0401 ss revised 012815_clean

SUPPORTING STATEMENT

ALASKA AMERICAN FISHERIES ACT (AFA) REPORTS

OMB CONTROL NO. 0648-0401

This request is for revision and extension of an existing information collection. Two information collections have been added, and one removed.

BACKGROUND

National Marine Fisheries Service (NMFS) manages the groundfish fisheries in the Exclusive Economic Zone (EEZ) off Alaska. The North Pacific Fishery Management Council prepared the Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area (FMP 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 under regulations at 50 CFR part 679.

Bering Sea pollock fishery is managed under the American Fisheries Act (AFA). This information collection describes management of the incidental catch of Chinook salmon in the Bering Sea pollock fishery. The four AFA sectors are: Catcher/processor, mothership, Inshore processors, and Western Alaska Community Development Quota Program (CDQ).

INTRODUCTION

Each year, NMFS makes allocations of the applicable Bering Sea Chinook salmon prohibited species catch (PSC) limit to the following four AFA sectors:

AFA Sector	Eligible participants are
Catcher/processor	AFA catcher/processors and AFA catcher vessels delivering to AFA catcher/ processors, all of which are permitted under § 679.4(l)(2) and § 679.4(l)(3)(i)(A), respectively.
Mothership	AFA catcher vessels harvesting pollock for processing by AFA motherships, all of which are permitted under § 679.4(l)(3)(i)(B) and § 679.4(l)(4), respectively.
Inshore	AFA catcher vessels harvesting pollock for processing by AFA inshore processors, all of which are permitted under § 679.4(l)(3)(i)(C).
CDQ Program	The six CDQ groups authorized under section 305(i)(1)(D) of the Magnuson-Stevens Act to participate in the CDQ Program.

JUSTIFICATION

1. Explain the circumstances that make the collection-of-information necessary.

This information collection describes the implementing regulations for the American Fisheries Act (AFA). The AFA was signed into law in October 1998. The purpose of the AFA was to tighten U.S. ownership standards for U.S. fishing vessels under the Anti-reflagging Act, and to provide the BSAI pollock fleet the opportunity to conduct their fishery in a more rational manner while protecting non-AFA participants in the other fisheries.

The AFA eliminated the race for pollock through the establishment of cooperatives with specific provisions for their allocations, structure, and participation by catcher vessels and processing plants, as well as annual reporting requirements and excessive share limits. In response to a directive in the AFA, the Council added measures to protect other fisheries from adverse effects arising from the exclusive pollock allocation. Cooperative fishing began under the AFA program in 1999.

The effects of AFA on the pollock industry included the following: Capacity was reduced, efficiency was increased, regulatory bycatch was reduced, a higher portion of the fish was utilized, and higher valued products were produced.

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 applicable NOAA Information Quality Guidelines.

This information collection contains the elements listed in the following table.

Name of Element	Site Location 50 CFR
Chinook Salmon Incentive Plan Agreement (IPA) and List of IPA Participants	679.21(f)(12)
Chinook Salmon IPA annual report	679.21(f)(13)
Non-Chinook Salmon Intercooperative Agreement (ICA) & renewal letter	679.21(g)(1)
Non-Chinook Salmon ICA annual report	679.21(g)(4)
Annual Cooperative catch report	679.5(o)
Annual AFA Cooperative report	679.61(f)
Annual AFA Cooperative contract	679.61(d)
AFA Catcher Vessel Intercooperative Agreement	Not in regulations. Voluntary submittal requested by Council
AFA Catcher Vessel Intercooperative Report

a. Application for Chinook Salmon Incentive Plan Agreement (IPA) and List of IPA Participants [Changed number of respondents]

Parties to an IPA (catcher/processor, mothership, Inshore, and CDQ) must collectively represent at least 9 percent of the Bering Sea pollock quota. NMFS requires an IPA for management of Chinook salmon. An IPA is a private contract among vessel owners or CDQ groups that establishes incentives for participants to reduce Chinook salmon bycatch.

The IPAs are intended to allow flexibility to industry to develop innovative incentives to constrain Chinook PSC. Participation in an IPA is voluntary. Industry members who participate in an approved IPA are either provided exemptions to certain other salmon bycatch management measures or are provided access to a higher salmon PSC limit.

Day-to-day management of inter-cooperative matters related to the performance of the Agreement is performed by United Catcher Boats Association. Data gathering, analysis, fleet monitoring and reporting services necessary to implement the Chinook salmon conservation area closure is performed by Sea State.

Deadline: For a new IPA, the application and the IPA must be received by NMFS by October 1 prior to the year in which the IPA is proposed to be effective. Once approved, an IPA is effective until December 31 of the first year in which it is effective or until December 31 of the year in which the IPA representative notifies NMFS in writing that the IPA is no longer in effect, whichever is later. An IPA may not expire mid-year.

To amend an approved IPA, with no change in the IPA participants, the IPA representative must submit an application and an amended IPA to NMFS. No party may join or leave an IPA once it is approved without changing the list of IPA participants. To change the list of IPA participants, this application must be received by NMFS by December 1. The amended IPA is effective upon written notification of approval by NMFS.

The application for an IPA or an amendment to an IPA or list of participants must be submitted by mail due to original signatures.

