0401 Chinook EDR 03-19-11.ss

SUPPORTING STATEMENT
NMFS ALASKA REGION AMERICAN FISHERIES ACT REPORTS
(FORMERLY ALASKA COOPERATIVES IN THE BERING SEA AND
ALEUTIAN ISLANDS)
OMB CONTROL NO. 0648-0401
National Marine Fisheries Service (NMFS), Alaska Region manages the groundfish fisheries in
the Exclusive Economic Zone off Alaska. The North Pacific Fishery Management Council
(Council) prepared the Fishery Management Plan (FMP) for Groundfish of the Bering Sea and
Aleutian Islands (BSAI) Management Area under the authority of the Magnuson-Stevens Fishery
Conservation and Management Act, 16 U.S.C. 1801 et seq. (Magnuson-Stevens Act). The FMP
is implemented through regulations at 50 CFR part 679.
NMFS manages the Bering Sea pollock fishery under the American Fisheries Act (AFA)
(16 U.S.C. 1851 note). The AFA “rationalized” the Bering Sea pollock fishery in part by
allowing for the formation and management of fishery cooperatives in the three pollock sectors
(catcher/processor, mothership, and inshore). A separate CDQ Program manages a portion of the
Bering Sea pollock fishery. The AFA inshore sector is further subdivided into seven inshore
cooperatives. Each sector or cooperative further subdivides pollock allocation among
participants in the sector or cooperative through private contractual agreements. The
cooperatives manage these allocations to ensure that individual vessels and companies do not
harvest more than their agreed upon share of pollock. The cooperatives also facilitate transfers
of pollock among the cooperative members, enforce contract provisions, and participate in an
intercooperative agreement to reduce salmon prohibited species catch (PSC).
AFA fishing vessels harvest pollock using pelagic (mid-water) trawl gear, which consists of
large nets towed through the water by the vessel. At times, Chinook salmon and pollock occur in
the same locations in the Bering Sea. Consequently, Chinook salmon are incidentally caught in
the nets as pollock is harvested. This incidental catch is called bycatch and is also called PSC.
Chinook salmon are defined as a prohibited species because they are caught by a vessel issued a
Federal Fisheries Permit under § 679.4(b) while fishing for groundfish (pollock) in the Bering
Sea and Aleutian Islands Management Area (BSAI) or Gulf of Alaska.
In December 2009, the Council recommended that NMFS implement the Chinook Salmon
Economic Data Report (Chinook Salmon EDR) to evaluate the effectiveness of Chinook salmon
bycatch management measures for the Bering Sea pollock fishery that were implemented under
Amendment 91 to the BSAI FMP (5 FR 53026, August 30, 2010).
In addition to creation of the Chinook Salmon EDR (see OMB Control No. 0648-XXXX),
NMFS will revise this collection, and submit a change request for OMB Control No. 0648-0515
(eLandings Electronic Reporting System) to obtain additional data for the Chinook salmon
analysis. Questions concerning vessel movements on the fishing grounds to avoid salmon
bycatch are added in a temporary new information collection, to be merged later with OMB
Control No. 0648-0213. Questions on Chinook salmon and pollock allocations and transfers are
added to the Incentive Plan Agreement (IPA) Final Report (originally from OMB Control No.
0648-0608) and the AFA Cooperative Report in OMB Control No. 0648-0401.
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This action revises the existing collection of information in support of the associated rule, RIN
0648-BA80, and supports the new Chinook Salmon EDR Program managed under the AFA. In
addition, this action merges OMB Control No. 0648-0608 into this collection and changes the
title to "NMFS Alaska Region American Fisheries Act Reports."

