AHCI ss 110106

SUPPORTING STATEMENT
ATLANTIC HAGFISH FISHERY COLLECTION OF INFORMATION
OMB CONTROL NO.: 0648-xxxx
INTRODUCTION:
This submission requests Office of Management and Budget (OMB) approval of the information
collection requirements associated with an information collection pilot program on the New
England hagfish (hagfish) fishery. Specifically, this clearance is for hagfish dealer permitting
and observer requirements. Electronic dealer and processor reporting requirements will also be
revised as a result of the hagfish information collection program and submitted for clearance
under OMB Control Numbers 0648-0229 and 0648-0018, respectively. This collection of
information for the hagfish fishery is being proposed under the provisions of section 402(a) of
the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act),
which allows for the collection of information on a fishery prior to its regulation under a Fishery
Management Plan (FMP). A request for an information collection on Atlantic hagfish was
received by the New England Fishery Management Council (Council) on October 3, 2006. This
collection of information may become permanent through the development and implementation
of the Atlantic hagfish FMP.
This information collection fulfills the requirements under section 402(a) of the MagnusonStevens Act. This data collection program would continue only until an FMP is implemented
(presumably sometime in 2008), and would involve a limited number of dealers and vessels (i.e.,
there are 2 hagfish dealers and 5 hagfish vessels known to participate in the hagfish fishery at
this time).
New collections that will increase the annual budget
The annual budget would increase slightly for the Northeast Region Permit Family of Forms
(OMB Control No.: 0648-0202), as per the hagfish collection of information observer coverage
and dealer permit requirements.
A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
Under the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens
Act), the Secretary of Commerce has responsibility for the conservation and management of
marine fishery resources off the coast of the U.S. The majority of this responsibility has been
delegated to the Regional Fishery Management Councils and NOAA Fisheries Service. The
New England Fishery Management Council (Council) develops management plans for fishery
resources in New England. In order to develop appropriate management measures and to better
understand the various aspects of a fishery that has been unregulated, section 402(a) of the
Magnuson-Stevens Act allows NOAA Fisheries Service to collect information prior to
development and implementation of a FMP.
The Atlantic Hagfish fishery is an unregulated fishery that relies on revenues from the export of
whole frozen hagfish product overseas, primarily to South Korea. In recent years, this fishery,
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which is prosecuted primarily off the coast of Gloucester, MA, has changed from an inshore
fishery comprised of small vessels to an offshore fishery that consists of large vessels.
According to reports from a workshop that was held to elucidate the challenges in collecting
information on this fishery, the reason for this change in the way the fishery is being conducted
is that the fishery has experienced localized depletion in nearshore waters necessitating
movement to areas not historically harvested for hagfish.
A control date* of August 28, 2002, has been reaffirmed to forewarn participants that the
Council and National Marine Fisheries Service (NMFS) will be considering the management of
hagfish in the future. The Council has decided to prioritize the management of hagfish and to
begin development of an FMP in 2007. The Northeast Regional Office’s Fisheries Statistics
Office (FSO) determined through their research of this fishery that five vessels on the U.S.
eastern seaboard participate in the hagfish fishery, and all these vessels are currently required to
provide catch information on their Fishing Vessel Trip Reports (FVTRs). Thus, vessel landings
information is already being captured in existing databases (hagfish dealer reporting through this
information collection will revise 0648-0229). In addition, due to a relative equilibrium between
supply and demand—the driving force being a South Korean market for hagfish meat – there is
stability in terms of participation in the NE hagfish fisheries that will likely remain unchanged.
However, while the market forces are understood, there remains an inability to obtain
information on new entrants to the fishery, verify vessel-level data, sub-sample the catch and
collect basic fleet information on the fishery. Therefore, dealers will be required to obtain
Federal hagfish dealer permits so that NMFS can obtain first purchase information on hagfish
landings to evaluate the biological, economic, and social implications of future management
measures. Also, vessel owners/operators who intend fish for, catch, and/or land hagfish taken in
or from the Exclusive Economic Zone (EEZ) will be required to take an observer on board their
vessel when requested in order to sample the catch and collect basic fleet information. This
information collection should enable the Council and NMFS to proceed with the development of
a management plan for hagfish.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
The information requested would be used by several offices of NMFS and the Council in its
development of the Hagfish FMP and to ensure that once implemented, the requirements for
monitoring the fisheries are effective and enforceable. Social and economic data will be used to
provide descriptive and behavioral information on the hagfish fishery and to provide estimates of
the value of this important export fishery.
Observer requirement
Under the Atlantic hagfish information collection pilot program, any vessel owner/operator that
intends to fish for, catch, or land hagfish taken in or from the EEZ would be required to take an
observer when requested to do so. Hagfish vessel owners would be required to call to arrange
deployment of observers on their vessels. These requests are made at the discretion of the
* Reference date for qualifying landings for future limited entry permit applications.
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Regional Administrator for the purpose of monitoring fishing activities, collection of data, and
compliance with pilot program requirements. An observer is necessary because of the high
discard rates (culling) that have been reported to occur in the hagfish fishery at sea due to
rejection of the live hagfish product at the docks and because the proportion of the catch that is
rejected by the dealer and later discarded at sea is not measured. The information collected by
observers may also be used to verify the information received by vessels through the FVTRs.
Dealer/Processor Permit Applications
Dealers that want to purchase/sell hagfish caught in Federal waters must have a hagfish-specific
Federal dealer permit. Hagfish dealers will be required to obtain an initial dealer permit upon
implementation of the hagfish information collection requirements and to renew the permit
annually. The dealer permit requirement ensures complete reporting from hagfish dealers.
Reports furnished by permitted dealers provide important information on the volume, value, and
distribution of value, at the point of first purchase.
It is anticipated that the information collected will be disseminated to the public or used to
support publicly disseminated information. As explained in the preceding paragraphs, the
information gathered has utility. NMFS will retain control over the information and safeguard it
from improper access, modification, and destruction, consistent with National Oceanic and
Atmospheric Administration (NOAA) standards for confidentiality, privacy, and electronic
information. See response #10 of this Supporting Statement for more information on
confidentiality and privacy. Basic fleet information is provided in aggregate statistical form (and
without identifying the source of data, i.e., vessel name, owner, etc.). The information collection
requirements described herein are designed to yield data that meet all applicable information
quality guidelines. Prior to dissemination, the information will be subjected to quality control
measures and pre-dissemination review pursuant to Section 515 of Public law 106-554.
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.
Catch data will be collected from observations taken at sea, on hagfish fishing boats, and sales
transactions made at the dock. Observer data will be processed and compiled using computer
systems. The catch data summarizes the actual fishing event/transaction that just occurred.
Federal Northeast seafood dealer initial permit applications can be downloaded at
http://www.nero.noaa.gov/permits/#Dealer
.
4. Describe efforts to identify duplication.
NMFS is aware of all related fishery management activities and since the hagfish fishery is
currently an unregulated fishery, the information collection requirements do not duplicate any in
existence.

