0512 ss ren 021208

SUPPORTING STATEMENT
SPECIAL SUBSISTENCE PERMITS AND HARVEST LOGS FOR
PACIFIC HALIBUT IN WATERS OFF ALASKA
OMB CONTROL NO.: 0648-0512

INTRODUCTION
Management of the Pacific halibut fishery in and off Alaska is based on an international
agreement between Canada and the United States. This agreement, titled the “Convention
between United States of America and Canada for the Preservation of the Halibut Fishery of the
Northern Pacific Ocean and Bering Sea” (Convention), was signed at Ottawa, Canada on March
2, 1953, and amended by the “Protocol Amending the Convention,” signed at Washington, D.C.,
March 29, 1979. This Convention, administered by the International Pacific Halibut
Commission (IPHC), is given effect in the United States by the Northern Pacific Halibut Act of
1982. The North Pacific Fisheries Management Council (Council) adopted a subsistence halibut
policy in October 2000 under the authority of the Halibut Act. A final rule issued at 68 FR
18145 and codified in 50 CFR part 300-Subpart E authorized a subsistence fishery for halibut in
Convention waters off Alaska. Halibut subsistence fishery is intended to allow eligible persons
to practice the long-term customary and traditional harvest of Pacific halibut for food in a noncommercial manner (see also Office of Management and Budget (OMB) Control No.: 06480460, halibut subsistence registration).
This action is a request for renewal for this collection-of-information and addresses the special
permits and harvest logs for this fishery.
A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
This statement supports a collection-of-information for special permits issued to participants in
the Pacific halibut subsistence fishery in waters off the coast of Alaska and any appeals resulting
from denials. National Marine Fisheries Service (NMFS) designed the permits to work in
conjunction with other halibut harvest assessment measures. Subsistence fishing for halibut has
occurred for many years among the Alaska Native people and non-Native people. Special
permits in this collection-of-information are initiated in response to the concerns of Native and
community groups regarding increased restrictions in IPHC Area 2C and include Community
Harvest Permits, Ceremonial Permits, and Educational Permits. NMFS designed the specialized
permits as vessel-oriented permits which allow eligible persons to harvest subsistence halibut
under reduced gear and harvest restrictions provided the permit is maintained on board during
fishing.
Except for enrolled students fishing under a valid Educational Permit, specialized permits require
persons fishing under them to also possess a Subsistence Halibut Registration Certificate
(SHARC) (see OMB Control No.: 0648-0460) which identifies those persons who are currently
eligible for subsistence halibut fishing. Each of the proposed instruments is designed to
minimize the reporting burden on subsistence halibut fishermen while retrieving essential
information.
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NMFS confirms the eligibility of registration applicants based on the information provided on an
application form. If eligible, the applicant receives the specialized permit for which he/she
applied. Compliance with the registration and reporting system for all specialized permits is
required.
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.
One application is used to apply for all three special permits: Subsistence Halibut Ceremonial,
Educational, and Community Harvest Permits. Upon completion of subsistence harvest, a
harvest log must be submitted to NMFS.
a. Subsistence Halibut Special Permits Application.
Ceremonial and Educational Permits
Ceremonial and Educational Permits are available exclusively to IPHC Area 2C or 3A Alaska
Native tribes listed in 50 CFR 300.65(f)(2) and consist of a laminated permit card and a harvest
log issued by NMFS. Either permit expires 30 days from its date of issuance. The permit and
log of each type must be returned within 15 days following the permit’s expiration date
regardless of whether halibut were harvested using the permit. Eligible tribes may request and
possess multiple Ceremonial Permits at any given time. Each Alaska Native tribe is limited to
only one Ceremonial Permit Coordinator per tribe for Ceremonial Permits, or one Authorized
Instructor per tribe for Educational Permits.
Community Harvest Permits
Community Harvest Permits (CHP) may be issued to Alaska Native tribes, or to eligible rural
communities in the absence of a tribe, provided the tribe or community is listed in § 300.65(f)(1)
or (f)(2). An eligible tribe or community may select individual harvesters who possess particular
expertise in halibut fishing to harvest halibut on behalf of the community or tribe under reduced
gear and harvest restrictions. NMFS will issue five laminated cards and a harvest log to the tribe
or community for each approved registration application. The tribe or community must
designate a Community Harvest Coordinator as part of the registration process. The CHP
expires 1 year from the date of issuance. It is the responsibility of the Community Harvest
Coordinator to issue the laminated CHP cards to eligible fisherman. Each fisherman must have a
CHP card as well as his/her SHARC on his/her person when fishing under the CHP.
Ceremonial Permits and Community Harvest Permits may be applied for on line through the
Internet. Educational Permits may not be applied for on line; rather the participant may complete
the form on-screen and print the form. An application may be submitted by an Alaska Native
tribe for more than one individual, with the list of individuals or applicants included, rather than
submission of a complete application for each person.
Electronic application may be made at:
https://www.alaskafisheries.noaa.gov/webapps/halibutsubsistence/PermitInitial