The current, approved Chinook salmon bycatch reduction incentive plan agreements (IPAs) may be viewed at

http://www.alaskafisheries.noaa.gov/sustainablefisheries/bycatch/salmon/chinook/ipa/ipas.htm

Application for an Incentive Plan Agreement (IPA) and List of IPA Participants

Type of application

Block A -- IPA Information

Name of IPA

IPA number (issued by NMFS)

Block B -- IPA contact information

Name of IPA representative and name of Agent for service of process (if different from representative)

Permanent and temporary (if applicable) business mailing address

Business telephone number, business fax number, and business e-mail address

Block C -- Vessel identification

Name of vessel

ADF&G vessel registration number

Federal fisheries permit number

Block D – Affirmation

Block E – Certification

Printed name and signature of representative and date signed

Attachment – Incentive Plan Agreement

The number of respondents is changed from 2 to 1, because no other IPAs or amendments to IPAs are expected. Personnel cost changed due to public comment, from $150/hr to $165/hr.

Chinook Salmon IPA, Respondent
Estimated number of respondents Total annual responses Response per respondent = 1 Total burden hours Time per response = 40 hr Total personnel cost = $165/hr Total miscellaneous cost (1.40) Photocopy (10 pp x .05 = 0.50) Postage (1 x 0.90 = 0.90)	1 1 40 hr $6,600 $1

Chinook Salmon IPA, Federal Government
Total annual responses Total burden hours Time per response = 10 hr Total personnel cost = $75/hr Total miscellaneous cost	1 10 hr $750 0

b. Chinook Salmon IPA annual report [Changed number of respondents]

The IPA representative must submit an annual IPA report to the Council. The IPA report is the primary tool through which the Council evaluates the effectiveness of the IPA concept in reducing Chinook salmon bycatch in the Bering Sea pollock fishery. Information gathered through the annual reports is necessary for the Council to evaluate the salmon bycatch management measures and to provide the public with information about how the programs operate and with information about bycatch reduction under these programs.

Deadline: The IPA Report must be submitted so that it is postmarked or received by the Council by April 1 of the following year to:

North Pacific Fishery Management Council

605 West 4th Avenue, Suite 306

Anchorage, AK 99501

The IPA reports are posted on the NMFS Alaska Region website at:

Inshore (http://www.alaskafisheries.noaa.gov/sustainablefisheries/afa/coopreports/2013/inshoreipa.pdf

Mothership

http://www.alaskafisheries.noaa.gov/sustainablefisheries/afa/coopreports/2013/mothershipipa.pdf

Catcher/processor

http://www.alaskafisheries.noaa.gov/sustainablefisheries/afa/coopreports/2013/cpipa.pdf

Chinook Salmon IPA Annual Report

Incentive measures in effect in the previous year.

How incentive measures affected individual vessels

How incentives 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

Number of Chinook salmon PSC and amount of pollock (mt) at the start of each fishing season

Number of Chinook salmon PSC and amount of pollock (mt) caught at the end of each season

In-season 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 PSC transferred

Amount of pollock (mt) transferred

Transfers among IPA vessels, provide:

Date of transfer;

Name of transferor;

Name of transferee;

Number of Chinook salmon PSC transferred

Amount pollock (mt) transferred.

Based on public comment, changed total burden hours from 8 hr to 30 hr and personnel cost from $75/hr to $165/hr.

Chinook IPA annual report, Respondent
Estimated number of respondents Total annual responses Response per respondent = 1 Total burden hours Time per response = 30 hr Total personnel cost ($165/hr) Total miscellaneous costs (14.35) Photocopy (10 pp x .05 x 2 = 1) Fax ($6 x 2 = 12) Postage (1 x 1.35 = 1.35)	3 3 90 hr $14,850 $14

Chinook IPA annual report, Federal Government
Total annual responses Total burden hours = 1 Total personnel cost ($37/hr) Total miscellaneous cost	3 3 hr $75 0

c. Non-Chinook Salmon Inter-cooperative Agreement (ICA) (previously known as Salmon bycatch reduction ICA)

The Non-Chinook Salmon ICA was created to enable the pollock fleet to utilize its internal cooperative structure to coordinate the pollock fishery in a manner that reduces incidental catch rates of salmon. Participation in the ICA is voluntary. Industry members who participate in an approved ICA are either provided exemptions to certain other salmon bycatch management measures or are provided access to a higher salmon PSC limit. For any ICA participant to be exempt from closure of the Chum Salmon Savings Area, an ICA must be filed in compliance with the requirements and approved by NMFS. The ICA is a private, contractual, salmon bycatch management agreement among all of the AFA pollock cooperatives and the CDQ groups.

The ICA includes provisions to retain the services of a private contractor to collect and analyze bycatch data and report salmon bycatch information to the ICA parties.

An amendment to the ICA requires submission of an amended ICA signed by all parties and approved by NMFS. Exemptions from salmon savings area closures will expire upon termination of the initial ICA, expiration of the initial ICA, or if superseded by approved amended ICA.

A representative must be appointed by the parties; this ICA Representative will file a signed copy of the initial ICA and any amended ICA to

Regional Administrator NMFS Alaska Region

P.O. Box 21668

Juneau, AK 99802

Or by courier delivery to

Regional Administrator NMFS Alaska Region

709 West 9th St., Suite 401

Juneau, AK 99801

Deadline: The initial ICA was due to NMFS by December 1, 2007 for the 2008 fishing year. After an ICA is initially filed with NMFS, the ICA representative may submit revisions to NMFS through an ICA renewal letter, also referred to as a revised ICA. The revised ICA must be postmarked or received by NMFS by December 1 of the year before the year in which the ICA is proposed to be effective. Once NMFS approves a non-Chinook ICA, it is not required to be resubmitted unless components of the ICA covered by NMFS regulations are amended.

