Download:
pdf |
pdfSUPPORTING STATEMENT
ALASKA REGION BERING SEA and ALEUTIAN ISLANDS CRAB
ECONOMIC DATA REPORTS
OMB CONTROL NO.: 0648-0518
INTRODUCTION
In January 2004, the U.S. Congress amended Section 313(j) of Magnuson-Stevens Act to
mandate the Secretary of Commerce (Secretary) to implement the Crab Rationalization Program
for the Bering Sea and Aleutian Islands Management Area (BSAI) crab fisheries. The Program
allocates BSAI crab resources among harvesters, processors, and coastal communities. The
North Pacific Fishery Management Council (Council) prepared, and National Marine Fisheries
Service (NMFS) approved, the Fishery Management Plan (FMP) for BSAI King and Tanner
Crabs. The FMP establishes criteria for the management of certain aspects of the BSAI crab
fisheries by the State of Alaska Department of Fish and Game (ADF&G). The FMP is
implemented by regulations at 50 CFR part 680.
This action is a request for renewal for this collection-of-information and addresses the economic
data report (EDR) provisions of the BSAI Crab Rationalization Program. In addition, the title of
the collection is changed from “Crab Economic Data Reports”.
The BSAI Crab Rationalization Program (CR Program) was implemented to both maintain
rigorous safeguards on use of fishing privileges for a public resource and to provide safeguards
for program constituents. The CR Program components include quota share allocation,
processor quota share allocation, individual fishing quota (IFQ) and individual processing quota
(IPQ) issuance, quota transfers, use caps, crab harvesting cooperatives, protections for Gulf of
Alaska groundfish fisheries, arbitration system, monitoring, economic data collection, and cost
recovery fee collection. Several of these components are analyzed in this action. Program details
are found at: http://www.alaskafisheries.noaa.gov/regs/680/default.htm.
A.
JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
The CR Program addresses conservation and management issues associated with the previous
crab derby fisheries, reduces bycatch and associated discard mortality, and increases the safety of
crab fishermen by ending the race for fish. Section 313(j) of the Magnuson-Stevens Act
authorizes a mandatory economic data collection program for the fisheries of the CR Program.
The CR Program includes a comprehensive economic data collection program to aid the Council
and NMFS in assessing the success of the CR Program and developing amendments necessary to
mitigate any unintended consequences.
According to Section 313(j)(1), the data from the economic data report (EDR) will be used “to
study the impacts of the CR Program,” to insure that the program will achieve “equity between
the harvesting and processing sectors,” and to monitor the “economic stability for harvesters,
processors and coastal communities”. The Magnuson-Stevens Act also provides specific
guidance on the type of data to be collected, requirements for selecting a collection agent,
1
verification of data, and treatment and distribution of confidential data that are included in this
collection.
Section 313(j)(1) requires the Secretary to collaborate with the Federal Trade Commission (FTC)
and Department of Justice (DOJ) to develop economic data for analysis by these agencies. Data
from the EDR will directly contribute to this ongoing evaluation of potential anti-trust and anticompetitive practices in the crab industry.
Congress required that an independent third party data collection agent (DCA) administer the
collection and dissemination of the EDR data. NMFS selected the Pacific States Marine
Fisheries Commission (PSMFC) to be PSMFC. The PSMFC is under contract (through a
grant/cooperative agreement) with NMFS to collect, verify, and disseminate data to NMFS,
ADF&G, and the Council.
Persons harvesting or processing crab managed under the CR Program were required to submit
an historical EDR and an annual EDR to PSMFC, after which PSMFC will furnish verified data
with personal identifiers removed to NMFS and other specified agencies.
PSMFC is authorized to obtain the services of an auditor to assist in verification of EDR data.
At a minimum, the auditor shall be board certified and be selected based upon ability to perform
the services in a timely manner within professional standards.
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.
An Economic Data Report (EDR) containing cost, revenue, ownership, and employment data is
collected annually from the harvesting and processing sectors. The data are used to estimate how
effort, operating revenues and costs, and labor income are affected for all parties that have
participated in the CR Program. Data are also used in an effort to understand changes in the
makeup of fishery participants, how fishing and processing is undertaken, and how crew are
compensated or employed. Specifically, the data will be used in meeting the Council’s stated
goal of analyzing changes in resource utilization, excess harvesting and processing capacity,
economic returns, variable costs and revenues, economic efficiency, and the stability of
harvesters, processors, and coastal communities.
Another use of the EDR data is as a source of information for DOJ and FTC to assess potential
antitrust and/or anti-competitive practices relating to the issuance and use of processing quota.
The information collection is designed to yield data that meet all applicable information quality
guidelines. Prior to dissemination, the information is subjected to quality control measures by
the PSMFC and NMFS and a pre-dissemination review pursuant to Section 515 of Public Law
106-554.
The EDR data is confidential and is not disseminated to the public. PSMFC disseminates the
EDR data to NMFS, ADF&G and the Council staff after removing all personal identifiers such
as Social Security Numbers, vessel identification numbers, names, and addresses and telephone
numbers. The data are supplanted with a randomized identification number that can be matched
2
between datasets. The information is used to assist the Council in evaluating and potentially
suggesting amendments to the CR Program. EDR data are also made available to the
Department of Justice and Federal Trade Commission who utilize EDR data to facilitate their
investigations and actions.
An EDR is available in both an historical version and an annual version for each of four
categories of participant in the Crab Rationalization fisheries (CR fisheries). These categories
are: catcher vessel, catcher/processor, stationary floating crab processor, and shoreside crab
processor. The historical EDRs were required only for the first year of the CR Program and are
not included in this analysis. The Catcher Vessel Annual EDR, Catcher/Processor Annual EDR,
the Stationary Floating Crab Processor Annual EDR, and the Shoreside Processor Annual EDR
must be submitted on or before May 1 of each year, beginning with the year 2005.