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Paper applications may be submitted by mail to:
Restricted Access Management
NMFS, Alaska Region
P.O. Box 21668
Juneau, AK 99802-1668
or by fax to: 907-586-7354
Subsistence Halibut Special Permits Application
Block A. Type of subsistence halibut special permit requested
Indicate whether applying for a community harvest permit, ceremonial permit, or educational permit
Indicate whether applying for a new permit or a renewal of an existing permit. If a renewal, enter permit number
Block B. Subsistence Halibut Community Harvest Permit
Name of Alaska Native tribe or community
Name, address, and daytime telephone number of CHP Coordinator
Attach any previously issued CHP harvest logs
Block C. Subsistence Halibut Ceremonial Permit
Name of Alaska Native tribe or community
Name, address, and daytime telephone number of Ceremonial Halibut Permit Coordinator
Describe occasion of cultural or ceremonial significance
Attach any previously issued ceremonial permit harvest logs from any expired ceremonial permit
Block D. Subsistence Halibut Education Permit
Name of Alaska Native tribe or community
Name, address, and daytime telephone number of Education Permit Instructor
Name, address, and daytime telephone number of Educational Institution or Organization
Course description
Demonstrate enrollment of qualified students
Describe minimum attendance requirements
Describe standards for the successful completion of the educational program
Describe standards for successful completion of the course
Attach any previously issued educational permit harvest logs from any expired educational permit

Ten community harvest permits have been issued in the 3 years since the program began. Three
education permits have been issued in the 3 years since the program began. No ceremonial
permits were requested. However, the potential still exists for the 38 tribes to request these
permits; at this time, we will not revise the numbers used in the burden analysis.
Subsistence halibut special permit application, Respondent
Total respondents
CHP permits (33 tribes)
Ceremonial permits (38 tribes)
Educational permits (38 tribes)
Total annual responses
CHP permits (33 x 1 = 33)
Ceremonial permits (38 x 5 = 190)
Educational permits, all tribes (5)
Total annual time burden hours (0.17 x 228 = 38.76)
Time per response (10 min/60 min = 0.17)
Total personnel cost (39 x $25)
Total miscellaneous costs (267.76)
Postage (36 x 0.41= 14.76)
FAX (36 x $6 = 216)
Online (37 x $1 = 37)

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109

228

39 hr
$975
$268

Subsistence halibut special permit application, Federal government
Total annual responses
Total annual time burden hours (0.17 x 228 = 38.76)
Estimated response time (10 min/60 min = 0.17)
Total personnel cost (39 x $25)
Total miscellaneous costs

228
39 hr
$975
0

b. Community Harvest Permit (CHP) Log.
The CHP Coordinator maintains possession of the CHP log at all times and issues the CHP
permit card to an eligible subsistence fisherman. The eligible subsistence fisherman returns the
CHP permit card and reports his or her catch to the CHP Coordinator upon completion of
subsistence fishing under the permit. The CHP Coordinator records this harvest information in a
CHP log. The CHP Coordinator returns to NMFS the CHP permit card and CHP log together
upon expiration
Community Harvest Permit Harvest Log
Name of Community Harvest Permit Coordinator
Subsistence Fisher Identification
Name of fisher
Community of residence
Date of birth
Tribal affiliation
SHARC number
Indicate YES or NO whether fisher did subsistence halibut fishing during the period on permit
If YES, complete the following harvest information
Date of harvest
Local water body, bay or sound
IPHC Regulatory Area
Number and Pounds of Halibut
Type of gear used
Number of hooks set
Number of incidental lingcod caught
Number of incidental rockfish caught