The renewal letter must provide notice that the previously filed ICA will remain in effect for the subsequent fishing year. The renewal letter also must detail any material modifications to the ICA that have been made since the last filing including, but not limited to, any changes to vessels participating in the ICA.

On October 1, 2010, NMFS received three proposed Chinook salmon bycatch reduction ICAs. On November 5, 2010, all three incentive plan agreements were approved. Exemptions from closure of the Chum Salmon Savings Area will expire upon termination of the initial ICA, expiration of the initial ICA, or if superseded by a NMFS-approved amended ICA

The current, approved Non-Chinook salmon bycatch reduction incentive plan agreements (ICAs) may be viewed at

http://www.alaskafisheries.noaa.gov/sustainablefisheries/bycatch/salmon/non_chinook/2010_non_chinook_coop_agreement.pdf

Non-Chinook Salmon Inter-cooperative Agreement (ICA)

Participants

Names of the AFA cooperatives and CDQ groups

Name, business mailing address, business telephone number, business fax number, and business email address of the ICA representative.

Name of entity retained to facilitate vessel PSC avoidance behavior and information sharing.

Name of at least one third party group. Third party groups include any organizations representing western Alaskans who depend on non-Chinook salmon and have an interest in non-Chinook salmon PSC reduction but do not directly fish in a groundfish fishery.

Vessel information

Names, Federal fisheries permit numbers, and USCG documentation numbers of vessels subject to the ICA

Provisions that dictate on-Chinook salmon PSC avoidance behaviors for vessel operators

Initial base rate

Inseason adjustments to the non-Chinook base rate calculation

ICA chum salmon savings area notices.

Fishing restrictions for vessels assigned to tiers 1, 2, and 3

Cooperative tier assignments.

PSC rates for Chinook salmon

Internal monitoring and enforcement

Provisions allowing any party of the ICA to bring civil suit or initiate a binding arbitration action against

another for breach of the ICA.

Minimum annual uniform assessments for any violation of savings area closures

$10,000 for the first offense, $15,000 for the second offense, and $20,000 for each offense thereafter.

Annual compliance audit

Must be conducted by a non-party entity

Each party must have an opportunity to participate in selecting the non-party entity.

If the non-party entity hired to conduct a compliance audit discovers a previously undiscovered failure to comply with the terms of the ICA, the non-party entity must notify all parties to the ICA and must simultaneously distribute to all ICA parties the information used to determine the failure

Must include such notice(s) in the compliance report.

Data dissemination

If the entity retained to facilitate vessel PSC avoidance behavior and information sharing determines that an apparent violation of an ICA chum salmon savings area closure has occurred, that entity must promptly notify the Board of Directors of the cooperative to which the vessel involved belongs. If this Board of Directors fails to assess a minimum uniform assessment within 180 days of receiving the notice, the information used by the entity to determine if an apparent violation was committed must be disseminated to all parties to the ICA.

The Non-Chinook ICA full burden was reduced from 40 hours to 1 hour, as no new ICs are now being added, only revisions made.

Non-Chinook ICA, Respondent
Estimated number of respondents AFA cooperatives CDQ groups Total annual responses Estimated responses per respondent = 1 Total burden hours Estimated hours per response = 1 hr Total personnel cost ($150/hr) Total miscellaneous costs (1.85) Photocopy (10 pp x .05 x 1= 0.50) Postage (1.35 x 1 = 1.35)	1 1 1 hr $150 $2

Non-Chinook ICA, Federal Government
Total annual responses Estimated responses per respondent = 1 Total burden hours Estimated hours per response = 1 Total personnel cost ($75/hr) Total miscellaneous costs	1 1 hr $75 0

d. Non-Chinook Salmon ICA annual report [Changed to include compliance audit report]

The non-Chinook salmon ICA annual report provides information about the performance of the non-Chinook salmon ICA as a whole. This information is necessary for the Council to evaluate the salmon bycatch management measures and to provide the public with information about how the programs operate and information about bycatch reduction under these programs. The requirement for a compliance audit report previously existed in the regulations but was inadvertently omitted from this analysis.

Deadline: The ICA representative must submit the ICA annual report so that it is postmarked or received by the Council by April 1 of each year.

The current, approved Non-Chinook salmon ICA annual report may be viewed at

http://www.npfmc.org/salmon-bycatch-overview/bering-sea-chum-salmon-bycatch/

ICA annual report

Estimated number of non-Chinook salmon avoided as demonstrated by movement of fishing effort away from Chum Salmon Savings Areas

Results of the compliance audit required at § 679.21(g)(2)(v)

Non-Chinook ICA annual report, Respondent
Estimated number of respondents Total annual responses Estimated responses per respondent = 1 Total burden hours Estimated hours per response = 8 Total personnel cost ($75/hr) Total miscellaneous costs (1.85) Photocopy (10 pp x .05 x 1 = 0.50) Postage (1.35 x 1 = 1.35)	1 1 8 hr $600 $2

Non-Chinook ICA final report, Federal Government
Total annual responses Total burden hours Estimated hours per response = 1 hr Total personnel cost ($37/hr) Total miscellaneous cost	1 1 $37 0

e. AFA Annual Cooperative Report [Changed number of respondents]

The table below lists the inshore catcher vessel cooperatives and the offshore catcher vessel cooperatives.