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5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The proposed collection of information requirements will not have a significant impact on small
entities. Only the minimum data to meet the requirements of the above identified data needs are
requested from all participants. The observer requirements will be detailed to the respective
vessel owners/operators prior to deployment in order to facilitate the process. Permit
information and all initial permit applications are posted on the NE Regional Office’s (NERO)
web site. Posting such information on the internet makes it widely available to the public,
thereby reducing both public and administrative burden. Since all of the respondents are small
businesses, separate requirements based on the size of the business have not been developed.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The observer requirements to be implemented through the pilot hagfish information collection
program is intended to improve upon the quality and quantity of information currently available
on the hagfish fishery resource and fishery operations. Since there is currently no management
program for this fishery, and consequently no permitting or reporting requirements, there is
considerable uncertainty regarding the actual level of hagfish landings. Moreover, the level of
discards and discard mortality of hagfish culled at sea in response to a rejection by the dealer in
port is unknown. Specifically, the information provided by the hagfish information collection
program participants would help NMFS and the Council shape future hagfish management
measures to reflect the unique aspects of this fishery and its interaction with other Federallymanaged fisheries. Without this information, management measures may not capture accurately
the geographic and seasonal aspects of this fishery which help to characterize its demand in
overseas markets and ensure that it may be sustained in future years. Increased knowledge of
this fishery may also help managers and scientists understand the factors that contribute to this
species’ localized depletion. Localized depletion if left to continue may lead to increased
economic impacts, as well overall depletion of the species. Therefore, these data are critical to
the development of a Hagfish FMP. In addition, hagfish have been collected in limited numbers
throughout the 40 years of the New England Fisheries Science Center (NEFSC) groundfish trawl
survey. These NEFSC surveys provide the best available stock abundance information, but none
of the surveys cover the entire range of hagfish habitat, which extends from depths of 25 m to
greater than 1,000 m.
Dealer permits for hagfish vessels will ensure that the data collection covers the entire fishery
and any new dealer entrants. Reports furnished by permitted dealers provide important
information on the volume, value, and distribution of the hagfish resource at the point of first
purchase.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
There are no special circumstances associated with this proposed rule that would require the
collection of information to be conducted in a manner inconsistent with OMB guidelines.