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
Chinook salmon PSC management measures for the Bering Sea pollock fishery that were
previously implemented under Amendment 91 to the Fishery Management Plan for Groundfish
of the Bering Sea and Aleutian Islands Management Area.
The Chinook EDR Program will:
♦ Evaluate the effectiveness of the IPA incentives in times of high and low levels of salmon
PSC abundance, the upper limit to Chinook salmon PSC, and the performance standard in
terms of reducing salmon PSC.
♦ Determine where, when, and how pollock fishing and salmon PSC occur
♦ Provide data for NMFS to study and verify conclusions drawn by industry in the
IPA annual reports.
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.
Each year under Amendment 91, NMFS will allocate up to the 60,000 Chinook salmon PSC
limit to the mothership sector, catcher/processor sector, inshore cooperatives, and CDQ groups
that participate in an incentive plan agreement (IPA) and remain in compliance with the
performance standard. An IPA is a private contract that establishes incentives for participants to
reduce Chinook salmon PSC. For those Bering Sea pollock participants that form an approved
IPA, the allocations may be further sub-allocated to a sector, cooperative, or vessel owner and
may be transferred among sectors, cooperatives, and their members.
Creation of individual accountability is one of the cornerstones of the PSC reduction measures in
Amendment 91. However, the specific methods for creating individual accountability are left to
the sectors, cooperatives, western Alaska Community Development Quota (CDQ) groups and
IPAs. Annual IPA reports are required to include a comprehensive explanation of incentive
measures in effect in the previous year, an assessment of how incentive measures affected
individual vessels, and an evaluation of whether incentive measures were effective in achieving
salmon savings beyond levels that would have been achieved in absence of the measures. In
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general, these requirements result in descriptions of the IPA and the individual accountability
that arises under the IPA structure.
Each vessel will be allocated a share of the Chinook salmon PSC allocation in proportion to its
share of Bering Sea pollock; the responsibility for the actual allocations will be made by
cooperatives and IPAs. Therefore, NMFS may not have data on individual vessel salmon PSC
allowances unless the sectors, cooperatives, and IPAs provide this data to the agency. This
information could be documented in the annual IPA reports, including the formulas used to
distribute the Chinook salmon PSC allocations and the allocation assigned to each vessel. If the
members of an IPA are different than the members in an AFA inshore cooperative, mothership
sector level entity, or catcher/processor sector level entity, then NMFS would require all of the
data to be included in the AFA cooperative report.
The IPA reports, describing the distribution of individual PSC allowances will be the basis for
measuring performance of individual vessels for those sectors which have formed IPAs. From
this perspective, the IPA reports will be useful in determining the effectiveness of Amendment
91, assuming that the distribution of allowances is transparent.
The burden associated with the IPA and cooperative reports is difficult to predict, as the burden
will likely depend on the structure of the IPA or cooperative and the rules applicable to