	No. of catcher vessels	No. of catcher/Processors
Inshore Catcher Vessel Cooperatives
Akutan Catcher Vessel Assoc. Northern Victor Fleet Cooperative Peter Pan Fleet Cooperative Unalaska Fleet Cooperative UniSea Fleet Cooperative Westward Fleet Cooperative	37 15 9 11 16 10
Offshore Catcher Vessel Cooperatives
Pollock Conservation Cooperative High Seas Catchers Cooperative		19 7

Deadline: Each AFA cooperative must submit an AFA annual report on fishing activity by April 1 of each year. Annual reports must be postmarked by the submission deadline or received by a private courier service by the submission deadline. The AFA annual cooperative report must be sent to:

North Pacific Fishery Management Council

605 West 4th Avenue, Suite 306

Anchorage, AK 99501

The AFA Annual cooperative reports are posted on the NMFS website at

http://alaskafisheries.noaa.gov/sustainablefisheries/afa/afa_sf.htm

AFA Annual Cooperative Report

Cooperative’s allocated catch of pollock and sideboard species

Any sub-allocations of pollock and sideboard species made by the cooperative to individual vessels on vessel-by-vessel basis

Cooperative’s actual retained and discarded catch of pollock, sideboard species, and PSC

on an area-by-area basis

on a vessel-by-vessel basis

Method used to monitor fisheries in which cooperative vessels participated

Actions taken in response to any vessels that exceed their allowed catch and bycatch

in pollock and all sideboard fisheries

Total weight of pollock landed outside the State of Alaska on a vessel-by-vessel basis.

Number of salmon taken by species and season

List each vessel's number of appearances on the weekly “dirty 20” lists for non-Chinook salmon

Number of respondents is changed from 11 to 8 to reflect current numbers.

AFA Coop Annual report, Respondent
Estimated number of respondents Total annual responses Response per respondent = 1 Total burden hours Time per response = 8 hr Total personnel cost ($75/hr) Total miscellaneous costs (24.10) Photocopy (10 pp x .05 x 8 = 4) Fax ($6 x 2 = 12) Postage (1.35 x 6 = 8.10)	8 8 64 hr $4,800 $24

AFA Annual report, Federal Government
Total annual responses Total burden hours = 1 Total personnel cost ($37/hr) Total miscellaneous cost	8 8 hr $296 0

f. AFA Annual cooperative catch report

The authorized representative of each AFA cooperative annually must submit to the Regional Administrator a catcher vessel Cooperative Catch Report detailing each delivery of pollock harvested under the allocation made to that cooperative. The owners of the member catcher vessels in the cooperative are jointly responsible for compliance.

The cooperative catch report may be submitted as an electronic data file in a format approved by NMFS or by Fax. Currently, these reports are sent to NMFS by email and are used by NMFS as an audit check.

Deadline: The cooperative catch report must be received by the Regional Administrator by 1200 hours, A.l.t. 1 week after the date of completion of delivery.

Annual Cooperative catch report

Cooperative account number

Catcher vessel ADF&G vessel registration number

Inshore processor Federal processor permit number

Delivery date

Amount of pollock (in lb) delivered plus weight of at-sea pollock discards

ADF&G fish ticket number.

Cooperative catch report, Respondent
Estimated number of respondents Total annual responses Response per respondent = 1 Total burden hours Time per response = 8 hr Total personnel cost ($75/hr) Total miscellaneous costs (24.10) Photocopy (10 pp x .05 x 8 = 4) Fax ($6 x 2 = 12) Postage (1.35 x 6 = 8.10)	8 8 64 hr $4,800 $24

Cooperative catch report, Federal Government
Total annual responses Total burden hours = 1 Total personnel cost ($37/hr) Total miscellaneous cost	8 8 hr $296 0

g. AFA Cooperative Contract

Any fishery cooperative formed under section 1 of the Fisherman’s Collective Marketing Act 1934 (15 U.S.C. 521) for the purpose of cooperatively managing directed fishing for Bering Sea subarea pollock must comply with the provisions of this section. The owners and operators of all the member vessels that are signatories to a fishery cooperative are jointly and severally responsible for compliance with the requirements of this section.

Each AFA cooperative must file on an annual basis, with the Council and NMFS, a signed copy of its fishery cooperative contract, and any material modifications to any such contract, together with a copy of a letter from a party to the contract requesting a business review letter on the fishery cooperative from the Department of Justice and any response to such request. The Council and NMFS will make this information available to the public upon request.

If the cooperative contract was previously filed with NMFS and the Council, a renewal letter may be submitted to NMFS and the Council by the filing deadline in lieu of the cooperative contract and business review letter. The renewal letter must provide notice that the previously filed cooperative contract will remain in effect for the subsequent fishing year. The renewal letter also must detail any material modifications to the cooperative contract that have been made since the last filing including, but not limited to, any changes in cooperative membership.

The cooperative contract or renewal letter and the required supporting materials may be submitted to:

North Pacific Fishery Management Council,

605 West 4th Ave, Suite 306,

Anchorage, AK 99501;

and

NMFS Alaska Region

P.O. Box 21668

Juneau, AK 99802

709 West 9th St., Suite 401

Juneau, AK 99801

Deadline: The contract or renewal letter and supporting materials must be received by NMFS and by the Council at least 30 days prior to the start of any fishing activity conducted under the terms of the contract. In addition, an inshore cooperative that is also applying for an allocation of Bering Sea subarea pollock under § 679.62 must file its contract, any amendments hereto, and supporting materials no later than December 1 of the year prior to the year in which fishing under the contract will occur.