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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.
At the September 2006 Council meeting, the Council voted to recommend that NMFS conduct a
pilot information collection program on hagfish. In addition, NMFS received feedback from
industry representatives on the fishery’s current operations and in doing so they helped
contribute to the development of the proposed information collection requirements. The
information collections contained in this submission are part of a proposed rule, RIN 0648AU80, scheduled to publish in November, 2006. Once public comments have been considered, a
final rule outlining the measures that would be implemented, as modified by public comment,
would be published in the Federal Register.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
Neither payments, nor gifts are given to the respondents of this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
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 submitted in support of the hagfish information collection
pilot program implemented by NMFS, would be considered confidential and would not be
disclosed except as provided in section 402(b) of the Magnuson-Stevens Act.
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.
There are no questions of a sensitive nature.
12. Provide an estimate in hours of the burden of the collection of information.
A summary of this burden estimate can be found in Table 1.
There are approximately 5 active participants in the hagfish fishery that would be subject to the
information collection’s observer coverage requirements. Responses to requests to carry an
observer are estimated at 2 minutes per request. The estimated annual time to comply with the
observer requirements would be 2 hours (12 responses x 5 respondents) x 2 minutes/response)).

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There are approximately 2 dealer/processors that currently participate in the hagfish fishery.
While one of these dealers has a Federal dealer permit to purchase federally-regulated species,
both participants will be required to obtain a Federal dealer permit to purchase hagfish. Initial
dealer permit applications take an estimated 15 minutes to complete, while preprinted dealer
permit renewal forms require an estimated 5 minutes to complete. The estimated annual time to
comply with the dealer permit requirement would be 30 minutes for an initial application and 10
minutes for a renewal application (2 responses x 15 minutes per response; 2 responses x 5
minutes per response, respectively), with a total annualized burden of 14 minutes.
Total annualized burden for the two requirements would be 2.24 (2) hours.
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in #12
above).
The cost burdens to the public associated with the measures proposed are summarized in Table 1
and described in further detail below.
No special equipment or technology is needed to comply with the reporting requirements
reflected in this submission. Respondents will have the option of electing to use the on-line
services associated with applying for the hagfish-specific dealer permit. The only cost associated
with this collection is the cost of postage for submitting the initial/renewal dealer permit
applications.
The annual postage fees for the dealer applications for the permit applications/renewals would be
$0.78 ($0.39 x 2).
14. Provide estimates of annualized cost to the Federal government.
A full summary of the cost to the Federal Government associated with this collection of
information can be found in Table 1.
The cost calculations for observer deployment are based on $25/wage and overhead value for the
Government. Assuming that each observation takes 2 minutes to complete and we expect no
more than 3 trips per quarter for a total of 24 trips for the complete time that the collection of
information will be in place. The annualized cost of processing observer reports is estimated to
be $10.00 ($25/hour x (0.033 hours x 12 trips).
The estimated average cost to the Federal Government for issuance of a dealer permit is
$33/permit, including labor, printing, distribution, computer time, and handling. The annualized
burden is based on one response per year for each of the three respondents, or $99 ($33 x 3).
15. Explain the reasons for any program changes or adjustments reported.
No program changes or adjustments relate to this collection of information as this is a new
collection.

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16. For collections whose results will be published, outline the plans for tabulation and
publication.
Results from this collection may 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 and the annual Stock Assessment, and Fishery
Evaluation (SAFE) Report prepared by the Council for the hagfish fishery. 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 why display would be inappropriate.
All forms will display the OMB control number and expiration date along with information
relevant to the Paperwork Reduction Act of 1995.
18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
All instances of this submission comply with 5 CFR 1320.9.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
No statistical methods are employed in the information collection procedures.

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TABLE 1. Calculation of Public and Federal Estimate of Annual Reporting Burden Hours and Costs

Requirement

Year 1
Year 2
Year 3

Observer Coverage
FY 2007
FY 2008
FY 2009

Cost to:

# of
Entities

Items
Per
Entity

Total #
of Items

Response
Time

Total
Burden Time

5
5

12
12

60
60

2 minutes
2 minutes

2 hours
2 hours

$0.00
$0.00

$49.50
$49.50

5

12

60

2 minutes

2 hours

$0.00

$49.50

Public
(labor) (1)

Govt. (2)
(3)

3 Year Average Burden
Dealer Permit (Initial and Renewal)
Year 1
FY 2007 (Initial)

5

12

60

2 minutes

2 hours

$0.00

$49.50

2

1

2

15 minutes

30 minutes

$0.78

$99.00

Year 2

FY 2008 (Renewal)

2

1

2

5 minutes

10 minutes

$0.78

$99.00

Year 3

FY 2009 (Renewal)

2

1

2

5 minutes

10 minutes

$0.78

$99.00

2

1

2

7 minutes

14 minutes

$0.78

$99.00

2.24 (2) hours

$0.78

$148.50

3 Year Average Burden
Total
(1)
(2)
(3)

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The cost to the public is for postage to mail the applications and is based on $0.39 per application.
The cost to the Government for observer coverage is estimated to be $25 / burden hour
The cost to the Government for permit application processing is estimated to be $33/entity

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