distributions and transfers. A simple IPA structure that either directly limits or creates
disincentives for transfers may have little associated reporting burden. On the other hand, a
structure that either makes frequent distributions or favors transfers could have a substantial
associated burden. In considering this burden, it should be noted that a structure with substantial
disincentives for transfers of Chinook PSC allowances may reduce the reporting burden on IPAs,
but create an incentive for pollock quota transfers that would increase the cooperative reporting
burden.
With this action, NMFS would move some pollock data to the IPA Annual Report, formerly
requested in the AFA Cooperative Report to provide a single location for Chinook and pollock
data. This data would include initial allocation, sub-allocations, NMFS-approved Chinook
salmon PSC transfers, internal cooperative or sector-level entity Chinook PSC transfers, and
catch by season and year for each catcher vessel, catcher/processor, or mothership participating
in an IPA. NMFS would remove the requirement from the AFA cooperative report to report the
cooperative’s actual retained and discarded catch of pollock and Chinook PSC on an area-byarea and vessel-by-vessel basis.
a. Chinook Salmon Incentive Plan Agreement (IPA) Annual Report (from OMB Control
No. 0648-0608)
This action would revise the IPA Annual Report to include the sub-allocation of Chinook salmon
PSC and pollock to each participating vessel at the start of each fishing season and the number of
Chinook salmon PSC and amount of pollock (mt) caught at the end of a season. The IPA Annual
Report would also request information on transfers of Chinook salmon PSC regardless of
whether the transfers were “compensated” transfers. This action would require each IPA
representative to report additional sub-allocations or transfers of Chinook within a sector-level
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entity or between participants in two or more sector-level entities. This additional information
will increase the time to complete the IPA Annual Report from 8 hr to 40 hr.
The IPA representative (estimated cost $150/hr) must submit a written annual IPA Report to the
Council at 605 West 4th Avenue, Suite 306, Anchorage, AK 99501, and must be postmarked or
received by the Council no later than April 1 of each year following the year in which the IPA is
first effective. The Council will make the annual report available to the public.
Chinook Salmon IPA Annual Report
Incentive measures in effect in the previous year
How incentive measures affected individual vessels
How incentive measures affected salmon savings beyond current levels
IPA amendments approved by NMFS since the last annual report and the reasons for amendments
Sub-allocation to each participating vessel of the number of Chinook PSC and amount of pollock (mt)
at the start of each fishing season, and number of Chinook PSC and amount of pollock (mt) caught
at the end of each season (see also §679.61(f)(2)).
Inseason transfers among entities of Chinook salmon PSC or pollock among AFA cooperatives
Date of transfer
Name of transferor
Name of transferee
Number of Chinook salmon transferred
Amount of pollock (mt) transferred
Transfers among IPA vessels provide the following information
Date of transfer
Name of transferor
Name of transferee
Number of Chinook salmon transferred
Amount pollock (mt) transferred
Additional information on sub-allocations or transfers of Chinook salmon PSC or pollock transfers
(see also §679.61(f)(2)).

