0040 SS 100510rev

0040 SS 100510rev.pdf

Highly Migratory Species Dealer Reporting Family of Forms

OMB: 0648-0040

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 0648-0040 can be found here:

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SUPPORTING STATEMENT

HIGHLY MIGRATORY SPECIES DEALER REPORTING FAMILY OF FORMS
OMB CONTROL NO. 0648-0040

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
This request is for renewal of previously approved information collections from seafood dealers
regarding purchases or sales of Atlantic highly migratory species (HMS), including federally
managed tunas, sharks, and swordfish. Transactions that are covered under this collection
include purchases of Atlantic HMS from commercial fishermen and import/export of all bluefin
tuna (BFT), frozen bigeye tuna (BET), southern bluefin tuna (SBT) or swordfish (SWO),
regardless of geographic area of origin. The information collected is used to monitor the harvest
of domestic fisheries, and/or track international trade of internationally managed species.
Domestic catch/landing data are necessary to effectively manage domestic fisheries. This
information is used to monitor quotas, estimate fishing mortality, and identify the geographic and
temporal distribution of fish and fisheries. Collection of this information for use in domestic
fishery management is authorized under the Magnuson-Stevens Fishery Management and
Conservation Act (16 U.S.C. 1801 et seq.) (MSA). Regulations at 50 CFR 635.5 implement
domestic dealer reporting requirements. The domestic reporting covered by this collection
includes domestic biweekly landings reports and negative reporting (i.e. reports of no activity,
when applicable), and bluefin tuna daily landings, including tagging of individual fish.
International trade tracking programs are required by both the International Commission for the
Conservation of Atlantic Tunas (ICCAT) and the Inter-American Tropical Tuna Commission
(IATTC). An overall goal of these programs is to reduce illegal, unreported and unregulated
fishing for the covered species, and improve management of associated fisheries. The programs
are designed to account for all international trade of covered species by requiring that a statistical
document (SD) or catch document (CD) accompany each export from and import into a member
nation, and that a re-export certificate (RXC) accompany each re-export. In this way, markets
will be closed to trade of covered species with non-participating nations. Collection of this
information to implement certain international fishery management recommendations is
authorized under the Atlantic Tunas Convention Act [ATCA; 16 U.S.C. 971(d)] and
implemented in regulations at 50 CFR 300 Subpart M.
The United States (U.S.) is a member of ICCAT and authorized by ATCA to promulgate
regulations as may be necessary and appropriate to implement recommendations adopted by
ICCAT. ICCAT has adopted recommendations for the mandatory implementation of CD, SD
and RXC trade tracking programs for BFT, frozen BET and SWO. U.S. regulations
implementing ICCAT SD and CD programs require SDs and CDs for international transactions
of the covered species from all ocean areas, so Pacific imports and exports must also be
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accompanied by SDs and CDs. Since there are SD programs in place under other international
conventions (e.g., the Indian Ocean Tuna Commission), an SD from another program may be
used to satisfy the SD requirement for imports into the U.S.
The U.S. is also a member of the IATTC, and required under the Tunas Convention Act of 1950
(TCA; 16 U.S.C. 955) to implement recommendations adopted by IATTC. IATTC has mandated
a trade tracking program for frozen BET, which the National Marine Fisheries Service (NMFS)
has implemented for shipments of frozen BET from the Pacific Ocean.
Dealers who internationally trade SBT are required to participate in a trade tracking program
implemented by the Commission for the Conservation of Southern Bluefin Tuna (CCSBT). This
facilitates enforcement of ICCAT’s BFT CD program by ensuring that imported Atlantic and
Pacific BFT will not be intentionally mislabeled as SBT in order to circumvent reporting
requirements. This action is authorized under ATCA, which provides for the promulgation of
regulations as may be necessary and appropriate to carry out ICCAT recommendations.
In addition to SD, CD and RXC requirements, this collection includes biweekly reports to
complement trade tracking SDs by summarizing SD data and collecting additional economic
information.
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.
Atlantic BFT Daily Landing Reports and Tagging
NMFS uses the information collected in this portion of the reporting package to monitor U.S.
landings of Atlantic BFT in relation to the assigned quota, thereby ensuring that the U.S.
complies with its international obligations to ICCAT. In addition, provisions of domestic
regulations such as time/area closures, fishing seasons, and subquotas by gear type and/or user
group are monitored through these reporting instruments. The data collected is also used to
assess the status of the BFT resources. Data reports are reviewed by ICCAT annually, and
provide the basis for ICCAT management recommendations that become binding on member
nations.
This portion of the package describes two reporting requirements. The Landing Report is used
for daily, real-time quota monitoring. Dealers are required to FAX reports to NMFS within 24
hours of purchasing an Atlantic BFT. Second, uniquely numbered tail tags must be affixed to
each Atlantic BFT purchased from a fisherman, after which the tag numbers are recorded on the
Landing Report and Atlantic BFT Domestic Landing Biweekly (discussed below). (Domestic
landings of Pacific BFT are not recorded under this collection, and use of tail tags is optional for
Pacific BFT.)

