 7501 entry number up to 3 working days prior to arrival, while all remaining details must be submitted 10 days prior. This advance notice does not impose a burden on importers, as ocean transit times provide adequate lead time to obtain necessary information.
Each export from a foreign country requires a unique DED and export reference number, and a single DED cannot cover multiple shipments. However, a single DCD may be reused with distinct DEDs when a vessel's overall catch is divided across multiple shipments. The toothfish quantity reported on the DED must agree with the pre-approval application within a 10 percent weight tolerance. Following review of the required documentation received 10 business days in advance, NMFS determines eligibility and issues an import approval certificate to the applicant.
A $200.00 fee is required for frozen toothfish pre-approval applications. NMFS estimates receiving 612 applications annually, with approximately 85 percent (520 applications) fulfilling pre-approval requirements and paying the fee. Pre-approvals may be denied for late submissions, documentation errors, or failure of the harvesting vessel to maintain continuous port-to-port C-VMS coverage.
Pre-approval is not required for fresh toothfish air shipments due to short transport times, low shipment frequency, and smaller volumes. Importers must report fresh air shipments within 24 hours of import using the Reporting Form for Shipments of Fresh Toothfish, accessible via the online portal for registered users. Fresh shipments remain subject to DCD and DED documentation requirements.
C. Re-Exports of Toothfish
To re-export toothfish, exporters must complete the Application for Re-export of Toothfish. This application requires details linked to the shipment's previously completed Dissostichus Catch Document (DCD), including the original DCD's document number and export reference number, product type, species, and re-export weight. It also requires the point of import, importer name, and the exporter's permit number, name, address, and email. Additionally, dealers must cite or attach the import approval documentation to assist in verifying the export reference and document numbers.
Using the E-CDS, the U.S. CDS Officer generates the re-export certificate on behalf of the dealer and serves as the validating authority to record the re-export document in the CCAMLR Secretariat's E-CDS system. The re-export document is subsequently included with the shipment when it is re-exported from the United States.
D. Import Ticket
Importers bringing in AMLR products other than toothfish must complete and file an import ticket within 24 hours of entry. This filing outlines specific details about the imported goods, including the importer's personal and corporate contact details, the date and description of the item, total quantity, the flag state, and the harvesting vessel(s) involved.

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. 
Electronic copies of NMFS harvesting and dealer forms are available at https://www.fisheries.noaa.gov/permit/antarctic-marine-living-resource-program.  VMS data are electronically transmitted. DCDs are electronically generated, completed and transmitted. 
Neither the display of vessel identification numbers on weather decks, deckhouses, or hulls nor the marking of fishing gear with identifying numbers are suitable for advanced information technology applications.

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. 
There is no duplication with collection efforts. The information requested under this collection is unique to the Antarctic Marine Living Resources (AMLR) Program and is necessary to fulfill specific U.S. obligations as a Contracting Party to the Convention on the Conservation of Antarctic Marine Living Resources (CCAMLR). Similar data is not available through other agency collections or existing federal records. 

5.	If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
Since all of the respondents are considered small businesses, separate requirements based on size of business have not been developed. Only the minimum data necessary are requested. 

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. 
Not collecting this information, or conducting the collection on a less frequent basis, would prevent DOC/NOAA from obtaining the comprehensive and timely data required to effectively monitor and report on the harvesting, transshipment, and importation of AMLR resources. Without these regular updates, the United States could fail to fulfill its treaty obligations as a Contracting Party to the CAMLR Convention and as a Member of CCAMLR. Furthermore, if vessel and gear marking requirements are not routinely enforced, NMFS and the U.S. Coast Guard would be unable to carry out necessary at-sea law enforcement activities, and international CCAMLR Inspectors would be hindered from conducting effective gear and vessel inspections to deter illegal, unreported, and unregulated fishing.

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

8.	If applicable, provide a copy and identify the date and page number of publications in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
A Federal Register Notice published on May 4, 2026 (91 FR 23975) solicited public comments.  No comments were received during the comment period. 
Applicants are contacted regularly regarding the information collected to monitor trade of AMLR. We have received no feedback from applicants regarding information collection burdens.

9.	Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts given 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 system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
As stated on the collection forms, the data collected will be kept confidential as required by section 402(b) of the Magnuson-Stevens Act and NOAA Administrative Order 216-1004, Confidentiality of Fisheries Statistics, and will not be released in a manner that discloses confidential business information. 
Consistent with OMB’s guidance implementing the Privacy Act of 1974, “an agency record-keeping system on firms it regulates may contain “records” (i.e., personal information) about officers of the firm incident to evaluating the firm’s performance.  Even though these are clearly “records” under the “control of” an agency, they would not be considered part of a system as defined by the Act unless the agency accessed them by reference to a personal identifier (name, etc.).  That is, if these hypothetical “records” are never retrieved except by reference to company identifier or some other nonpersonal indexing scheme (e.g., type of firm) they are not a part of a system of records.”  NOAA believes this guidance speaks directly to this scenario and suggests that while the information system certainly will collect and maintain personally identifiable information (PII), it is not maintained in a system of records.