The following persons must submit an annual EDR:
♦ Persons who owned fishing vessels or processing plants that harvested crab or processed
crab harvested in the CR fisheries at any time during the calendar year.
♦ Persons who were lease holders of fishing vessels or processing plants that participated in
the CR fisheries during the calendar year.
♦ Definition of "Leaseholder": For the purpose of defining the persons responsible for
submitting the EDR, a Leaseholder is a person, other than the owner of the catcher vessel
for which the EDR is required, who: was identified as the leaseholder, in a written lease,
of the catcher vessel, OR paid expenses of the catcher vessel, OR claimed expenses for
the catcher vessel as a business expense on schedule C of his/her Federal Income Tax
Return, or on a State Income Tax Return.
The EDR must be submitted to the Pacific States Marine Fisheries Commission (PSMFC)
Ensuring industry compliance with the data reporting requirements of the CR Program is
considered an integral component of collecting reliable data and accurate data. To ensure
accuracy of the EDR, enforcement staff has access to individual and confidential data in the
course of an investigation. It would not be possible to ensure reporting compliance from the
firms that are required to provide the data in a timely fashion without these enforcement tools.
a. Historical Catcher Vessel EDR – NO LONGER USED
It was expected that 275 catcher vessels would submit an historical EDR. PSMFC reports that
218 catcher vessels submitted EDR data for 1998 participation, 218 catcher vessels submitted
EDR for 2001 participation, and 237 catcher vessels submitted EDR data for 2004.
b. Annual Catcher Vessel (CV) EDR
An Economic Data Report (EDR) is required from any owner or leaseholder of a catcher vessel
that harvested crab in specified Bering Sea and Aleutian Islands (BSAI) crab fisheries during the
prior calendar year. The annual EDR submission deadline is June 28. 2007 EDRs won’t be
collected until June of 2008. Postage for submittal of the EDR is paid by PSMFC.
3
Annual catcher vessel EDR
Certification page
Catcher Vessel Information
Vessel Name and ADF&G Vessel Registration Number
Crab License Limitation Permit Number(s)
USCG Documentation Number
Current Estimated Market Value of Vessel and Equipment ($)
Replacement Value of Vessel and Equipment ($)
Name of Crab Harvesting Cooperative (if applicable)
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same name and address provided in the Owner Information block above, do
not repeat)
Leaseholder (If name and address are the same name and address provided in the Leaseholder Information
block above, do not repeat here)
Designated Representative
Name and Title
Business Telephone Number and Business FAX Number
Business E-mail address (if available)
The participant must select the appropriate statement to describe his or her EDR filing status and provide either
the complete EDR or just the certification pages
Buyer/Leaseholder Information (if applicable)
Buyer/Leaseholder Name
Telephone No (include area code)
Business Address
Date of Sale or Lease (day/month/2006)
Signature and date signed
EDR
BSAI Crab Activity Chart
CR Fishery Code
ADF&G Fish Ticket Number
Number of Days Crab Fishing
Number of Days Traveling and Offloading.
Crab Sales, Gross Revenue
Crab harvested, by fishery.
IFQ Type
Pounds Sold
Deadloss
Gross Revenue
BSAI Crab Quota
Catcher Vessel Owner Annual IFQ Allocation
Owner Quota Harvested by this Catcher Vessel
Owner Quota Transferred to Other Vessels
BSAI Crab CDQ and IFQ Lease Costs
Adak WAG IFQ and Community Development Quota (CDQ): Pounds and Total Cost
CPO-IFQ: Pounds and Total Cost
IFQ A: Pounds and Total Cost
IFQ B: Pounds and Total Cost
IFQ C: Pounds, Total Cost, and Number of Crew
4
Labor Information
Crab Harvesting Labor Costs
Number of Paid Harvest Crew Members (exclude the captain)
Total Labor Payment to Harvest Crew (exclude the captain)
Captain Labor Payment
Labor Payment Details
Indicate by checking the appropriate column whether the following expenses were
Deducted (shared expenses taken off the top of gross revenues)
Directly charged (charged to an individual after the crew share is calculated), or
Not charged to crew when calculating the harvest crew payments in BSAI crab fisheries
Revenue Shares
Indicate what percentage of the net share (total revenues minus the expenses was paid to the owner, crew,
and captain for each of the listed CR fisheries
BSAI Crab Crew Licenses
Alaska Commercial Crew license number or
State of Alaska Commercial Fisheries Entry Commission (CFEC) gear operator permit number
Vessel Costs
Costs for BSAI Crab Fishing Only
Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Insurance Deductibles
Crab Pots Purchased for Use in BSAI Crab Fishery, by location
Line and Other Crab Gear Purchases, by location
Bait used in BSAI crab fishery, by type and location
Fuel, Lubrication, and Fluids Used in BSAI Crab Fishery
Food and Provisions for Crew
Other Crew Costs
Freight Costs for Landed Crab
Storage, Wharfage, and Delivery
Observer Costs
Crab Landing Taxes and Fees
Fishing Cooperative Costs
Other Crab-specific Costs
Annual Vessel Costs
Investments in Vessel and Equipment
Repair and Maintenance for Vessel and Equipment
Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Fuel, Lubrication, and Fluids
Other Vessel-specific Costs
Annual Totals for All Fisheries
Calendar year for days at sea
Gross revenue
Pounds retained
Labor costs
It was expected that 275 catcher vessels would submit an annual EDR. PSMFC reports that 166
catcher vessels submitted EDR data for 2005 participation, and 99 catcher vessels submitted
EDR data for 2006 participation. 2007 EDRs won’t be collected until June of 2008. No
responses are indicated for the Federal Government, as the responses go to PSMFC. Federal
time burden is changed from 2 hr to 1 hr, because the coordination and data entry are done by
PSMFC. The 1 hr shown as Federal Government burden is due to staff comparison of lists from
PSMFC of participants who submitted EDRs. This comparison is necessary for issuance of
permits. The number of participants used in the analysis is 100.