AFA Cooperative Contract

Requirements for all fishery cooperatives.

List parties to the contract.

List all vessels and processors that will harvest and process pollock harvested under the cooperative.

Specify the amount or percentage of pollock allocated to each party to the contract.

Specify a designated representative and agent for service of process.

Include a contract clause under which the parties to the contract agree to make payments to the State of Alaska for any pollock harvested in the directed pollock fishery that are not landed in the State of Alaska, in amounts which would otherwise accrue had the pollock been landed in the State of Alaska subject to any landing taxes established under Alaska law. Failure to include such a contract clause or for such amounts to be paid will result in a revocation of the authority to form fishery cooperatives under section 1 of the Act of June 25, 1934 (15 U.S.C. 521 et seq.).

Additional required elements in all fishery cooperatives that include AFA catcher vessels

Adequate provisions to prevent each non-exempt member catcher vessel from exceeding an individual vessel sideboard limit for each BSAI or GOA sideboard species or species group that is issued to the vessel by the cooperative in accordance with the following formula:

The aggregate individual vessel sideboard limits issued to all member vessels in a cooperative must not exceed the aggregate contributions of each member vessel towards the overall groundfish sideboard amount as calculated by NMFS under § 679.64(b) and as announced to the cooperative by the Regional Administrator, or

In the case of two or more cooperatives that have entered into an inter-cooperative agreement, the aggregate individual vessel sideboard limits issued to all member vessels subject to the inter-cooperative agreement must not exceed the aggregate contributions of each member vessel towards the overall groundfish sideboard amount as calculated by NMFS under § 679.64(b) and as announced by the Regional Administrator.

Cooperative contract, Respondent
Estimated number of respondents Total annual responses Response per respondent = 1 Total burden hours Time per response = 8 hr Total personnel cost ($75/hr) Total miscellaneous costs (24.10) Photocopy (10 pp x .05 x 8 = 4) Fax ($6 x 2 = 12) Postage (1.35 x 6 = 8.10)	8 8 64 hr $4,800 $24

Cooperative contract, Federal Government
Total annual responses Total burden hours = 1 Total personnel cost ($37/hr) Total miscellaneous cost	8 8 hr $296 0

h. AFA Catcher Vessel Intercooperative Agreement [New – ADDED by Council as Voluntary data]

The AFA catcher vessel cooperatives rewrote portions of the Intercooperative Agreement for 2013 to accommodate the Council’s request for additional information. The changes focused on improving the Bering Sea cod fishery in terms of improved catch efficiency and the reduction of halibut bycatch. To improve catch efficiency the allocation timing mechanisms for halibut PSC were revised in a manner intended to maximize cod harvest timing at the peak CPUE time of the season.

Catcher vessel Intercooperative Agreement

Allocation, monitoring, and compliance of the BSAI and GOA sideboard limits and PSC caps among the AFA catcher vessel cooperative members

Allocation, monitoring, and compliance of BSAI pollock harvest inside the Steller sea lion conservation area

Establishment of penalties for coops that exceed pollock and sideboard allocations

Provides for harvest of BSAI pacific cod by the “under 1700 mt” exempt vessels while complying with PSC limits

Establishment and monitoring of sideboard species transfers between cooperatives

Promotes compliance of the Council’s recommended sideboard measures and PSC limits while allowing for the maximum harvest of AFA pollock and sideboard allocations

Promotes reduction of PSC in the Bering Sea pollock fishery

Catcher vessel Intercoop Agreement, 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 cost Photocopy (10 pp x .05 = 0.50) Online (0.05 x 1 = 0.05)	1 1 40 hr $6,000 $1

Catcher vessel Intercoop Agreement, Federal Government
Total annual responses Total burden hours Time per response = 10 hr Total personnel cost = $75 Total miscellaneous cost	1 10 hr $750 0

i. Annual AFA Catcher Vessel Intercooperative Report [New – ADDED by Council as Voluntary data]

In response to the Council’s request for additional voluntary information in 2013, the AFA Catcher Vessel Intercooperative Report was changed. The report is a summary of the eight active catcher vessel cooperative reports required by the AFA regulations. While the individual coop reports track the annual activities of each cooperative at the vessel level, a summary of AFA catcher vessel harvests in the Bering Sea and Gulf of Alaska fisheries is useful as NMFS allocates the catcher vessel sideboard caps and PSC caps and triggers in the aggregate, not by individual cooperatives.

The Catcher Vessel Intercooperative Report provides the Council, and the public, with a simple means of evaluating the AFA catcher vessel fleets’ aggregate fishing performance under the AFA regulations. Additionally, this report provides voluntary information requested by the Council beyond the required regulatory elements of the individual coop reports to provide a broader understanding of catcher vessel cooperative activities.

The AFA Catcher Vessel Intercooperative Report may be viewed at http://www.alaskafisheries.noaa.gov/sustainablefisheries/afa/coopreports/2013/cvintercoop.pdf.

Deadline: April 1 of each year.

AFA Catcher Vessel Intercooperative Report

Bering Sea Pollock Fishery

Allocations and Harvest

Salmon Bycatch Reduction Measures

Sideboard Fishery Management

Groundfish Sideboards

PSC Catch

AFA Annual Catcher vessel Intercoop report, Respondent
Estimated number of respondents Total annual responses Response per respondent = 1 Total burden hours Time per response = 8 hr Total personnel cost ($75/hr) Total miscellaneous costs (0.55) Photocopy (10 pp x .05 x 1 = 0.50) Online (0.05 x 1 = 0.05)	1 1 40 hr $3,000 $1

AFA Annual catcher vessel Intercoop report, Federal Government
Total annual responses Total burden hours = 8 Total personnel cost ($37/hr) Total miscellaneous cost	1 8 hr $296 0

j. Agent for Service of Process [Removed because is not a recordkeeping requirement]

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. 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.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology.