When maintaining a community harvest log, the coordinator would take an estimated 30 minutes
to instruct each fisherman on responsibilities prior to fishing and to record the fisherman’s catch
information when returning. The 30 minutes is per fisherman. It is estimated that up to three
fishermen would fish against the license.
Subsistence halibut community harvest log, Respondent
Total respondents
Total annual responses
Frequency of response = 1
Total annual time burden hours (0.5 x 3 x 33 = 49.50)
Time per response (30 min/60 min) = 0.5 hr
Number of fishermen per license = 3
Total personnel cost (50 x $25)
Total miscellaneous cost
Postage to mail log (33 x 0.41=13.53)

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33
33
50 hr
$1,250
$14

Subsistence halibut community harvest log, Federal Government
Total annual responses
Total annual time burden hours (0.5 x 33 = 16.5)
Time per response (30 min/60 min = 0.5)
Total personnel cost (17 x $25)
Total miscellaneous costs

33
17 hr
$425
0

c. Subsistence Ceremonial or Educational Permit Harvest Log
Subsistence Ceremonial or Educational Permit Harvest Log
Name of Ceremonial Permit Coordinator or Educational Permit Instructor
Subsistence Fisher Identification
Name of fisher or student
Daytime telephone number and mailing address (number and street, city and state, zip code)
Community of residence
Date of birth
Tribal affiliation
SHARC number (students do not need a SHARC)
Indicate YES or NO whether fisher did subsistence halibut fishing during the period on permit
If YES, complete the following harvest information
Date of harvest
Local water body, bay or sound
IPHC Regulatory Area
Number and weight (in pounds) of halibut
Type of gear used
Number of hooks set
Number of incidental lingcod caught
Number of incidental rockfish caught

When maintaining a ceremonial or educational permit harvest log, the coordinator or instructor
would take an estimated 30 minutes to instruct each fisherman on responsibilities prior to fishing
and to record the fisherman’s catch information when returning. The 30 minutes is per
fisherman. It is estimated that up to three fishermen would fish against the license.
Subsistence halibut ceremonial or educational harvest log, Respondent
Total respondents
Total annual responses
Frequency of response = 2
Total annual time burden hours (0.5 x 3 fishermen on license x 152)
Time per response (30 min/60 min = 0.5)
Number of fishermen per license = 3
Total personnel costs (228 x $25)
Total miscellaneous costs (243.58)
Postage (38 x 0.41=15.58)
Fax (38 x $6=$228)
Subsistence halibut ceremonial or educational harvest log, Federal Government
Total annual responses
Total annual time burden hours (152 x 0.5)
Time per response (30 min/60 min = 0.5)
Total personnel costs (76 x $25)
Total miscellaneous costs

5

76
152
228 hr

$5,700
$244

152
76 hr
$1,900
0

c. Appeals Process.
NMFS provides an appeals process to provide administrative due process to those whose
applications for a Community Harvest Permit, Ceremonial Permit, or Educational Permit are
denied and to those whose permit is subject to revocation.
In every instance in which an administrative determination is made to deny an application or to
revoke a permit, NMFS issues a formal Initial Administrative Decision (IAD) to the affected
applicant or permit holder. If dissatisfied with the determination, the applicant may appeal to the
NMFS Alaska Region Office of Administrative Appeals (OAA) under 50 CFR part 679.43. For
permit appeals, the participant must provide a written statement in support of the appeal and
must show why the initial determination should be reversed. If the participant does not appeal
within 60 days following the issuance of the IAD, the IAD becomes a Final Agency
Determination.
Subsistence halibut special permit appeal, Respondent
Total respondents
Total annual responses
Frequency of response = 1
Total annual time burden hours
Time per response = 4 hr
Total personnel costs (8 x $25)
Total miscellaneous costs
Postage (2 x $1.64 = $3.28)
Subsistence halibut special permit appeal, Federal government
Total annual responses
Total annual time burden hours (2 x 25)
Time per response = 25
Total personnel costs (50 x $25)
Total miscellaneous costs