5
Annual Catcher Vessel EDR, Respondent
Number of respondents
Total annual responses
Frequency of response = 1
Total burden hours (100 x 7.5 hr)
Time per response = 7.5 hr
Total personnel cost
Total miscellaneous costs (75,138.50)
Photocopy ($0.10 x 15 x 77 = 115.50)
Online costs (23 x $1 = 23)
Postage paid by PSMFC = 0
Accountant completion of EDR ($100 x 750 = 75,000)
Annual Catcher Vessel EDR, Federal Government
Number of responses
Total burden hours
Time per response = 1 hr
Total personnel costs ($50 x 1)
Total miscellaneous costs
100
100
750 hr
0
$75,139
0
1 hr
$50
0
c. Historical Catcher/Processor (C/P) EDR – NO LONGER USED
It was expected that 12 catcher/processors would submit an historical EDR. PSMFC reports that
8 catcher/processors submitted EDR data for 1998 participation, 7 catcher/processors submitted
EDR data for 2001 participation, and 10 catcher/processors submitted EDR data for 2004.
d. Annual Catcher/Processor EDR
An Economic Data Report (EDR) is required from any owner or leaseholder of a
catcher/processor that harvested or processed crab in specified Bering Sea and Aleutian Islands
(BSAI) crab fisheries during the prior calendar year. The annual EDR submission deadline is
June 28. Postage for submittal of the EDR is paid by PSMFC.
Certification page
Catcher/processor Information
Catcher/processor Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
Crab License Limitation Permit Number(s)
USCG Documentation Number
Current Estimated Market Value of Vessel and Equipment ($)
Replacement Value of Vessel and Equipment ($)
Name of Crab Harvesting Cooperative (if applicable)
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same name and address provided in the Owner Information
block above, do not repeat)
Leaseholder (If name and address are the same name and address provided in the Leaseholder Information
block above, do not repeat here)
Designated Representative
6
Name and Title
Business Telephone Number and Business FAX Number
Business E-mail address (if available)
The participant must select the appropriate statement to describe his or her EDR filing status
and provide either the complete EDR or just the certification pages
Buyer/Leaseholder Information (if applicable)
Buyer/Leaseholder Name
Telephone No (include area code)
Business Address
Date of Sale or Lease (day/month/2006)
Signature and date signed
EDR
Harvesting and Processing Information
BSAI Crab Activity Chart
Dates Covered
Number of Days Crab Fishing
Number of Days Traveling and Offloading
Number of Days Crab Processing
BSAI Crab Production
Raw Crab Pounds
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
Custom Processed (Yes or No)
BSAI Crab Sales and Processing
Annual BSAI Crab Sales
Species Code
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
FOB Alaska/Seattle Revenues
Custom Processing Services Provided
CR fishery code
Product Code
Process Code
Custom Processing Revenue
BSAI Crab Quota
Catcher/Processor Owner Annual IFQ Allocation
Owner Quota Harvested or Processed by this Catcher/Processor
CPO – IFQ Harvested
IFQ A Harvested
IFQ B Harvested
Owner Quota Transferred to other Vessels
CPO – IFQ Transferred
Revenue
IFQ A Transferred Pounds
Revenue
IFQ B Transferred Pounds
Revenue
BSAI Crab CDQ and IFQ Lease Costs
Adak WAG IFQ and Community Development Quota (CDQ): Pounds and Total Cost
CPO-IFQ: Pounds and Total Cost
7
IFQ A: Pounds and Total Cost
IFQ B: Pounds and Total Cost
IFQ C: Pounds, Total Cost and Number of Crew
Labor Information
Crab Harvesting Labor Costs
Number of Paid Harvest Crew Members (exclude the captain
Total Labor Payment to Harvest Crew (exclude the captain)
Captain Labor Payment
Crab Processing Labor Costs
Number of Crew with Pay Determined by Processing Work
Average Number of Crab Processing Positions
Total Processing Labor Payment
Harvest Labor Payment Details
Indicate whether the following expenses were
Deducted (shared expenses taken off the top of gross revenues)
Directly charged (charged to an individual after the crew share is calculated), or
Not charged to crew
BSAI Harvest Crew Licenses/Permits
Alaska Commercial Crew license number or
State of Alaska Commercial Fisheries Entry Commission (CFEC) gear operator permit number
BSAI Crab Processing Employee Residence
City, state, or country of residence
Number of employees that are from each residential location
BSAI Crab Custom Processing Done for You
Raw Pounds Supplied to Custom Processors
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
Processing Fee
Raw Crab Purchases from Delivering Vessels
Crab Size
Crab Grade
Raw Pounds Purchased
Gross Payment
Vessel Costs
Costs for BSAI Crab Production Only
Insurance Premiums (Hull, Property and Indemnity, and Pollution
Insurance Deductibles
Crab Pots Purchased for Use in BSAI Crab Fishery, by location
Bait used in BSAI crab fishery, by type and location
Fuel, Lubrication, and Fluids Used in BSAI Crab Fishery, by location
Food and Provisions for Crew
Other Crew Costs
Processing and Packaging Materials, Equipment, and Supplies
Re-packing Costs
Broker Fees and Promotions for BSAI Crab Sales
Crab Landing and Sales Taxes and Fees
Storage, Wharfage, and Delivery
Observer Costs
Freight and Handling Costs for Processed Crab Products from the Vessel
Product Storage
Fishing Cooperative Costs
Other Crab-specific Costs
Annual Vessel Costs
Investments in Vessel and Equipment
Repair and Maintenance (R&M) for Vessel and Equipment
8
Number of Employees and Salaries for Foremen, Managers and other Employees
Insurance Premiums (Hull, Property and Indemnity, and Pollution)
Fuel, Lubrication, and Fluids
Other Vessel-specific Costs
Annual Totals for All Fisheries
Total sum for the calendar year for all fishing and processing activities
Processing days
Days at sea
FOB revenues
Finished pounds processed
Pounds retained
Labor costs
It was expected that 12 catcher/processors would submit an annual EDR. PSMFC reports
that 8 catcher/processors submitted EDR data for 2005 participation, and 7
catcher/processors submitted EDR data for 2006 participation. 2007 EDRs won’t be
collected until June of 2008. No responses are indicated for the Federal Government, as the
responses go to PSMFC. Federal time burden is changed from 4 hr to 1 hr, because the
coordination and data entry are done by PSMFC. The 1 hr shown as Federal Government
burden is due to staff comparison of lists from PSMFC of participants who submitted EDRs.
This comparison is necessary for issuance of permits. The number of participants used in
the analysis is 10.
Annual Catcher/Processor EDR, Respondent
Number of respondents
Total annual responses
Frequency of response = 1
Total burden hours (10 x 12.5 hr)
Time per response = 12.5 hr
Total personnel cost
Total miscellaneous costs
Photocopy $0.1 x 15 x 10 = 15)
Postage paid by PSMFC
Accountant fee to complete EDR ($100 x 12500)
10
10
125 hr
0
$12,515
Annual Catcher/Processor EDR, Federal Government
Number of responses
Total burden hours
Time per response = 1 hr
Total personnel cost ($50 x 1)
Total miscellaneous costs
0
1 hr
$50
0
e. Historical Stationary Floating Crab Processor EDR—NO LONGER USED
It was expected that 4 stationary floating crab processors (SFCP) would submit an historical
EDR. PSMFC reports that 12 SFCP submitted EDR data for 1998 participation, 6 SFCP
submitted EDR data for 2001 participation, and 6 SFCP submitted EDR data for 2004.
f. Annual Stationary Floating Crab Processor (SFCP) EDR
An Economic Data Report (EDR) is required from any owner or leaseholder of a stationary
floating crab processor that processed crab in specified Bering Sea and Aleutian Islands (BSAI)
crab fisheries during the prior calendar year. The annual EDR submission deadline is June 28.
Postage for submittal of the EDR is paid by PSMFC.
9
Certification page
Stationary floating crab processor Information
SFCP Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
USCG Documentation Number
Current Estimated Market Value of SFCP and Equipment ($)
Replacement Value of SFCP and Equipment ($)
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business Fax Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business Fax Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same name and address provided in the Owner Information
block above, do not repeat)
Leaseholder (If name and address are the same name and address provided in the Leaseholder Information
block above, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business Fax Number
Business E-mail address (if available)
The participant must select the appropriate statement to describe his or her EDR filing status
and provide either the complete EDR or just the certification pages
Signature and date signed
EDR
BSAI Crab Processing Activity
BSAI Crab Activity Chart
Number of Crab Processing Days
Dates Covered
Raw Crab Pounds Purchased
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
Custom Processed (Yes or No)
BSAI Crab Sales and Processing
Annual BSAI Crab Sales
Species Code
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
FOB Alaska/Seattle Revenues
10
Custom Processing Services Provided
CR fishery code
Product Code
Process Code
Custom Processing Revenue
Labor Information
Crab Processing Labor Costs
Average Number of Crab Processing Positions
Total Man-Hours
Total Processing Labor Payment
BSAI Crab Processing Employee Residence
City, state, or country of residence
Number of employees that are from each residential location
BSAI Crab Custom Processing Done for You
Raw Pounds Supplied to Custom Processors
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
Processing Fee
Raw Crab Purchases from Delivering Vessels
IFQ Type
Crab Size
Crab Grade
Raw Pounds Purchased
Gross Payment
Vessel Costs
Costs for BSAI Crab Production Only
Fisheries Taxes
Processing and Packaging Materials, Equipment, and Supplies, by Location
Food and Provisions
Other Costs for Direct Crab Labor
Insurance Deductibles
Re-packing Costs
Broker Fees and Promotions for BSAI Crab Sales, by Fishery
Observer Costs, by Fishery
Freight Costs for Supplies to the Plant
Freight and Handling Costs for Processed Crab Products from the Plant
Product Storage
Water, Sewer, and Waste Disposal
Other Crab-specific Costs:
Annual Vessel Costs
Fuel, Electricity, Lubrication and Hydraulic Fluids
Investments in Plant and Equipment, by location
Repair and Maintenance (R&M) for Plant and Equipment, by location
Number of Employees and Salaries for Foremen, Managers and other Employees
Other Vessel-specific Costs
Annual Totals for All Fisheries
Total sum for the calendar year for all relevant fishery participation
Processing days
FOB Alaska/Seattle revenues
Finished pounds processed
Processing Labor costs
It was expected that 4 SFCPs would submit an annual EDR. PSMFC reports that 4 SFCPs
submitted EDR data for 2005 participation, and 5 SFCPs submitted EDR data for 2006
11
participation. 2007 EDR won’t be collected until June of 2008. No responses are indicated for
the Federal Government, as the responses go to PSMFC. Federal time burden is changed from 4
hr to 1 hr, because the coordination and data entry are done by PSMFC. The 1 hr shown as
Federal Government burden is due to staff comparison of lists from PSMFC of participants who
submitted EDRs. This comparison is necessary for issuance of permits. The number of
participants used in the analysis is 5.
Annual stationary floating crab processor EDR, Respondent
Number of respondents
Total annual responses
Frequency of response = 1
Total burden hours (5 x 10 hr)
Time per response = 10 hr
Total personnel cost
Total miscellaneous costs (5007.50)
Photocopy ($0.1 x 15 x 5 = 7.50)
Postage paid by PSMFC
Accountant fee to complete EDR (100 x 50 = 5,000)
Annual stationary floating crab processor EDR, Federal Government
Number of responses
Total burden hours
Time per response = 1 hr
Total personnel costs ($50 x 1)
Total miscellaneous costs
5
5
50 hr
0
$5,008
0
1 hr
$50
0
g. Historical Shoreside Processor EDR—NO LONGER USED
It was expected that 20 shoreside processors would submit an historical EDR. PSMFC reports
that 13 shoreside processors submitted EDR data for 1998 participation, 17 shoreside processors
submitted EDR for 2001 participation, and 14 shoreside processors submitted EDR data for
2004.
h. Annual Shoreside Processor EDR
An Economic Data Report (EDR) is required from any owner or leaseholder of a shoreside
processor that processed crab in specified Bering Sea and Aleutian Islands (BSAI) crab fisheries
during the prior calendar year. The annual EDR submission deadline is June 28. Postage for
submittal of the EDR is paid by PSMFC.
Certification page
Shoreside processor Information
Shoreside Processor Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
Physical Location of Land-based Plant (street address, city, state, zip code)
Borough Assessed Value of Plant and Equipment ($) and Year Assessed
Current Estimated Value of Plant and Equipment ($)
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
12
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business FAX Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same name and address provided in the Owner Information
block above, do not repeat)
Leaseholder (If name and address are the same name and address provided in the Leaseholder Information
block above, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business FAX Number
Business E-mail address (if available)
The participant must select the appropriate statement to describe his or her EDR filing status
and provide either the complete EDR or just the certification pages
Signature and date signed
EDR
BSAI Crab Processing Activity
Number of Crab Processing Days
Dates Covered
Raw Crab Pounds Purchased
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
Custom Processed (Yes or No)
BSAI Crab Sales and Processing
Annual BSAI Crab Sales
Species Code
Product Code
Process Code
Crab Size
Crab Grade
Box Size
Finished Pounds
FOB Alaska/Seattle Revenues
Custom Processing Services Provided
CR fishery code
Product Code
Process Code
Custom Processing Revenue
Labor Information
Crab Processing Labor Costs
Average Number of Crab Processing Positions
Total Man-Hours
Total Processing Labor Payment
BSAI Crab Employee Residence
City, state, or country of residence
Number of employees that are from each residential location
BSAI Crab Custom Processing Done for You
Raw Pounds Supplied to Custom Processors
Product Code
Process Code
Crab Size
Crab Grade
13
Box Size
Finished Pounds
Processing Fee
Raw Crab Purchases from Delivering Vessels
IFQ Type
Crab Size
Crab Grade
Raw Pounds Purchased
Gross Payment
Plant Costs
Costs for BSAI Crab Production Only
Fisheries Taxes
Processing and Packaging Materials, Equipment, and Supplies, by Location
Food and Provisions
Other Costs for Direct Crab Labor
Insurance Deductibles
Re-packing Costs
Broker Fees and Promotions for BSAI Crab Sales, by Fishery
Observer Costs, by Fishery
Freight Costs for Supplies to the Plant
Freight and Handling Costs for Processed Crab Products from the Plant
Product Storage
Water, Sewer, and Waste Disposal
Other Crab-specific Costs
Annual Plant Costs
Fuel, Electricity, Lubrication and Hydraulic Fluids
Investments in Plant and Equipment, by location
Repair and Maintenance (R&M) for Plant and Equipment, by location
Number of Employees and Salaries for Foremen, Managers and other Employees
Other Plant-specific Costs
Annual Totals for All Fisheries
Total sum for the calendar year for all relevant fishery participation
Processing days
FOB Alaska/Seattle revenues
Finished pounds processed
Processing Labor costs
It was expected that 20 shoreside processors would submit an annual EDR. PSMFC reports that
13 shoreside processors submitted EDR data for 2005 participation, and 16 shoreside processors
submitted EDR data for 2006 participation. 2007 EDRs won’t be collected until June of 2008.
No responses are indicated for the Federal Government, as the responses go to PSMFC. Federal
time burden is changed from 2 hr to 1 hr, because the coordination and data entry are done by
PSMFC. The 1 hr shown as Federal Government burden is due to staff comparison of lists from
PSMFC of participants who submitted EDRs. This comparison is necessary for issuance of
permits. The number of participants used in the analysis is 16.
Annual shoreside processor EDR, Respondent
Number of respondents
Total annual responses
Frequency of response = 1
Total burden hours (16 x 10 hr)
Time per response = 10 hr
Total personnel cost
Total miscellaneous costs
Photocopy ($0.1 x 15 x 16 = 24)
Postage paid by PSMFC
Accountant fee to complete EDR (100 x 160 = 16,000)
14
16
16
160 hr
0
$16,024
Annual shoreside processor EDR, Federal Government
Number of responses
Total burden hours
Time per response = 1 hr
Total personnel costs ($50 x 16)
Total miscellaneous costs
0
1
$50
0
i. Verification of Data.
PSMFC conducts verification of EDR information with the owner or leaseholder. The owner or
leaseholder must respond to inquiries by PSMFC within 20 days of the date of issuance of the
inquiry. The owner or leaseholder must provide copies of additional data to facilitate
verification by PSMFC.
To make sure that each company is consistently and accurately completing the EDR, random
audits will be performed by a qualified accountant on some of the EDRs for a subset of the crab
fishery participants. This step will ensure that the data can be relied upon to produce accurate
and reliable information for the Alaska crab fisheries. The PSMFC auditor may review and
request copies of additional data provided by the owner or leaseholder, including but not limited
to: previously audited or reviewed financial statements, worksheets, tax returns, invoices,
receipts, and other original documents substantiating the data.
Auditors will verify records by comparing specific elements of the report with participant
accounting records. To make this activity as efficient and non-intrusive as possible, NMFS
suggests that participants:
♦ Keep a copy of the completed EDR or certification pages submitted to the Data
Collection Agent (DCA). Copy and attach extra sheets as needed.