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

SSA Part
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)
Ia)
5-year CEMP permit application
Physical Scientist (19-2099)
1
1 every 5 years
0.2
0.2
0
$62.13
$0
Ib)
CEMP annual report
19-2099
1*
1
1
1
1
$62.13
$62
II A)
Applicants for new or exploratory fishery
19-2099
2*
1
2
28
56
$62.13
$3,479 
II B)
Harvest and/or transshipment applications
Captains, Mates & Pilots of Water Vessels (53-5021)
5
1
5
2
10
$49.87
$499
II C)
Radio transmissions
First-Line Supervisor of Farming, Fishing & Forestry Workers (45-1011)
5*
2
10
0.0833
1
$30.16
$30
II D)
Centralized VMS
45-1011
5*
1
5
2.8
14
$30.16
$422
 
Installation (burden averaged over 5 years) 
5*
1
5
4
4
 
 
 
VMS certifications (burden averaged over 5 years) 
5*
1
5
 
 
 
 
 
Maintenance 
5*
1
5
2
10
 
 
 
Installation & Activation Checklist (burden averaged over 5 years) 
5*
1
5
0.0833
0.4165
 
 
 
Annual VMS transmission costs 
5*
1
5
N/A
N/A
 
 
II E)
Vessel Marking
45-1011
5*
3
15
0.25
4
$30.16
$121
II F)
Gear Marking (2 Longline vessels, 1 Crab Vessel, 2 Trawl Vessels)
45-1011
5*
6
12
10.1166
11
$30.16
$332
 
Buoys/floats
 
2
4
8
0.0833
0.6664
 
 
 
Traps/pots
 
1
1
1
10
10
 
 
 
Tag Sewn into Net (Trawl gear)
2
1
3
0.0333
0.4
 
 
II G)
Request for Observer
45-1011
5*
1
5
0.0833
0
$30.16
$0
II H)
Transshipment Notification
45-1011
1*
5
5
0.25
1
$30.16
$30
III A)
First Receiver Permit Applications (includes designating a registered agent)
Buyers & Purchasing Agents (13-1020)
1
1
1
0.25
0
$40.27
$0
III B)
Toothfish Import/Export
13-1020
72
7.8333
564
0.2748
155
$40.27
$6,242
 
Shipments of Fresh Toothfish
 
2*
2
4
0.5
2
 
 
 
Pre-Approval Applications
 
70*
8
560
0.25
153
 
 
III C)
Re-Export of Toothfish
Wholesaler Trade & Broker (41-4012)
10*
40
400
0.25
100
$39.68
$3,968
III D)
Import Tickets
41-4012
2*
4
8
0.25
2
$39.68
$79

Totals
 
120
 
1033
 
355
 
$15,264
There are 79 unique respondents.
* Respondents in this column are not additive: unique respondents are the CEMP applicant, 5 vessels/vessel representatives, 1 first receiver applicant, and 72 dealers. All asterisked figures indicate the same set or a subset of one of these four respondent categories.
Wage rates were obtained from BLS:  https://data.bls.gov/oes/#/area/0000000/2025
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).

SSA Part
Information Collection
# of Respondents
Annual # of Responses / Respondent
 Total # of Annual Responses
Cost Burden / Response
Total Annual Cost Burden
Ia)
5-year CEMP permit application
1
1 every 5 years
0.2
$0.78
$0
Ib)
CEMP annual report
1*
1
1
$0.78
$1
II A)
Applicants for new or exploratory fishery
2*
1
2
$0.78
$2
II B)
Harvest and/or transshipment applications
5
1
5
$0.78
$4
II C)
Radio transmissions
5*
2
10
0
0
II D)
Centralized VMS
5*
1
5
$1,400.40
$7,002
 
Installation (burden averaged over 5 years)
5*
1
5
$2,250
$2,250
 
VMS certifications (burden averaged over 5 years)
5*
1
5
$0.78
$1
 
Maintenance
5*
1
5
$350
$1,750
 
Installation & Activation Checklist (burden averaged over 5 years)
5*
1
5
$0.78
$1
 
Annual VMS transmission costs
5*
1
5
$600
$3,000
II E)
Vessel Marking
5*
3
15
$40
$600
II F)
Gear Marking (2 Longline vessels, 1 Crab Vessel, 2 Trawl Vessels)
5*
6
12
$40
$480
 
Buoys/floats
2
4
8
 
 
 
Traps/pots
1
1
1
 
 
 
Tag Sewn into Net (Trawl gear)
2
1
3
 
 
II G)
Request for Observer
5*
1
5
$1.50
$8
II H)
Transshipment Notification
1*
5
5
0
0
III A)
First Receiver Permit Applications (includes designating a registered agent)
1
1
1
$0.78
$1
III B)
Toothfish Import/Export
72*
7.833
564
$199.36
$112,440
 
Shipments of Fresh Toothfish
2*
2
4
$0.78
$3
 
Pre-Approval Applications
70*
8
560
$200.78
$112,437
III C)
Re-Export of Toothfish
10*
40
400
$0.78
$312
III D)
Import Tickets
2*
4
8
$0.78
$6
 
TOTALS
 
 
1,033
 
$130,854**
* Respondents in this column are not additive: unique respondents are the CEMP applicant, 5 vessels/vessel representatives, 1 first receiver applicant, and 72 dealers. All asterisked figures indicate the same set or a subset of one of these four respondent categories.
** The difference between this table and ROCIS is due to rounding.