The “fillable” form for the IPA application is available at the NMFS Alaska Region Home Page at alaskafisheries.noaa.gov for downloading, completing and printing. Other submissions consist of multiple documents. Documents may be sent by U.S. mail, fax, or as an attachment to an email, except that the ICA and the plan attached to the IPA application require signatures, and therefore these two sets of documents must be sent by mail.

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 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, and the impact is not significant.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

The purpose of the information collection is to minimize Chinook salmon PSC to the extent practicable while achieving optimum yield from the pollock fishery. The information is necessary to ensure long-term conservation and abundance of salmon, maintain a healthy marine ecosystem, provide maximum benefit to fishermen and communities that depend on salmon and pollock, and comply with the Magnuson–Stevens Act. If the information were not collected annually, NMFS would be unable to achieve these goals.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

No special circumstances exist.

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 June 19, 2014 (79 FR 35150) solicited public comments. No comments were received.

In addition, NMFS AKR created and submitted a questionnaire to request comments from 14 randomly selected AFA participants. Two emails were returned as invalid. One response was received. The results of the survey are added to this analysis, shown below. The questionnaire is included as a supplementary document.

SURVEY SUMMARY

ALASKA AMERICAN FISHERIES ACT (AFA) REPORTS COLLECTION

November, 2014

Application for Chinook Salmon Incentive Plan Agreement (IPA) 1 response

and List of IPA Participants

1. Is the data requested easily available? Yes

2. Is this process easy to understand and to apply for? Yes

3. We estimate it takes 40 hours for your office personnel to complete this agreement and application. Is this time accurate and reasonable?

Comment

No. While 40 hours is a reasonable estimation of the person-hours to write an agreement and complete an application, it undercounts the total amount of time it takes for all members to the agreement to come to terms as to what the agreement encompasses.

Response

According to OMB guidelines, public reporting burden includes the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed , and completing and reviewing the collection of information. It does not include gathering of persons to determine the terms of an agreement. NMFS recontacted the commenter for an estimate of gathering time, but received no response.

4. We estimate that personnel costs to complete and submit the agreement and application are $150/hour. Is this cost accurate and reasonable?

Comment

No. Cost of staff time to prepare written report estimated at $165/hr.

Response

AKR will change the PRA analysis from $150/hr to $165/hr.

5. Does someone other than your office personnel complete the agreement and application?

Comment

Yes. The Mothership Fleet Cooperative Entity does not have an office, and thus does not have office personnel.

Response

No response needed

6. We estimate that it costs $13 to submit by mail or fax and $1 to copy the application and agreement. Do you agree? Yes

7. Do you agree with the frequency of collection? not required to be resubmitted annually and is only required to be resubmitted to NMFS if components of the IPA covered by NMFS regulations are amended. Yes

8. Are the instructions for completion of the application clear? Yes

9. Do you agree with the reporting format, which is a form?

Comment

No. When amending our IPA, NMFS has requested narrative form (i.e., a cover sheet explaining what our IPA amendment seeks to do), so the form is insufficient and somewhat duplicative.

Response

The request for a cover letter was a one-time only suggestion to one respondent. Regulations do not require a cover letter.

NMFS will consider this survey comment in an upcoming proposed rule. The North Pacific Fishery Management Council currently is reviewing regulations governing management of salmon bycatch in the Bering Sea pollock fishery, and is scheduled to take final action in April 2015.  The regulations under review include the requirements for submission of this form and the IPA. The IPA is a signed contract that must include certain provisions; the form provides an easily readable method for collecting contact information and the list of vessels included in the IPA. 

The upcoming review of regulations and procedures will consider this comment. If there is duplication between the form and the IPA, then NMFS will correct that.

10. Are the required data elements reasonable and necessary? Yes

11. Do you believe that this application has practical utility? Yes

12. Do you have suggested ways to enhance the quality and clarity of the information to be collected? No

13. Do you have suggestions to minimize the burden of completing this application? No

14. Please provide any additional comments on any aspect of the AFA Program. No comment

Chinook IPA Annual Report 1 response

1. Is the data requested easily available? Yes

2. Is this process easy to understand ? Yes

3. We estimate it takes 8 hours for your office personnel to complete this report. Is this time accurate and reasonable?

Comment

No. It takes approximately 24 hours to complete all aspects of preparing and submitting the annual report. In addition, the Council requests a verbal report delivered to the Council and its advisory panel, which takes another six hours of preparation and delivery time.

Response

AKR will change the time to complete from 8 hours to 30 hours

4. We estimate that personnel costs to complete and submit the report are $75/hour. Is this cost accurate and reasonable?

Comment

No. The report is written by the same staff person as the IPA Application, which is estimated at $165/hr. Also, data are audited by external auditors that charge $150/hr.

Response

AKR will change the cost to complete from $75/hr to $165/hr

5. Does someone other than your office personnel complete the report?

Comment

Yes. The Mothership Fleet Cooperative Entity does not have an office, and thus does not have office personnel.

Response

No response needed

6. We estimate that it costs $13 to submit the report by fax or mail $1 to copy the report. Do you agree? Yes

7. Do you agree with the frequency of collection, which is annual? Yes

8. Are the instructions for completion of the report clear? Yes

9. Do you agree with the reporting format, which is narrative form rather than completion of a form? Yes

10. Are the required data elements reasonable and necessary? Yes

11. Do you believe that this report has practical utility? Yes

12. Do you have suggested ways to enhance the quality and clarity of the information to be collected? No

13. Do you have suggestions to minimize the burden of completing this application? No

14. Please provide any additional comments on any aspect of the AFA Program. No comment

Non-Chinook Salmon Inter-cooperative Agreement (ICA) No responses

Non-Chinook Salmon ICA Annual Report No responses

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. Assurance of confidentiality provided to respondents and the basis for this assurance in statute, regulation, or agency policy.

All information collections by NMFS Alaska region are protected under confidentiality provisions of section 402(b) of the Magnuson-Stevens Act. It is also confidential under NOAA Administrative Order 216-100, which sets forth procedures to protect confidentiality of fishery statistics. However, none of the information in the applications, contracts, or reports submitted under this collection of information contains confidential business information. All of the information in the ICA, IPA, and annual reports 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.

Estimated total respondents: 8, decreased from 11. Estimated total responses: 32, decreased from 161. Estimated total burden: 411 hr, decreased from 425 hr. Estimated total personnel costs: $51,450, increased from $45,100.

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).`

Estimated total miscellaneous costs: $93, increased from $56.

14. Provide estimates of annualized cost to the Federal government.

Estimated total responses: 32, decreased from 159. Estimated total burden: 66, decreased from 68. Estimated total personnel cost: $3,546, increased from $2,700.

15. Explain the reasons for any program changes or adjustments.

Adjustments are made in this collection: personnel costs are changed from $25/hr to $37/hr and in two cases, from $150 to $165.

Chinook IPA

a decrease of 1 respondent, 1 instead of 2

a decrease of 3 responses, 1 instead of 4

a decrease of 120 hours, 40 instead of 160 hr

a decrease of $17,400 personnel costs, $6,600 instead of $24,000

Chinook IPA Annual Report

an increase of 1 respondent and response, 3 instead of 2

an increase of 50 hours, 90 instead of 40 hr

an increase of $13,350 personnel costs, $14,850 instead of $1,500

an increase of $9 miscellaneous costs, $14 instead of $5

Non-Chinook ICA revisions

The previously named Salmon Bycatch Reduction ICA was replaced by this IC, but had been left in the collection in error; that burden of 40 hours was removed. Also, the Non-Chinook ICA full burden was reduced from 40 hours to 1 hour, as no new ICs are now being added, only revisions made.

Non-Chinook ICA Annual Report

an increase of 4 hours, 8 instead of 4 hr

an increase of $500 personnel costs, $600 instead of $100

AFA Coop Annual Report

a decrease of 3 respondents and responses, 8 instead of 11

a decrease of 24 hours, 64 instead of 88 hr

a decrease of $8,400 personnel costs, $4,800 instead of $13,200

an increase of $6 miscellaneous costs, $24 instead of $18

Annual Coop Pollock Catch Report

a decrease of 3 respondents, 8 instead of 11

a decrease of 124 responses, 8 instead of 132

an increase of 53 hours, 64 instead of 11 hr

an increase of $4,525 personnel costs, $4,800 instead of $275

an increase of $7 miscellaneous costs, $24 instead of $17

AFA Cooperative Contract – dropped at some point, now corrected by re-including

an increase of 8 respondents and responses, 8 instead of 0

an increase of 64 hours, 64 instead of 0

an increase of $4,800 personnel costs, $4,800 instead of 0

an increase of $24 miscellaneous costs, $24 instead of 0

Program Changes

AFA Catcher Vessel Intercoop Agreement [NEW]

an increase of 1 respondent and response, 1 instead of 0

an increase of 40 hours, 40 instead of 0 hr

an increase of $6,000 personnel costs, $6,000 instead of 0

an increase of $1 miscellaneous costs, $1 instead of 0

AFA Catcher Vessel Intercoop Report [NEW]

an increase of 1 respondent and response, 1 instead of 0

an increase of 40 hours, 40 instead of 0 hr

an increase of $3,000 personnel costs, $3,000 instead of 0

an increase of $1 miscellaneous costs, $1 instead of 0

Agent for Service of Process [REMOVED]

a decrease of 11 respondents and responses, 0 instead of 11

a decrease of 1 hour, 0 instead of 1

a decrease of $25 personnel costs, 0 instead of $25

a decrease of $1 miscellaneous costs, $0 instead of 1

16. For collections whose results will be published, outline the plans for tabulation and publication.

All of the Chinook Salmon IPAs, IPA list of participants, IPA annual reports and Non-Chinook Salmon ICAs and ICA annual reports are available to the public on the Alaska Region website at http://www.alaskafisheries.noaa.gov/sustainablefisheries/afa/afa_sf.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.

SURVEY

WHAT DO YOU THINK ABOUT THE

ALASKA AMERICAN FISHERIES ACT (AFA) REPORTS COLLECTION?

OMB Control No. 0648-0401

November, 2014

When renewing an Office of Management and Budget (OMB) information collection, NMFS Alaska Region is required to ask for comments from non-agency stakeholders and participants in each collection of information -- with the goal of minimizing burden. The collection is described at http://www.alaskafisheries.noaa.gov/notice/79fr35150.pdf

OMB requires NMFS to ask participants for comments on:

♦ Availability of data

♦ Frequency of collection

♦ Clarity of instructions and record keeping

♦ Disclosure

♦ Reporting format

♦ Data elements to be recorded, disclosed, or reported, and

♦ Accuracy of estimated burden.