♦ Keep a file that has all of the supporting information used in the preparation of the EDR.
♦ Make sure that the EDR agrees to the company's highest level of financial information.
For this purpose, the highest level of financial information is defined in order as:
• Audited financial statements
• Reviewed financial statements
• Compiled financial statements
• Tax returns.
♦ Record only whole numbers. Round up dollar figures to the next highest dollar.
Verification of Data, Respondent
Number of respondents (16+5+10+100)
Total annual responses
Frequency of response = 1
Total burden hours (131 x 3 hr)
Time per response = 3 hr
Total personnel cost
Total miscellaneous costs
Photocopy ($15 x 131 = 1965)
Telephone calls ($5 x 131 = 655)
Accountant fee to verify EDR ($100 x 393 = 39300)
15
131
131
393
0
$41,920
Verification of Data, Federal Government
Total burden hours
Total personnel costs
Total miscellaneous costs
0
0
0
Focused Outreach Campaign
Office of Management and Budget (OMB) stipulated that the renewal request for this and two
other collections include a "focused outreach campaign" to validate burden estimates and elicit
suggestions from the regulated community for reducing the burden. The information collections
are: Crab Permits; Crab Economic Data Reports (EDR); and Crab Arbitration. Comments were
required to be submitted by November 1, 2007, through the Alaska Region's website at:
http://www.fakr.noaa.gov/sustainablefisheries/crab/rat/pra.
A postcard was sent to all crab permit holders announcing NMFS’ request for comments and
indicating the web address for entering comments. In addition, an information bulletin was
posted on the NMFS Alaska Region web site soliciting response to the online questionnaire. The
information bulletin No. 90 is provided in Appendix A.
The online questionnaire was posted at
http://www.fakr.noaa.gov/sustainablefisheries/crab/rat/pra
and stated:
______________________________________________________________________________
BSAI Crab Rationalization Program Information Collection
Public Comment Period
NMFS invites the pubic to comment on three of the BSAI Crab Rationalization Program's information collection
systems. Comments must be submitted by November 1, 2007, and will be accepted through the following forms.
Please click on the form that is most applicable:
Comment Forms on:
Crab Permit Applications
Crab Arbitration
Crab Economic Data Reports
The agency is seeking comments on (a) whether the three information collection systems are necessary and whether
the information has practical utility; (b) the accuracy of the agency's estimates on the burden of collecting the
information; (c) ways to enhance the quality, utility, and clarity of the information collected; and (d) ways to
minimize the burden of collecting the information from respondents.
For more information, contact Patsy Bearden, NMFS Resource Management Specialist, at 907-586-7008, or email:
patsy.bearden@noaa.gov.
Related Information
72 FR 50937, September 5, 2007. Notice of proposed information collection on the Alaska Region BSAI Crab
Permits and Crab Economic Data Reports. Comment period through November 5, 2007.
_____________________________________________________________________________
16
When the public clicked on “Crab Economic Data Reports,” they were transferred to the specific
questionnaire which is provided as Appendix B.
NMFS received one public comment through this web site and one public comment to the
Federal Register notice for this collection. These comments are provided at question 8 below.
______________________________________________________________________________
It is anticipated that the information collected will be disseminated in aggregated and nonconfidential form to the public or used to support publicly disseminated information about Crab
Rationalization. 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. 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 predissemination 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.
The EDR may be downloaded from our web site at www.alaskafisheries.noaa.gov, printed, and
submitted by mail or FAX to Pacific States Marine Fisheries Commission. The catcher vessel
EDR is provided online for participants. All other EDRs must be mailed or faxed. Current
reasons for having the online data collection for catcher vessels only: The principal reason is the
cost-effectiveness of the web version: out of 114 EDR submitted last year, 96 of them were from
catcher vessels, five from catcher/ processors(C/P), and 13 from stationary floating or shoreside
processors. Furthermore, the built-in error checking and validation capabilities of the online form
are much more useful for the catcher vessel (CV) sector than for the processors. C/P and
processing plant EDRs are filled out almost exclusively by professional bookkeepers or
accountants and are less prone to error, whereas many of the CV EDR forms are completed by
proprietors with more propensity for errors. We have found that many of the accountants prefer
to use the fillable .pdf version of the EDR form and would be unlikely to use the online form in
any case.
NMFS in the future plans to coordinate efforts with PSMFC in the next year or so to create a
data entry system that will allow additional applicants to enter EDR data online. The data will
go directly into a database. It is anticipated that this type of system will more efficient, timely,
and accurate, though as stated above, some may choose to continue with the fillable .pdf version.
4. Describe efforts to identify duplication.
The information collected as part of this information collection pertains almost exclusively to the
cost and employment records of harvesters and processors. Such information is not collected
within other data collections. Some of the information on production levels we request from
processors has been provided within the Commercial Operator’s Annual Report (COAR), but we
are attempting to get more precision on the grade, size and quality of the products and to get that
information the submitter must also tell us what kind of crab they are producing. One other type
17
of information that is somewhat duplicative in nature is the revenue data we collect on
production and sales. In many cases the data submitted through Alaska Fish Tickets or in the
COAR do not include post-seasonal adjustments and thus are not accurate or true records of
revenues received. Because of the timing of the EDR survey process we are able to get more
correct and complete data after such adjustments have been made.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
This information collection does require data from fishing operations that are small entities as
identified by the Small Business Administration (SBA). The number of respondents that will be
small entities at the time the CR Program was initiated is anticipated to decrease dramatically
due to the consolidation of BSAI crab operations, the quota awarded, the 25 vessels eliminated in
the BSAI crab buyback program, and from the opportunity to form cooperatives. Most of the
historical data was collected during the first year of the program as a one-time submission.