The following information is collected on the Atlantic BFT Daily Landing Report:
1. Dealer name and permit number;
2. Date the fish was landed;
3. Gear type used to capture the BFT - used for estimating catch per unit effort as part of stock
assessment;
4. Length and weight of fish & measurement method (curved or straight length / round or
dressed weight) - used to determine age of fish and population structure; weight used for quota
management;
5. Tail tag number - identifies fish and provides cross-reference with biweekly report, and is
used in place of CD validation;
6. Area caught - provides information on temporal distribution of fish and fishing, and aids in
enforcement of area closures;
7. Port landed - identifies principal ports for the fishery, temporal distribution of fish, and aids in
enforcement;
8. Fisherman and vessel names, permit number and signature - provides vessel permit
enforcement information.
Biweekly Landings Reports
NMFS uses biweekly reports to account for domestic landings of managed species, and collect
and verify international trade data. For species managed by quotas, such as sharks, swordfish
and BFT, this information is vital to ensure that landings do not exceed the established quota.
For BFT, timely quota management requires that landings be accounted for on a daily basis (see
above). Thus for BFT, biweekly reporting is used to verify daily landing report information and
collect economic information needed to manage the fishery. For international related reporting,
biweekly reports also are used to cross-reference and check information provided on SDs and
collect important economic information needed for managing the fishery. Four types of biweekly
reports used to monitor information on HMS are covered under this collection
The NMFS Southeast Region (SER) uses the Dealer Reporting form for HMS, collected on
a biweekly basis, to monitor swordfish, shark, and tuna (bigeye, albacore, yellowfin, and
skipjack or “BAYS”) landings as well as landings of coastal pelagics. Since dealers that
purchase HMS also frequently purchase coastal pelagics, reporting for these species (dolphin,
greater amberjack, king mackerel, escolar, and wahoo) is also included on this form, but the
reporting burden is not included under this collection. The information on this form is used to
track landings against quotas and collect landings data for use in stock assessments. If no HMS
or coastal pelagics are landed during the biweekly reporting period, a report (i.e., a negative
report) must still be filed. This requirement clarifies for NMFS whether or not a report is
pending from the dealer for the reporting period. The following information is required on the
SER Dealer Reporting for HMS form:
1. Dealer name;
2. SER Dealer number;
3. Northeast Region Dealer number (if applicable) - provides cross-reference and helps avoid
any double reporting;
4. Begin & end date for reporting period;
5. Contact (optional);
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6. Negative reporting option - (see above);
7. Dressed weight and price per pound for recorded species - provides economic data used in
development of management measures and landings used for quota monitoring and stock
assessment;
8. Date landed, vessel name, documentation number, port landed and state landed - provides
information on temporal distribution of fish and fishery and provides enforcement data for permit
checks.
The second biweekly report is used to monitor Atlantic BFT landings and can be used by
dealers that land Atlantic BFT to track BFT trade (exports). Information on the sale and
disposition of BFT is also collected. The following information is collected on the Biweekly
Atlantic BFT Dealer Landings and Trade Report:
1. Biweekly reporting period;
2. Dealer name, Atlantic Tunas Dealer permit number, and name of person filling out report;
3. Date of landing;
4. Vessel permit I.D. number - used for enforcement purposes;
5. Tail tag number - used to identify the fish and cross-reference with daily landing report and
BFT SD;
6. Weight of the fish (round or dressed) - used to cross-reference daily landing report
information and collect economic information;
7. Nature of sale (dockside or consignment) - used in assessing the relative importance of the
Japanese and U.S. domestic markets;
8. Price per pound - important for evaluating economic characteristics of the fishery;
9. Quality rating - assists in determining how regulations affect price of BFT; and
10. Destination of fish (domestic, import, export, or re-export) - used for assessing importance
of foreign market and identifying variables that can affect all markets.
The third biweekly form monitors international trade of BFT, SBFT, BET, and SWO.
This information is used to cross-check and verify SD data as well as obtain economic
information that is essential for domestic management policy and rulemaking with respect
to management impacts on prices. The following information is required on the HMS Trade
Biweekly Dealer Report:
1. Dealer Name;
2. HMS International Trade Permit number;
3. Contact name and phone number;
4. Report time period;
5. For each shipment/fish:
a. Species
b. Statistical document and re-export certificate (if applicable) number - cross-checks trade
documentation;
c. Entry number from US customs form 7501 (import only) - allows for cross-check of trade
data with customs data;
d. Date of import or export;
e. Total weight of shipment (import only) - cross-check with trade data;

f. Condition (fresh or frozen) and product form (round, headed, gutted, steaks, fillets, loins,
dressed) - used to assess how regulations and other factors affect ex-vessel prices and gross
revenues;
g. Weight of each fish (if available) - used to estimate gross revenues and cross-check trade
data;
h. Price per kilogram - used to evaluate the status of the market and gross revenues;
i. State/landing document number - cross-check used for non-government validation;
j. Tag number (if applicable) - cross-checked with trade data for verification; and
k. Destination of fish (import, domestic, export, re-export) - cross-checks with trade data
and customs data.
The fourth type of biweekly reporting covered by this collection includes reports to the
NMFS Northeast Region (NER) for shark, swordfish and BAYS tuna landings data by
dealers who do not possess other NER permits. This reporting occurs on a biweekly basis in
the form of dealer-generated forms that provide the landing weight and covered highly migratory
species. Landings reports for these species by dealers who possess other NER permits are
covered under the collection 0648-0229.
Catch Document and Statistical Documents and Re-export Certificates
Original CDs and SDs accompany each export from or import into the United States, and must
stay with a shipment until it reaches its final destination. Covered species include Atlantic
bluefin tuna, Pacific bluefin tuna, Southern bluefin tuna, swordfish, and frozen bigeye tuna. If
the shipment is re-exported, then a RXC may also be required. NMFS collects the documents
and forwards the information to ICCAT or IATTC, which can then compare the data collected
from all participating nations to cross-reference and verify trade and landings data. The program
is designed to account for all trade of the covered species. Trade data may be cross-referenced
with each nation’s landings quotas to help identify illegal or unreported landings.
A CD or SD is considered completed and approved for import, export, or re-export if it is
identified by a number assigned by the issuing government and has all of the required
information recorded, and, if applicable, is validated (see below). U.S. CDs and SDs will be
available from NMFS to accompany exports from the United States. Imports to the United States
must be accompanied by a CD or SD issued by the flag country of the harvesting vessel. If
needed, foreign exporters may obtain unnumbered CDs or SDs from the appropriate website
(www.iccat.int; www.iattc.org; www.ccsbt.org; www.iotc.org) to accompany exports to the
United States; a document number must be assigned by the country issuing the CD or SD. U.S.
importers are required to complete the import section of the foreign CD or SD. Sample CDs,
SDs, and RXCs are included in this submission.
The following information is required on all SDs and is used for tracking the product unless
otherwise noted:
a) The document number assigned by the country issuing the document;
b) The name of the country issuing the document, which must be the country whose flag
vessel harvested the fish, regardless of where it is first landed;

c) The name of the vessel that caught the fish, the vessel's length, the vessel’s registration
number, and ICCAT record number, if applicable;
d) The point of export, which is the city, state or province, and country from which the fish is
first exported;
e) The product type (fresh or frozen), time of harvest (month/year), and product form (round,
gilled and gutted, dressed, fillet, or other);
f) The method of fishing used to harvest the fish (e.g., purse seine, trap, rod and reel) - used to
gather socioeconomic data on fishery regarding catch per sector;
g) The ocean area from which the fish was harvested (i.e., western Atlantic, eastern Atlantic,
Mediterranean, or Pacific);
h) The weight of each fish (in kilograms for the same product form previously specified) or the
net weight of each product type, as applicable;
i) The name and license number of, and signature of, the exporter and date in the exporter's
certification block; and
j) The name and title of, and signature and date in the validation block by, the responsible
government official of the country whose flag vessel caught the fish (regardless of where the fish
are first landed) or by an official of an institution accredited by said government, with official
government or accredited institution seal affixed, thus validating the information on the statistical
document. (NOTE: Validation of an imported SD by a government official is not required if
NMFS waives the requirement following a recommendation of the ICCAT Secretariat.)
k) If applicable, the name(s) and address(es), including the name of the city and state or province
of import, and the name(s) of the intermediate country(ies) or the name of the country of final
destination, and license number(s) of, and signature and date in the importer certification block
by each intermediate dealer and final importer.
Bluefin Tuna Catch Documents. Bluefin tuna catch documents, to be deemed complete, in
addition to the elements above must also state:
(1) Whether the fish was farmed or captured.
(2) Identifying information regarding the owner of the trap that caught the fish or the farm from
which the fish was taken, if applicable.
(3) The identifying tag number, if landed by vessels from countries with BSD tagging programs
or tagged by a U.S. dealer under the Atlantic BFT tagging program.
(4) Documents for tagged fish do not have to be validated.
Southern Bluefin Tuna Statistical Documents. Southern bluefin tuna statistical documents, to be
deemed complete, in addition to the elements above, must also state:
(1) The name and address of the processing establishment, if applicable.
Bigeye Tuna Statistical Documents. Bigeye tuna statistical documents, to be deemed complete,
in addition to the elements above, must also state:
(1) The name of the trap that caught the fish, if applicable.
(2) The net weight of product for each product type (in kilograms for the same product form
previously specified).

Swordfish Statistical Documents. Swordfish statistical documents, to be deemed complete, in
addition to the elements above must state:
(1) Certification by the exporter that the individual Atlantic swordfish included in the shipment
are greater than 15 kilograms (33 lbs.) or if pieces, that the pieces were derived from a swordfish
weighing more than 15 kilograms (33 lbs).
The following information is required on all RXCs and is used for tracking the product unless
otherwise noted:
1) The document number assigned by the country issuing the document.
2) The name of the country issuing the document, which must be the country through which the
product is being re-exported.
3) The point of re-export, which is the city, state, or province, and country from which the
product was re-exported.
4) The description of the fish product as imported, including the product type (fresh or frozen),
product form (round, gilled and gutted, dressed, fillet, or other), the net weight, flag country of
the vessel that harvested the fish in the shipment, and the date of import to the country from
which it is being re-exported, and the original SD or CD number.
5) The description of the fish product as re-exported, including the product type (fresh or frozen),
product form (round, gilled and gutted, dressed, fillet, or other) and the net weight.
6) The name and license number (if applicable) of, and re-exporter’s signature and date in the reexporter's certification block.
7) If applicable, the name and title of, and be signed and dated in the validation block by, a
responsible government official of the re-exporting country appearing on the certificate, or by an
official of an institution accredited by said government, with official government or accredited
institution seal affixed, thus validating the information on the re-export certificate.(NOTE:
Validation of a RXC by a government official is not required if NMFS waives the requirement
based on a recommendation from the ICCAT Secretariat.)
8) If applicable, the name(s) and address(es), including the name of the city and state or province
of import, and the name(s) of the intermediate country(ies) or the name of the country of final
destination, and license number(s) of, intermediate and final exporters, signed and dated in the
importer's certification block.
Bluefin Tuna Re-Export Certificates. Bluefin tuna re-export certificates, to be deemed complete,
in addition to the elements described above must also state whether the fish for re-export was
farmed, and the name and address of the farm, if applicable.
Validation - NMFS has worked with ICCAT with the intent of minimizing the public reporting
burden for the government validation requirement. ICCAT/IATTC require that CDs, SDs, and
RXCs be validated by a government institution at export. For example, in the United States,
Atlantic BFT are tagged when landed, and the numbered tag stays with the carcass. ICCAT and
U.S. regulations exempt tagged fish from validation requirements since the BFT data associated
with the tag number must be provided to NMFS and can be tracked. In addition, NMFS has
instituted a validation service which is available on a 24 hour/7 day per week basis. NMFS may
also authorize non-governmental industry partners to validate CDs, SDs, and RXCs once they
have met the necessary requirements. The entity must apply for authorization in writing to
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NMFS, and indicate the procedures to be used for verification of information to be validated, list
the names, addresses, and phone/fax numbers of individuals to perform validation, and provide
an example of the stamp or seal to be applied to the statistical document or re-export certificate.
Upon approval, NMFS will issue a letter specifying the duration of effectiveness and conditions
of authority for validation. Authorization must be renewed annually.
Although the information collected is not expected to be disseminated directly to the public, it
may be used in the development or review of fishery management plans and associated
regulatory documents, and is therefore subject to NOAA’s Information Quality Guidelines. As
explained in the preceding paragraphs, the information gathered has utility. NOAA Fisheries
will retain control over the information and safeguard it from improper access, modification, and
destruction, consistent with NOAA standards for confidentiality, privacy, and electronic
information. See response to Question10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed to yield data that meet all
applicable information quality guidelines. Although the information collected is not expected to
be disseminated directly to the public, results may be used in scientific, management, technical or
general informational publications. Should NOAA Fisheries Service decide to disseminate the
information, it will be subject to the quality control measures and pre-dissemination review
pursuant to Section 515 of Public Law 106-554.
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.
Most reporting forms under this collection are electronically fillable. The statistical documents
and re-export certificates must be original documents. Electronic submission for all forms is
being investigated domestically. BFT daily landing reports are submitted and entered into the
database via FAX, and some validation is provided via FAX. In addition, the U.S. is pursuing
development of electronic trade monitoring programs among regional fishery management
organizations. Future availability of electronic form submissions could reduce the overall cost
and administrative burden to the public by providing an internet accessible web page where the
forms can be filled out and submitted electronically.
Catch documents may be generated online and printed out, following directions on the NMFS
website (http://www.nmfs.noaa.gov/sfa/hms/ITP/International_Trade_Permit.htm) These may be
emailed or faxed to NMFS. NMFS is preparing to implement the International Trade Data
System which will provide permit holders with the ability to submit all documents electronically.
See also Question 4 below.

4. Describe efforts to identify duplication.
The impacts of the reporting requirements were analyzed prior to implementation through
rulemaking processes including public review. In addition, a Federal Register Notice announced
the renewal of this reporting package. No duplicative efforts were identified. The Highly
Migratory Species Management Division of NMFS works closely with other NMFS offices on
reporting and permitting issues, and ensures that reporting regulations are not duplicative.
Although daily landing reports, biweekly report forms, and SDs may include some of the same
data fields, this information is necessary to cross-reference and cross-check reports. NMFS has
attempted to combine SDs with other reporting requirements into a single form in the past;
however, ICCAT did not approve the use of forms other than those developed specifically by
ICCAT. NMFS has been able to combine several non-ICCAT reporting requirements to reduce
the number of forms dealers must fill out (i.e., HMS Trade Biweekly Dealer Report covers all
affected species). In addition, the U.S. is participating in discussions among many regional
fishery management organizations (most recently in a June 2010 meeting in Barcelona, Spain) to
determine ways of using technology to reduce paperwork and improve the efficacy of trade
monitoring programs.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
Small businesses will be the respondents of this data collection and this collection will not have a
significant impact on them. As described in Question 4, reporting requirements have been
condensed as much as possible. In addition, electronic reporting will be implemented as soon as
practicable, as discussed in Questions 3 and 4.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Atlantic BFT Landing Reports and Tagging - If reporting were conducted less frequently or not
conducted at all, the United States could overharvest its internationally approved BFT quota, and
would fall out of compliance with its international obligations under ICCAT, in violation of
ATCA. In addition, the status of the resource would be indeterminable since approximately 55
percent of the western Atlantic BFT Total Allowable Catch is allocated for landing by U.S.
fishermen, and the conservation and management objectives of ATCA and ICCAT would be
jeopardized. Furthermore, it would be impossible for the United States to formulate domestic
policy consistent with the Magnuson-Stevens Act, which is based on sound socioeconomic and
biological data and analyses.
Biweekly Reports - A two-week time period has provided a reasonable reporting regime for
dealers without significantly delaying quota monitoring for species such as sharks and swordfish.
If reporting were less frequent (e.g., monthly), timely quota monitoring could be compromised.
Inefficient quota monitoring or altogether loss of monitoring could result in over-harvest of the
ICCAT-recommended U.S. swordfish or BFT quota, which would violate obligations under
ICCAT and ATCA. Over-harvest of HMS quotas (including sharks) could negatively impact
9