IPA annual report, Respondent
Estimated number of respondents
Total annual responses
Response per respondent = 1
Total burden hours
Time per response = 40 hr
Total personnel cost = $150/hr
Total miscellaneous costs (6.96)
Photocopy (10 pg x .10 x 3 = 3)
Postage ($1.32 x 3 = 3.96)

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3
120 hr
$18,000
$7

Agency cost is estimated to be $35,000 associated with use of IPA and cooperative reports to
collect transfer data. Individual reporting on compensated transfers that were administered
through intermediaries (e.g., IPAs or cooperatives) will need to be integrated with the IPA and
cooperative reports to make full use of the data. The extent of these costs will depend on the
number of compensated transactions and the IPA and cooperative structures adopted by industry.
Structures that limit the number of transfers and simplify the transfer structure would reduce
agency administrative costs.

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IPA annual report, Federal Government
Total annual responses
Total burden hours = 40
Total personnel cost = 75
Total miscellaneous cost
One-time data integration procedure

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120
$9,000
$35,000

b. AFA cooperative annual report
NMFS requires an annual AFA cooperative report to describe the fishing activities of each AFA
cooperative through December 1 of each year. This report must be submitted and postmarked by
April 1 of the following year or received by a private courier service by the submission deadline.
Each AFA fishery cooperative must submit the cooperative report to the Council at 605 West 4th
Avenue, Suite 306, Anchorage, AK 99501. The Council posts the reports on its website at
http://www.alaskafisheries.noaa.gov/npfmc/default.htm.
The fishing industry accounting for the AFA cooperative report involves the services of a
representative, Sea State, Inc., a company that provides catch accounting services (estimated at
$150/hr). Sea State works on a data release agreement between the industry and NMFS. Sea
State, an independent contractor, receives data from the NMFS Observer Program via satellite
from participating vessels.
Sea State regularly provides catch reports which include cumulative fleet-wide and vessel-level
catch data as well as a tow-by-tow summary for each vessel. The Sea State program works as
follows:
♦ Observers sample hauls and estimate catch and bycatch;
♦ Each vessel electronically transmits its observer data to Sea State which checks the data
and performs statistical extrapolations to factor in any hauls that were not sampled;
♦ Position-specific data for each vessel is used to create a chart of vessel-specific bycatch
rates that is faxed to participating vessels within 24 hours; and
♦ Vessels move away from high bycatch areas and exert peer pressure on any vessel that is
reluctant to move.
AFA cooperative reports are one of the only sources of disaggregated catch data that are
available to the public. In addition, the AFA cooperative reports are the only sources that can be
used by analysts to report comprehensive data on individual AFA vessel harvests without
violating NMFS and State of Alaska Department of Fish and Game (ADF&G) data
confidentiality rules.
With this action, the annual cooperative report does not request any information about pollock or
Chinook salmon PSC. However, each AFA cooperative collects and summarizes information on
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its allocated target species all through the year and provides it to Sea State to perform parallel
accounting of “sideboard” species for each cooperative. Sideboard species are non-pollock
groundfish species allocated annually as incidental catch to AFA and other fishery cooperatives.
Sea State summarizes each cooperative’s target species and sideboard information and maintains
analyses of cooperatives compared with each other in order to keep each and all cooperatives
from overfishing.
Cooperative annual report
Allocated catch of sideboard species
Any sub-allocations of sideboard species made to individual vessels on a vessel-by-vessel basis
Cooperative's actual retained and discarded catch of sideboard species and PSC, except for Chinook salmon
PSC, on an area-by-area and vessel-by-vessel basis
Description of monitoring method for fisheries in which cooperative vessels participate
Description of any actions taken by the cooperative in response to any vessels that exceed their allowed catch
and bycatch in pollock and all sideboard fisheries
Total weight of pollock landed outside State of Alaska waters on a vessel-by-vessel basis

Cooperative annual report, Respondent
Estimated number of respondents
Total annual responses
Annual responses per respondent = 1
Total burden hours
Estimated hours per response = 8
Total personnel cost
Personnel cost $150/hr
Total miscellaneous costs (17.82)
Postage cost (1.32 x 11 = 14.52)
Photocopy cost (11 x 6 pg x 0.05 = 3.30)
Cooperative annual report, Federal Government
Total annual responses
Total burden hours
Estimated hours per response = 3 hr
Total personnel cost
Personnel cost $25/hr
Total miscellaneous cost

11
11
88 hr
$13,200
$18

11
33 hr
$825
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. The National Oceanic and Atmosphere Administration
(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 Question 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.