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. 
The Commerce Alternative Personnel System (CAPS) pay tables5 for the Rest of U.S. locality rates were used to determine the base salary.  The Rest of U.S. locality was used since NOAA staff are geographically dispersed.  The upper bound for Interval 3 of each Pay Band was used as the base salary and a multiplier of 1.5 was used to calculate the loaded salary.

Cost Descriptions
Grade/Step
Loaded Salary /Cost
% of Effort
Fringe (if Applicable)
Total Cost to Government
Federal trade monitoring position
 ZA III
$173,543
75%
 
$130,907
Contractor

$80,000
25%

$20,000
Vessel permitting and monitoring position
 ZA III
$173,543
 1%
 
 $1,735
 
 
 
 
 
 
Travel
 
 
 
 
 
Other Costs:
 
 
 
 
 
TOTAL
 
 
 
 
 $152,642
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

5-year CEMP permit application
1
1
0
0
0
0
 
CEMP annual report
1
1
1
1
1
1
 
Applicants for new or exploratory fishery
2
2
2
2
56
56
 
Harvest and/or transshipment applications
5
5
5
5
10
10
 
Radio transmissions
5
5
10
10
1
1
 
Centralized VMS
5
5
5
5
14
14
 
Vessel Marking
5
5
15
15
4
4
 
Gear Marking (2 Longline vessels, 1 Crab Vessel, 2 Trawl Vessels)
5
5
12
12
11
11
 
Request for Observer
5
5
5
5
0
1
Response time was reduced from 10 minutes to 5 minutes to more accurately reflect the actual burden time.
Transshipment Notification
1
1
5
5
1
1
 
First Receiver Permit Applications (includes designating a registered agent)
1
1
1
1
0
0
 
Toothfish Import/Export
72
82
564
766
155
193
The number of dealers has decreased and each dealer now submits more responses.  The number of responses overall has decreased as a result of fewer imports.
Re-Export of Toothfish
10
10
400
352
100
88
Math calculations were incorrect in the previous renewal pkg.
Import Tickets
2
2
8
8
2
2
 
Total for Collection
120
130
1033
1187
355
382
 
Difference
-10
-154
-27
 

Information Collection
Miscellaneous Costs
Reason for change or adjustment

Current
Previous

5-year CEMP permit application
$0
$0
 
CEMP annual report
$1
$1
 
Applicants for new or exploratory fishery
$2
$1
Postage increase
Harvest and/or transshipment applications
$4
$3
Postage increase
Radio transmissions
$0
$0
 
Centralized VMS
$7,002
$16,006
The previous submission did not annualize all costs.
Vessel Marking
$600
$600
 
Gear Marking (2 Longline vessels, 1 Crab Vessel, 2 Trawl Vessels)
$480
$480
 
Request for Observer
$8
$8
 
Transshipment Notification
$0
$0
 
First Receiver Permit Applications (includes designating a registered agent)
$1
$1
 
Toothfish Import/Export
$122,440
$152,883
Fewer import/export applications are submitted, reducing the overall cost burden.
Re-Export of Toothfish
$312
$222
Adjusted based on the corrected number of responses.
Import Tickets
$6
$5
Postage increase
Total for Collection
$130,855
$170,210
 
Difference
-$39,355*
 
*The difference between the table and ROCIS is due to rounding.
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.
The Ecosystem Monitoring and Management Working Group of the CCAMLR Scientific Committee compiles the research and required permit reports submitted by Member States on CEMP site activity and presents these findings in a published form to the Commission. These published reports are available to Member delegations and to interested individuals from the Commission. NMFS does not plan to make available results of any of the information collections discussed above on the Internet. The Executive Secretary of CCAMLR publishes information on harvesting vessel licenses, harvesting activity, and toothfish trade on password protected sections of the CCAMLR website.
NOAA 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. Although the information collected is not expected to be disseminated directly to the public, results may be used in scientific, management, technical or general informational publications. Should NOAA (insert line office) decide to disseminate the information, it will be subject to the quality control measures and pre-dissemination review pursuant to Section 515 of Public Law 106-554.

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 OMB expiration date is omitted from the Dissostichus Catch Document (DCD) due to its status as a CCAMLR-standardized form. Displaying a domestic administrative expiration date on documentation utilized across international jurisdictions could induce confusion and impede customs clearance processes abroad.
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).

B.	COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods.