Change request justification for electronic submission and emailing, respectively, of two subsets of documents

Highly Migratory Species Dealer Reporting Family of Forms
OMB Control No. 0648-0040
JUSTIFICATION OF CHANGE: Minor adjustment to allow Voluntary Electronic Report
Submission
Communication systems in the United States have rapidly shifted to electronic formats such as
email, text messaging, and use of internet portals to provide information. National Marine
Fisheries Service (NMFS) has incorporated such new technologies already in some dealer or
vessel reporting programs. NMFS would like to update the HMS Dealer Reporting Family of
Forms (OMB Control No. 0648-0040) to allow HMS dealers to satisfy appropriate NMFS
reporting requirements electronically, on a voluntary basis, saving dealers time and money.
NMFS is constructing an internet portal to allow dealers to create and submit export bluefin
catch documents. Through this portal, which will be a link from
http://www.nmfs.noaa.gov/sfa/hms/ITP/index.htm, International Trade Permit holders may enter
and store data to be used to create bluefin catch documents for exports. Once all information is
entered, then the documents would be printed out and exported along with the bluefin shipment,
as required by the International Commission for the Conservation of Atlantic Tunas (ICCAT)
bluefin catch document program. Use of paper data forms will still be available to permit
holders whose preference is to submit hard copy forms. Alternatively, forms could be completed
and emailed to BFTReporting@NOAA.gov.
Further, certain dealer reports do not require submission of the original, hard-copy document or
submission via a particular medium (i.e., FAX). NMFS would like to allow the following
reports to be submitted via email. Those in the list below that require a signature could be
scanned and emailed.
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Biweekly Atlantic Bluefin Tuna Dealer Landings and Trade Report
Highly Migratory species (HMS) Trade Biweekly Dealer Report
(ICCAT) Bluefin Tuna Re-export Certificate
Swordfish Statistical Documents and re-export certificates (for exports)
Southern Bluefin tuna statistical document & re-export certificate (for exports)
Bigeye Tuna statistical documents and re-export certificates (for export)
HMS Biweekly Dealer Report

For certain other reporting requirements, such as import documents under the regulations
implementing the ICCAT bluefin catch document program and statistical document programs,
original documents must be submitted to NMFS. These documents include:
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ICCAT Bluefin tuna catch document and re-export certificate (import)
ICCAT Swordfish statistical document and re-export certificate (import)
Southern bluefin tuna statistical document and re-export certificate (import)
Bigeye tuna statistical document or re-export certificate (import)

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This requirement may change as NMFS implements the International Trade Data System
(ITDS). Dealer reporting regulations at 50 CFR 300 Subpart M and 635 clarify whether original
documents are currently necessary.
As NMFS implements the International Trade Data System, electronic reporting (via a portal) is
also expected to be available for imports. The ITDS is a single data entry portal that is under
development as required by the Safe Ports Act of 2006 (P.L. 109-347, October 13, 2006) for
entry of all Federal government-required trade data. An Advanced Notice of Proposed
Rulemaking published on May 8, 2009 (74 FR 21615 ), and NMFS anticipates full ITDS
integration for import data by 2012. An additional change request will be submitted at the time
of Final Rule publication, to address this change.
The burden hours and costs for the instruments in this reporting package previously approved
under 0648-0040 would stay the same as a result of this currently proposed adjustment.

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