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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.
No forms exist for the IPA Report, the AFA Cooperative Report, or the ICA; these reports may
be submitted to the Council by mail or fax. A cooperative catch report may be submitted as an
attachment to an e-mail or by fax. Information describing agent for service of process may be
submitted by e-mail. An application for an Incentive Plan Agreement (IPA) and List of IPA
Participants may be submitted online at http://www.alaskafisheries.noaa.gov.
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 proposed action applies only to those entities that participate in the directed pollock trawl
fishery in the Bering Sea. The only small entities that are directly regulated by this action are the
six western Alaska CDQ organizations. A significant increase in burden is estimated for the IPA
annual report -- from 16 hr annually to 120 hr annually. An increased estimate for personnel cost
is also due to figuring in the cost of the contractor (representative) at $150/hr. These increases
are the result of adjusting these figures to the cost of an independent contractor or representative.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
This information collection is one of four components of the Chinook Salmon Economic Data
Program developed to assess the effect that the BSAI Amendment 91 has on Chinook salmon
prohibited species catch (PSC) in the pollock fishery.
The IPA Report and AFA Cooperative Report provide information on the number and
characteristics of Chinook PSC transfers, in addition to other information. Without this data,
NMFS will not be able to tell how vessels differ from each other in terms of efficient use of
Chinook PSC or of the costs of avoiding Chinook PSC. Without this data, it will not be possible
to determine if the tradable Chinook PSC is working or if it is not working, how to fix it.
If the information were not collected, NMFS would be unable to implement the socioeconomic
goals and objectives of the AFA, the Magnuson-Stevens Act, and the FMP.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
No special circumstances exist.
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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.
NMFS Alaska Region will submit a proposed rule (RIN 0648-BA80) coincident with this
submission, requesting comments from the public.
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.
None of the information in the IPA Report or the AFA Cooperative Report submitted under this
collection of information, including individual vessel information, contains sensitive personally
identifiable information or confidential business information. All of the information in the IPA
Report and the AFA Cooperative Report will be posted on the NMFS Alaska Region webpage
and made available to the public.
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.
12. Provide an estimate in hours of the burden of the collection of information.
Including program changes due to Proposed Rule RIN 0648-BA80 and adjustments due to
merging OMB Control No. 0648-0608 into this information collection as part of this revision:
Estimated total respondents: 11. Estimated total responses: 164, increased from 155. Estimated
total burden: 425 hr, increased from 101 hr. Estimated total personnel costs: $ 61,625,
increased from $ 2,525.
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).
Estimated total miscellaneous costs: $56, increased from $38.
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14. Provide estimates of annualized cost to the Federal government.
Estimated total burden: 216 hr, increased from 19 hr. Estimated total personnel cost: $13,900,
increased from $ 4,275. Estimated total one-time cost: $35,000.
15. Explain the reasons for any program changes or adjustments.
Adjustments in this collection are due to merging OMB Control No. 0648-0608 into this
collection. The merger adds a net increase of 8 responses, 220 hours, $31,300 personnel costs,
and $14 miscellaneous costs.
Non-chinook bycatch reduction intercooperative agreement (ICA) [added by 608]
An increase of 1 response, 1 instead of 0
An increase of 40 hr burden, 40 hr instead of 0 hr
An increase of $6,000 personnel costs, $6,000 instead of $0
An increase of $2 miscellaneous costs, $2 instead of 0
Non-chinook ICA annual report [added by 608]
An increase of 1 response, 1 instead of 0
An increase of 4 hr burden, 4 hr instead of 0 hr
An increase of $100 personnel costs, $100 instead of $0
An increase of $2 miscellaneous costs, $2 instead of 0
Application for an Incentive Plan Agreement (IPA) and List of IPA Participants [added by 608]
An increase of 4 responses, 4 instead of 0
An increase of 160 hr burden, 160 hr instead of 0
An increase of $24,000 personnel costs, $24,000 instead of 0
An increase of $7 miscellaneous costs, $7 instead of 0
Chinook Salmon IPA Annual Report [added by 608]
an increase of 2 responses, 2 instead of 0
an increase of 16 hr burden, 16 hr instead of 0
an increase of $1,200 personnel costs, $1,200 instead of 0
an increase of $5 miscellaneous costs, $5 instead of 0
Program changes in this collection are due to Proposed Rule 0648-BA80, regarding the Chinook
Salmon Economic Data Reports.
Chinook Salmon IPA Annual Report [revised by EDR]
an increase of 1 respondent and response, 3 instead of 2
an increase of 104 hr burden, 120 hr instead of 16 hr
an increase of $16,800 personnel costs, $18,000 instead of $1,200
an increase of $2 miscellaneous costs, $7 instead of $5
AFA Cooperative Annual Report [revised by EDR]
an increase of $11,000 personnel costs, $13,200 instead of $2,200
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16. For collections whose results will be published, outline the plans for tabulation and
publication.
The IPA Annual Reports and AFA Cooperative Report are posted on the NMFS Alaska Region
website at http://www.alaskafisheries.noaa.gov/sustainablefisheries/default.htm.
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.
Not applicable
18. Explain each exception to the certification statement.
Not applicable

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods. However, the information gathered in this
collection will be used in the analyses for the Chinook Salmon EDR Program (see
OMB Control No. 0648-XXXX).

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