Small entities continuing to participate in the crab fisheries are required to submit annual EDRs
each year. The number of crab harvesting entities that continue to meet SBA criteria for being
small entities is anticipated to be greatly minimized over the pre-quota fisheries. In designing
the EDRs we had several meetings with vessel owners and operators (the parties who comprise
the small entity component of this collection) to discuss the way in which their financial records
are kept. The goal of these discussions was to tailor the EDR so that the information requested
closely matched the way in which records were kept. We also held meetings with an accountant
that would be filling out the EDRs for much of the crab vessels to discuss the way in which she
kept their books. Again, this information was used to define various cost and expenditure
categories that match the general structure present in much of the fleet. Obviously there is a fair
amount of variation in the way financial records are kept, so some extra work will be
encountered by some submitters to report costs according to our selected categories, but for the
most part these categories are consistent with the majority of the vessels’ financial records.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The intent of this collection is to study the impacts of the CR Program; to ensure that the
program achieves equity between the harvesting and processing sectors; and to monitor the
economic stability for harvesters, processors and coastal communities. Without the specified
reporting scheme described in this Supporting Statement, the program would be jeopardized.
The consequences of not collecting this information would be that NMFS could not fulfill the
intent of the law created under Public Law (P.L.) No. 108-199 and would be unable to provide
data to the Council and the State of Alaska to evaluate the CR Program for each of the required
review periods. P.L. No. 108-199 also requires that each component of the crab program enacted
by Congress must be implemented or the whole program must be withdrawn. Thus, disapproval
of this data collection program would threaten all components of P.L. No. 108-199.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
Each EDR is required to be submitted annually. While the collection requires the EDR to
typically be submitted within 90 days, requests for verification of data must be responded to
within 20 days of a question transmitted by the data collection agent. This may constitute a
18
special circumstance that is inconsistent with OMB guideline 2: “Must not require respondents
to prepare a written response in fewer than thirty days after they receive the request.”
The reason for the 20-day response period is that there may be EDR verification questions that
are sequential based on previous questions. It would be difficult to complete verification in a
reasonable period of time, if a longer period were allowed. The verification questions are likely
to be small in number, and are often addressed with a telephone call or other short
communication. The 20-day response period should not place a significant burden on
submitters.
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, 72 FR 50937 published September 5, 2007, solicited public comment.
One comment was received. In addition, one comment was received in response to Public
Outreach.
Comment from Online Questionnaire
This commenter from a catcher vessel stated that “Dividing out capital improvements versus
repairs--further divided by location of service was time consuming and that bait itemization by
category was also very time consuming” In addition, the commenter said the actual personnel
cost is $200 per hour. The commenter said the number of hours needed to train staff is more
than 30 hours.
Additional Comments: “The information gathering process takes many hours and required us to
revamp our entire accounting system--making it more cumbersome as well. It required the use
of a hired accountant to complete, increasing our costs. The EDR comes out in May, but the
data requested occurred over a year prior. Otherwise, the EDR time table is different than the
NMFS crab year, making it confusing.”
Comment from Federal Register Notice.
This commenter from a shoreside processor expressly disagrees that the crab EDR collection of
information is necessary for the proper performance of the functions of the agency, and that the
information does not have practical utility. The commenter agrees that the management of our
national resources is exceptionally vital for the continued wellbeing of the fisheries and
ecosystem, but fails to perceive how the amount that a processor spends on hydraulic fuel, as an
example, has any bearing on the management of this resource.
The commenter believes that Table 6.1—Costs for BSAI Crab Production Only and Table 6.2—
Annual Plant Costs is particularly invasive and again has no bearing on the management of this
resource. The commenter processes several products simultaneously and distinguishing between
processing, packaging material, equipment and supplies for crab only is a very tedious and
19
daunting process. Due to the fact that the processor is a small processing plant the office staff
consists of four individuals to handle all the office duties. The office staff has been continually
further burdened with the ever increasing reports from various organizations requesting further
additional information as well as the burden of collecting the NOAA Crab buyback fees and the
Registered Crab Receiver (RCR) rationalization fees from the vessels. The annual EDR report
for the Crab fisheries request for information far surpasses the request of any other fishery. The
crab fishery is the only fishery that requires an EDR. All other fisheries are contented with no
more than the annual COAR report that the processor considers fundamental for the management
of these fisheries.
The commenter disagrees with the accuracy of the agency’s estimate of the burden of the
collection-of-information. The commenter contends that the estimated time per response is in
actuality far greater and estimates the time allotment to be 24 hours to complete and submit the
report.
NMFS Response to Comments
Currently, NMFS is working on a proposed/final rule to improve the EDRs expected to be in
regulations by 2009 (reporting for 2008). After receiving and analyzing the first EDR
submittals, NMFS economists determined that certain questions on the EDRs could be simplified
and the order of questions could be reorganized, which could reduce the amount of time needed
to complete the EDR. The two comments above would be incorporated into these EDR
revisions. Some data elements would be disaggregated to clarify ambiguities arising from
aggregation methods. The regulations at 50 CFR part 680.6 would be revised to reflect the
clarification, simplification, and reorganization of the forms. It is expected that the data obtained
through application of these changes would be improved.
Regarding the cost to complete an EDR, NMFS anticipated that most quota holders and owners
of vessels and processing plants in this fishery would use accounting staff or accounting
contractors for tracking and providing this data. The assumption of an hourly rate of $100/hour
is consistent with accounting supply costs in this region of the U.S.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift will be provided under this program.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
The information collected is confidential under section 302(i) of the Magnuson-Stevens Act (16
U.S.C. 1852 et seq.) and under NOAA Administrative Order (AO) 216-100, which sets forth
procedures to protect confidentiality of fishery statistics. It was last revised in 1994.