2
2
8 hr
$200
$3

2
50 hr
$1,250
0

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. The information collection is designed to yield data that meet all
applicable information quality guidelines. Prior to dissemination, the information will be
subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of
Public Law 106-554.
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.
Applications for Ceremonial Permits and Community Harvest Permits may be made online
through the Internet. Educational Permit applications are “fillable” on the computer screen by
participants at the NMFS Alaska Region Home Page at www.alaskafisheries.noaa.gov, then
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downloaded, printed, and faxed to NMFS; the extra documentation required for these permits
precludes electronic submission.
4. Describe efforts to identify duplication.
None of the information collected as part of this information collection duplicates other
collections. This information collection is part of a specialized and technical program that is not
like any other.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The collection-of-information does not impose a significant impact on small entities.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Without the specified permitting and reporting scheme described in this Support Statement, the
halibut subsistence community harvest, ceremonial, and educational programs would be unable
to proceed.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
No special circumstances exist that would require information collection to be conducted in a
manner inconsistent with OMB guidelines.
8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received
in response to that notice and describe the actions taken by the agency in response to those
comments. Describe the efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions and
recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
A Federal Register notice, 72 FR 50935 published September 5, 2007, solicited public comment.
No comments were received.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gift is provided under this program.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
This information is used to monitor the subsistence halibut program under the Northern Pacific
Halibut Act of 1982 . Responses to this information request are not confidential.
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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.
No issues of a sensitive nature exist under this program.
12. Provide an estimate in hours of the burden of the collection of information.
Estimated total respondents: 109. Estimated total responses: 415. Estimated total burden:
325 hr, increased from 140 hr. Estimated total personnel costs: $8,125, increased from $3,350.
The personnel cost of $25 per hour is based on the average wage equivalent to a GS-7 employee
in Alaska, including COLA.
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 annual miscellaneous costs: $529, decreased from $983.
14. Provide estimates of annualized cost to the Federal government.
Estimated total burden hours: 182. Estimated total personnel cost: $4,550, increased from
$4,301. The personnel cost of $25 per hour is based on the average wage equivalent to a GS-7
employee in Alaska, including COLA, except for the Appeals Office which is estimated to be
$75 per hour.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or
14 of the OMB 83-I.
Postage rates were increased from 0.37 to 0.41.
Subsistence Halibut Special Permits Application Adjustments: a decrease of $454 in
miscellaneous costs, $268 instead of $726. For the number of participants, 114 incorrectly was
used in the calculation instead of 109. Also the former costs were fax and postage, whereas the
renewal incorporates lower-cost online applications.
Community Harvest Log Adjustments: an increase of $2 for miscellaneous costs, $14
instead of $12 due to increase in postage. There was an increase of 33 hours in burden, due to
more accurate calculation.
Ceremonial or Education Harvest Log Adjustments: an increase of $2 for miscellaneous
costs, $244 instead of $242, due to increase in postage. There was an increase of 152 hours in
burden, due to more accurate calculation.

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16. For collections whose results will be published, outline the plans for tabulation and
publication.
Information obtained through registration to issue Halibut Subsistence Community Harvest
Permits, Ceremonial Permits, and Educational Permits is posted on the NMFS Alaska Region at
http://www.fakr.noaa.gov/ram/daily/subsist_other_than_sharc.pdf. The information is posted in
lists sorted by holder, by eligible tribe, and by eligible community. In addition, a summary by
date of the special permits issued to rural and tribal applicants is posted.
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 control number and the expiration date of OMB
approval are shown on the application form and harvest logs.
18. Explain each exception to the certification statement identified in Item 19 of the
OMB 83-I.
In accordance with OMB requirements, the certification statement control is shown on the
application form and harvest logs.

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

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