stocks and the fishing industry, and violate the Magnuson-Stevens Act. Lastly, this information
is necessary for the development of domestic policy, since it provides socioeconomic and
biological data upon which policy decisions are based.
Catch Documents, Statistical Documents, and Re-export Certificates - If this information
collection were not conducted, the U.S. would fall into a status of non-compliance with its
international obligations under ICCAT and IATTC, in violation of ATCA and TCA, respectively.
Without the authorization of non-government validation, NMFS would be required to
individually validate each export and re-export, which would impose a greater reporting burden
on industry. If authorization were not renewed annually, in the same manner that dealer and
vessel permits are annually renewed, NMFS would not be able to effectively monitor
implementation of the trade program.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The frequency with which data are collected in this package is inconsistent with OMB guidelines
that respondents should not be required to report information more often than quarterly. To
accurately monitor the domestic quota allocation among a diverse group of users, BFT landings
data must be collected on a real-time basis. Furthermore, biweekly reports are necessary to
manage other quotas, including sharks, swordfish, and king mackerel. Failure to maintain the
current reporting frequency could jeopardize the agency’s ability to close fisheries prior to
exceeding a quota. (See Question 6 also regarding reporting frequency).
8. Provide information on 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 published on May 14, 2010 (75 FR 27296) solicited public comment
on this collection. No public comments were received in response to this notice.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are to be offered as part of this information collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
Pursuant to Section 402(b) of the Magnuson-Stevens Act, as amended in 2007, and consistent
with NOAA Administrative Order 216-100 (Confidentiality of Fisheries Statistics), NMFS does
not release confidential information submitted in compliance with provisions of the MSA, other
than in aggregate form and under circumstances required or authorized by law. Whenever data
are requested or released to the general public, the Agency ensures that information on the
financial business activity of a dealer is not identified.
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 information of a sensitive nature is requested in this collection of information.
12. Provide an estimate in hours of the burden of the collection of information.
For this collection, there are 1,832 respondents, 29,984 responses and 6,735 hours
(responses and totals added from Tables 3 and 4). Total labor costs are $100,080.
Burden hours associated with each reporting instrument are given in Table 1 and estimation of
burden hours is discussed below by reporting requirement. All reports covered by this collection
are required to be kept by the dealer for a period of 2 years. The burden hour estimate for each
report includes the time required for filing and storing reports.
Table 1. Burden estimates for each dealer reporting instrument employed by this collection.
Reporting Requirement

Burden

Biweekly Reports

0.25 hrs (15 mins)

Catch Document (CD) Statistical Document (SD) or Re-export
Certificate (RXC) (includes all steps from export to import)

0.08 hrs (5 mins.)

CD/SD/RXC validation by govt. official

0.25 hrs (15 mins)

Authorization for non-government validation

2 hours (120 mins)

Daily Landing Report

0.03 hrs (2 mins.)

Tagging (for BFT domestic landing reporting)

0.02 hrs (1 min.)

The universe of respondents for this collection is identified in Table 2, and includes the
following: all U.S. dealers importing or exporting BFT, frozen BET, SWO, or SBT,(HMS
International Trade Permit holders), U.S. dealers located in the SER that land SWO, BAYS tuna,
or sharks, and dealers that land these species located in the NER that do not have any other NER
permits, all dealers landing BFT, and non-government institutions requesting validation
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authorization. Finally, an estimated number of international dealers is given, since burden hours
must be calculated for international respondents as well as domestic respondents. Foreign
dealers impacted by this collection include exporters that must fill out statistical documents and
obtain validation prior to exporting a shipment to the U.S. The number of foreign respondents
was calculated by identifying the number of countries exporting BET (40), BFT, (20), SBT (4) or
SWO (29) to the United States, and assuming that there were approximately 10 active exporters
per country.
Table 2 Estimate of total number of respondents for this collection
Respondent Type

Number

HMS International Trade Permits

233

Shark or Swordfish Permits

283

Tuna Permits (BFT, BAYS or both), includes:
SER BAYS dealers
NER BAYS dealers w/o other NER permits
International Dealers

376
55
10
930

Non-government Institutions for Validation

TOTAL

1,832

Atlantic BFT Landing Reports and Tagging
Atlantic BFT daily landing reports are submitted to NMFS for each Atlantic BFT purchased by a
dealer from a vessel, and each of these fish must be tagged. The burden associated with these
reporting activities is based on the number of BFT landed during 2009 given by the Northeast
Regional Office (NERO) and summarized in Table 3.

Table 3. Biweekly and other dealer reporting activities for this collection.
Instrument or Activity

Responses

Burden
(hrs.) per
response

Burden
(hrs)

Domestic BFT Landings
Atlantic BFT Daily Landing Report

2000

2 minutes

Atlantic BFT Landing tag (formerly OMB Control
No.0648-0239)

2000

1 minute

8346

15 minutes

2087

6580

15 minutes

1645

865

15 minutes

216

1854

5 minutes

155

2 hours

Biweekly Reports
Bluefin Tuna Domestic Landing Biweekly Report
HMS Trade Biweekly Dealer Report
HMS biweekly landings report for sharks,
swordfish & BAYS tuna
HMS biweekly negative reporting
Validation Authorization
Non-governmental validation authorization
TOTAL