As a participant in the Alaska AFA Reports Collection identified as OMB Control Number 0648-0401, please take a moment to answer the following questions. The comments you provide will help NMFS improve this collection of information. Please e-mail your responses to me at patsy.bearden@noaa.gov by November 24, 2014.

Thank you in advance. If you have questions or need additional information, please call me at 907-586-7008.

Respectfully,

Patsy A. Bearden

Sustainable Fisheries Division

NMFS Alaska Region

__________________________________________________________________________________________

Respond to questions with YES or NO answers and NO COMMENT with an “X” in the appropriate column. Please explain your comment on each item in the space provided. If you do not use an item, check NOT APPLICABLE, N/A.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Application for Chinook Salmon Incentive Plan Agreement (IPA) and List of IPA Participants	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand and to apply for?
3. We estimate it takes 40 hours for your office personnel to complete this agreement and application. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the agreement and application are $150/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the agreement and application?
6. We estimate that it costs $13 to submit by mail or fax and $1 to copy the application and agreement. Do you agree?
7. Do you agree with the frequency of collection? not required to be resubmitted annually and is only required to be resubmitted to NMFS if components of the IPA covered by NMFS regulations are amended.
8. Are the instructions for completion of the application clear?
9. Do you agree with the reporting format, which is a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this application has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this application?
14. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Chinook IPA Annual Report	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand ?
3. We estimate it takes 8 hours for your office personnel to complete this report. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the report are $75/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the report?
6. We estimate that it costs $13 to submit the report by fax or mail $1 to copy the report. Do you agree?
7. Do you agree with the frequency of collection, which is annual?
8. Are the instructions for completion of the report clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this report has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this application?
14. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Non-Chinook Salmon Inter-cooperative Agreement (ICA)	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand and to apply for?
3. We estimate it takes 40 hours for your office personnel to complete this agreement. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the agreement are $150/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the agreement?
6. We estimate that it costs $1.35 to submit the agreement by mail, 50 cents to copy the report, and $450 for third-party audit. Do you agree?
7. Do you agree with the frequency of collection? not required to be resubmitted annually and is only required to be resubmitted to NMFS if components of the ICA covered by NMFS regulations are amended.
8. Are the instructions for completion of the agreement clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this agreement has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this agreement?
14. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Non-Chinook ICA Annual Report	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand ?
3. We estimate it takes 8 hours for your office personnel to complete this report. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the report are $75/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the report?
6. We estimate that it costs $1.35 to submit the report by mail and 50 cents to copy the report. Do you agree?
7. Do you agree with the frequency of collection, which is annual?
8. Are the instructions for completion of the report clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this report has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this application?
14. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Annual Cooperative Report	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand ?
3. We estimate it takes 8 hours for your office personnel to complete this report. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the report are $75/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the report?
6. We estimate that it costs $1.35 to submit the report by mail, $6 by fax, and 50 cents to copy the report. Do you agree?
7. Do you agree with the frequency of collection, which is annual?
8. Are the instructions for completion of the report clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this report has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this application?
14. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Annual Catcher Vessel Cooperative Pollock Catch Report	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand ?
3. We estimate it takes 8 hours for your office personnel to complete this report. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the report are $75/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the report?
6. We estimate that it costs $1.35 to submit the report by mail, $6 by fax, and 50 cents to copy the report. Do you agree?
7. Do you agree with the frequency of collection, which is annual?
8. Are the instructions for completion of the report clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this report has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this report?
14. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Catcher Vessel Intercooperative Agreement	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand and to apply for?
3. We estimate it takes 40 hours for your office personnel to complete this application. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the application are $150/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the application?
6. We estimate that it costs $0.90 to submit the agreement online and 50 cents to copy the agreement. Do you agree?
7. Do you agree with the frequency of collection, which is annual?
8. Are the instructions for completion of the agreement clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this agreement has practical utility?
12. Do you have suggested ways to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this agreement?
14. Do you agree with adding voluntary data to data required by regulations in the same agreement?
15. Please provide any additional comments on any aspect of the AFA Program.

OMB 0648-0401 – Expiration Date 12/31/2014 Check if N/A [ ]
Annual Catcher Vessel Intercooperative Report	YES	NO	COMMENTS	No Comment
1. Is the data requested easily available?
2. Is this process easy to understand and to apply for?
3. We estimate it takes 8 hours for your office personnel to complete this report. Is this time accurate and reasonable?
4. We estimate that personnel costs to complete and submit the report are $75/hour. Is this cost accurate and reasonable?
5. Does someone other than your office personnel complete the report?
6. We estimate that it costs $0.05 to submit the report online and 50 cents to copy the report. Do you agree?
7. Do you agree with the frequency of collection, which is annual?
8. Are the instructions for completion of the report clear?
9. Do you agree with the reporting format, which is narrative form rather than completion of a form?
10. Are the required data elements reasonable and necessary?
11. Do you believe that this report has practical utility?
12. Do you have suggestions to enhance the quality and clarity of the information to be collected?
13. Do you have suggestions to minimize the burden of completing this report?
14. Do you agree with adding voluntary data to data required by regulations in the same report?
15. Please provide any additional comments on any aspect of the AFA Program.

AFA Reports Collection

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