NOAA also follows regulatory procedures for data confidentiality found at 50 CFR Sec. 600.405
et seq. The Magnuson-Stevens Act generally prohibits collection of economic data, particularly
from processing entities. In the legislation for the CR Program, an exception was created to the
prohibition. NMFS was directed to implement a mandatory economic data program and feed the
data to prescribed entities, with or without identifiers, depending on the entity.
20
NMFS will retain control over the information that is supplied, and safeguard it from improper
access, modification, and destruction, consistent with NOAA standards for confidentiality,
privacy, and electronic information.
System of Records: Routine Uses
The routine uses were described in the COMMERCE/NOAA System-16; Crab Economic Data
Report for Bering Sea/Aleutian Islands Management Area (BSAI) off the coast of Alaska,
published in 40 FR 28953-28955
1. In the event that a system of records maintained by the Department to carry out its
functions indicates or is relevant to a violation or potential violation of law or contract,
whether civil, criminal or regulatory in nature and whether arising by general statute or
particular program statute or contract, or rule, regulation or order issued pursuant thereto,
or the necessity to protect an interest of the Department, the relevant records in the
system of records, including individual identifiers, may be referred to the appropriate
agency, whether Federal, State, local or foreign, charged with the responsibility of
investigation or prosecuting such violation or charged with enforcing or implementing
the statute or contract, or rule, regulation or order issued pursuant thereto, or protecting
the interest of the Department. That agency may disclose such records in the course of
conducting its investigation.
2. A record from this system of records may be disclosed in the course of presenting
evidence to a court, magistrate or administrative tribunal, including disclosures during the
course of litigation, such as through discovery or to opposing counsel in the course of
settlement negotiations.
3. A record in this system of records may be disclosed to a Member of Congress submitting
a request involving an individual when the individual has requested assistance from the
Member with respect to the subject matter of the record.
4. A record in this system of records may be disclosed without individual identifiers to a
contractor of the Department having need for the information in the performance of the
contract, but not operating a system of records within the meaning of 5 U.S.C. 552(a).
5. A record in this system of records may be disclosed with individual identifiers to
Department of Justice and the Federal Trade Commission when such records are
requested by those agencies for anti-trust analyses or enforcement proceedings.
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 information collection does not involve information of a sensitive nature.
21
12. Provide an estimate in hours of the burden of the collection of information.
Estimated total respondents: 131, a decrease from 187. Estimated total responses: 262, a
decrease from 291. Estimated total burden: 1,478 hr, a decrease from 5,429. Estimated total
personnel costs: $0, a decrease from $766,950.
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).
Estimated total miscellaneous costs: $150,606, an increase from $3,289.
14. Provide estimates of annualized cost to the Federal government.
Estimated total burden: 4 hr, a decrease from 1,388. Estimated total personnel costs: $200, a
decrease from $71,880. Estimated total miscellaneous costs: $500,000.
A significant cost of administering the EDR is the cost of the contract with the independent third
party. In P.L. No. 108-199, section 801, Congress required that the economic data collection be
administered by an independent third party under contract to NMFS. The Pacific States Marine
Fishery Commission is the independent agent selected by NMFS to disseminate EDR forms, to
be the collection point for the EDR, and to verify the accuracy of the data collected from the
BSAI crab fishing industry. The estimated cost of this contract is $500,000 annually.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
Adjustments were made to numbers of participants based on actual numbers of EDRs submitted
to PSMFC and due to the one-time historical EDR submissions having been completed. In
addition, in response to comments received, the costs to complete and verify the EDRs are
removed from personnel costs and added to miscellaneous costs, because generally an
accountant is contracted to perform these tasks.
CRAB EDR RESPONDENTS
Historical catcher vessel
Annual catcher vessel
Historical catcher/processor
Annual catcher/processor
Historical SFCP
Annual SFCP
Historical shoreside processor
Annual shoreside processor
Verification of data
TOTAL
No. Respondents
No. Responses
2004
2007
2004
2007
2004
2007
2004
2007
2004
2007
275
0
275
0
4125
0
412500
0
688
0
275
100
275
100
2063
750
206250
0
413
75139
12
0
12
0
300
0
30000
0
18
0
12
10
12
10
150
125
15000
0
18
12515
4
0
4
0
80
0
8000
0
6
0
4
5
4
5
40
50
4000
0
6
5008
20
0
20
0
400
0
40000
0
30
0
20
16
20
16
200
160
20000
0
30
16024
104
131
104
131
312
393
31200
0
2080
41920
311
131
726
262
7670
1478
766950
0
3289
150606
22
Burden Hours
Personnel Cost ($)
Misc. Cost ($)
No statistics are given for the historical EDRs, because these EDRs were submitted on a onetime basis.
Verification of data was applied to all participants instead of a select few, because the number of
participants has decreased.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
NMFS is not required by statute to formally publish results or summaries of the data collected in
the EDR for public review. P.L. No. 108-199, section 801 does require three-year and five-year
reviews of the economic effects of the crab rationalization program. An 18-month review is
required as part of proposed Amendment 18 to the BSAI Crab FMP. As part of these reviews, a
number of data reports with aggregated and verified EDR data will be made available to the
Council and/or Congress. The analysis is anticipated to include some assessment of the change
in the benefits and costs of the BSAI crab resource as well as distributional effects of the
implementation of Crab Rationalization. Thus, some data regarding costs and revenues of
harvesting and processing crab fisheries are likely to be displayed in aggregate to protect
individual data. The specific variables or analytical results likely to be displayed in tables or
narrative cannot be identified at this time.
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.
In accordance with OMB requirements, the expiration date for OMB approval is shown on the
EDRs.
18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
There are no exceptions.
23
24
| File Type | application/pdf |
| File Title | SUPPORTING STATEMENT |
| Author | NOAA Fisheries |
| File Modified | 2008-02-19 |
| File Created | 2008-02-19 |