21,655

4,223

Biweekly Reports and Non-governmental Validation
Estimation of biweekly reporting for Atlantic BFT dealers is based on reporting during a
previous year of relatively high landings, and included in Table 3. Biweekly reporting for
swordfish, sharks, and BAYS tuna as well as negative reporting that is required when permitted
dealers do not receive landings of these species during a reporting period is estimated in Table 3.
Numbers of biweekly reports were collected from the Southeast Fisheries Science Center during
the calendar year 2009.
The international trade biweekly reporting requirements for this collection occur on the HMS
Trade Biweekly Dealer Report. Estimation of burden hours associated with this form was
calculated by multiplying the number of responses gathered from the NERO and multiplying the
number by the estimated burden per response.
Non-government institutions may apply for authorization to validate statistical documents or reexport certificates by applying in writing, indicating the procedures to be used for verification of
information to be validated, the names and contact information of individuals that will perform
the validation, and an example of the stamp or seal applied to the statistical document or reexport certificate. Authorizations must be renewed on an annual basis. In the past, one
13

institution has been provided with validation authority for Pacific BFT. With the increase in
need for validation based on the recent expansion of SD programs, it is estimated that
approximately 9 other institutions may apply for this authority for a total of 10. Preparing the
necessary application is expected to take approximately 2 hours. Total burden hours are given in
Table 3.
Total reporting burden for Atlantic BFT domestic reporting, all biweeklies, and nongovernmental authorization for statistical document validation is estimated at 4,222 hours with
an estimated opportunity cost of $15/hour, this results in an approximate cost of $62,400.
Statistical Documents and Re-export Certificates
Burden estimates for CDs, SDs, RXCs, and validation are calculated in Table 4. The annual
number of shipments by species for frozen BET, SBT, and SWO for each trade activity
(import/export/re-export) was provided by the National Seafood Inspection Lab, derived from
customs data. U.S. Customs data tracks total imports, and provide the total annual weight and
number of shipments for each species. This information was used to calculate the average
weight of each shipment. BFT catch document program data from 2009 was used for calculating
BFT burden estimates in Table 4.
ICCAT requires that exports (including some re-exports) associated with its SD programs are
validated. This validation requirement is implemented by either tagging each fish in a shipment
and maintaining the necessary records, or obtaining verification from a government official or
their designee. The tagging option is currently available for Atlantic and Pacific BFT. (Atlantic
BFT are tagged upon landing (see above)). A FAX-in system is available for all other validation,
whereby a dealer faxes a complete document to a NMFS contractor, and the document is returned
to the dealer with the necessary validation stamp in place and a document number.
The total burden associated with catch and statistical documents, re-export certificates and
validation is 2,512 hours. Using $15/hour as the opportunity cost, the reporting cost is estimated
at $37,680.

Table 4. International dealer trade reporting burden estimates for bigeye tuna (BET), bluefin tuna (BFT),
southern bluefin tuna (SBT) and swordfish (SWO) statistical documents (SD), re-export certificates (RXC), and
shipment certification. Estimates are given by species for imports (I), exports (E) and re-exports (R)) and by
coast (Atlantic - A, Pacific - P) for bluefin tuna.
Activity

# of CDs, SDs,
or RXCs
(based on # of
shpmts for 2009)

CD/SD/RXC
Response
Hourly Burden
5 min per form)
(less than 1 hour
total rounded up to
1 hour)

Validation
Burden
(15 min. per
shipment)
Domes
tic

TOTAL
HOURS

Foreign

BET (frozen)
I

968

BFT (Atlantic/Pacific)
I (A)

242

323

E (A)

1073

N/A

R (A)

181

I (P)

370

E (P)

R (P)

201

5,134

428

147

111

8,329

695

124

SBT
50

SWO

TOTALS

1,284

1,693

1,712

2,512

NOTE:

Domestically landed BFT are required to be tagged, which is used for certification of exports. Burden hours
are calculated under the domestic portion of this collection (Table 3).

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 Question
12 above).
Costs for the public as a result of this collection include the cost of submitting reports to NMFS
via either U.S. mail or FAX. Forms and tags are provided free of charge. Mailing costs are

estimated in Table 5. In addition, non-government institutions approved for validating exports
would spend approximately $10 for a validation stamp and total costs are estimated in Table 5.
Table 5. Costs to the public as a result of this collection, not including those associated with burden hours.
Reporting Instrument

Number of
Responses

Submission
Method

Cost per
Item ($)

Total
Cost
($)

Atlantic BFT Daily Landing Report

2,000

FAX

0.15

300

Atlantic BFT Landing Biweekly Report

8,346

mail

0.44

3,672

Atlantic BFT Landing Tag

2,000

N/A

865

mail

N/A

HMS biweekly negative reporting

1,854

mail

N/A*

HMS Trade Biweekly Dealer Report

6,580

mail

0.44

2,895

CDs, SDs, & RXCs

8,329

mail

0.44

3,665

Included in
CDs etc.

FAX

0.15

1,249

mail

0.44

HMS biweekly landings report

Validation for CDs, SDs, & RXCs
Non-governmental validation auth. (Total
cost includes $10/dealer for valid. stamp)
TOTAL

29,984

11,785

*Postage-paid envelopes are supplied.

14. Provide estimates of annualized cost to the Federal government.
Costs to the Federal government for this collection include the reproduction of documents and
tags, and contracted validation services. For domestic reporting, daily landing reports, tags, and
biweeklies must be reproduced. Landing report books cost approximately $5.06/book and
approximately 376 (number of dealers with Atlantic tuna permits) will be needed for a total of
$1,903. Tags cost approximately $.075 per tag and approximately 2,000 will be needed for a total
of $1,500. Biweeklies cost approximately $.05 per copy and approximately 2,719 will be needed
for a total of $136. SER provides postage-paid envelopes to dealers reporting on the HMS
biweekly landings report, costing approximately $1/response for a total of $2,719.
For international reporting, SDs and RXCs must be reproduced. At a cost of approximately $.13
per copy and a total number of approximately 7,959 the total cost would be approximately $1,035.
The average cost of validation services is $300 per month or approximately $3,600 per year.
Total cost to the Federal government for the items listed above is $10,893.

15. Explain the reasons for any program changes or adjustments.
Annual Adjustments accounted for all of the modified reporting and cost burden estimates,
which are given in Table 6. Small changes occurred from the last renewal period due to increases
in some of the response categories and thus increased burden hours, based on 2009 data. Landings
and trade of species requiring CDs, SDs, and RXCs vary from year to year.
Table 6. Program adjustments
Adjustment Category
Number of Respondents
Number of Responses
Number of Burden Hours
Total Annual Costs

New
Estimates

Adjustment

1,751

1,832

37,435

29,984

-7,451

6,152

6,735

583

$8,258

$11,785

$3,527

16. For collections whose results will be published, outline the plans for tabulation and
publication.
Results from data collection using the forms in this family are not planned for publication.
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.
Consistent with the last renewal of OMB approval for the BFT CD forms (OMB Control
No.0648-0040), it is requested that the burden statement, expiration date, and OMB Control
Number not appear on the CD form, but be provided in a cover letter to U.S. tuna dealers and
importers. An example cover letter (“0040 attachment permit holder letter”) is included in this
submission. The reason for this request stems from concerns expressed by other ICCAT members
that U.S. CDs not differ from the format agreed to at the conference of parties. Due to the
confusion the PRA information presents to foreign dealers and customs officials, in the last
renewal package for this collection, NMFS proposed to provide this information in a cover letter
so that the form would match the generic form adopted by ICCAT. In addition, SDs and RXCs
for SWO, BET and SBT are available to dealers either from NMFS or from the internet websites
of the different international commissions (ICCAT, IATTC, CCSBT, IOTC). NMFS wants
dealers to be able to access the forms directly from these websites. Since all U.S. dealers will be
required to have an international trade permit in order to import and/or export species requiring
CDs or SDs, NMFS will be able to ensure that each dealer receives the cover letter. This will
meet NMFS obligations under the PRA while reducing the likelihood of delays/problems in
clearing customs in countries that are contracting parties to ICCAT.
NMFS already has a process in place for BFT CDs whereby individually numbered CDs are
allocated to each dealer. The OMB Control Number is printed on each form, and the rest of the
PRA information is included in a cover letter.
17

The BFT daily landing report is part of an optical character recognition (OCR) system which reads
data from a hard copy and puts it in electronic format. Any text in addition to that required for
data fields would compromise the OCR system. However, these landing reports are distributed in
a booklet form, and the booklet cover includes all the necessary PRA statements, including the
OMB Control Number and expiration date.
18. Explain each exception to the certification statement.
Not Applicable.

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

File Type	application/pdf
Author	dianne stephan
File Modified	2010-10-18
File Created	2010-10-18