SUPPORTING STATEMENT PART A
ALASKA REGION CRAB ECONOMIC DATA REPORTS (EDR)
OMB CONTROL NO. 0648-0518
This action is a request for extension of an existing information collection with no changes to the components of the collection or the data collected. Responses to the supporting statement questions and estimates of the number of respondents, burden hours, and costs have been revised and updated.
INTRODUCTION
The Crab Rationalization Program (CR Program) is one of seven catch share programs in the federally managed fisheries off Alaska. The CR Program was developed by the North Pacific Fishery Management Council (Council) as Amendments 18 and 19 to the Fishery Management Plan for Bering Sea/Aleutian Islands King and Tanner Crabs (Crab FMP). In January 2004, the United States Congress amended the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act) by adding section 313(j) mandating NMFS to implement the Council’s CR Program. The Council’s recommended CR Program included an economic data collection component that is the subject of this information collection. Section 313(j)(3) also authorizes the Council to submit and the Secretary of Commerce to approve subsequent changes to or repeal of provisions of the CR Program. The final rule implementing the CR Program was effective April 1, 2005 (70 FR 10174) and fishing under the CR Program started in the fall of 2005.
The CR Program is a catch share program that allocates BSAI crab resources among harvesters, processors, and coastal communities. The CR Program components include quota share (QS), processor quota share (PQS), individual fishing quota (IFQ), individual processing quota (IPQ), quota transfers, use caps, crab harvesting cooperatives, protections for Gulf of Alaska groundfish fisheries, arbitration system, monitoring, economic data collection, and cost recovery collection. Additional information about the CR Program is available on the NOAA Fisheries Alaska Region’s webpage.
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
This information collection (0648-0518) covers the economic data collection components of the CR Program, which are known as “Economic Data Reports” (EDRs). The Council recommended implementing economic data collection requirements and provided the following purpose and need for this information collection in its June, 2002 motion:
A mandatory data collection program shall be developed and implemented as part of the crab rationalization program and continued through the life of the program. Cost, revenue, ownership and employment data will be collected on a periodic basis (based on scientific requirements) to provide the information necessary to study the impacts of the crab rationalization program as well as collecting data that could be used to analyze the economic and social impacts of future FMP amendments on industry, regions, and localities. This data collection effort is also required to fulfill the Council problem statement requiring a crab rationalization program that would achieve “equity between the harvesting and processing sectors” and to monitor the “...economic stability for harvesters, processors and coastal communities. Both statutory and regulatory language shall be developed to ensure the confidentiality of these data.
Any mandatory data collection program shall include:
A comprehensive discussion of the enforcement of such a program, including enforcement actions that would be taken if inaccuracies in the data are found. The intent of this action would be to ensure that accurate data are collected without being overly burdensome on industry for unintended errors.”
This information collection contains three forms and a non-form component:
1. Annual Catcher/Processor Crab Economic Data Report
2. Annual Catcher Vessel Crab Economic Data Report
3. Annual Processor Crab Economic Data Report
4. Information required to conduct verification of data.
The requirements for the crab EDRs are contained in Chapter 11, Section 14 of the Crab FMP and regulations at 50 CFR part 680.
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.
Pacific States Marine Fisheries Commission (PSMFC) has been designated at the “data collection agent” (DCA) for the crab EDR Program. NMFS provides funding to PSMFC through a grant. PSMFC provides primary administrative support for collection and database management for the crab EDR. NMFS and PSMFC collaborate on development and maintenance of work plans for implementation of the EDRs, including development procedures and requirements for soliciting and selecting bids for required IT application development and the data verification audits that are subcontracted by PSMFC. NMFS monitors implementation and oversees quality control of PSMFCs administrative process and communication with respondents.
Any owner or leaseholder of a vessel or processing plant, or a holder of a Registered Crab Receiver permit (RCR) who harvested, processed, custom processed, or obtained custom processing for CR crab, during a calendar year, must submit a complete EDR by following the instructions on the applicable EDR. A completed EDR or EDR certification pages must be submitted to PSMFC for each calendar year on or before 1700 hours, A.l.t., July 31 of the following year.
The purpose of the crab EDRs is to gather information about ownership, revenue, cost, vessel operations, and employment to analyze the economic effects of the Crab Rationalization Program and the economic performance of participants in the program, and to estimate impacts of future issues, problems, or proposed revisions to the program. The data collected through the EDRs are used to prepare reports, program reviews, and analysis of proposed revisions to the Crab Rationalization Program.
An annual summary of crab EDR data is prepared as part of the Economic Status of the Bering Sea and Aleutian Islands King and Tanner Crab Fisheries off Alaska. Statistics on harvesting and processing activity; effort; revenue; labor employment and compensation; operational costs; and quota ownership, usage and disposition among participants in the fisheries are provided.
The data collected through the crab EDRs is necessary to conduct the Crab Rationalization Program reviews. The Magnuson-Stevens Act requires periodic program reviews for all catch share programs (also known as limited access privilege programs). Both the 5-year and 10-year Crab Rationalization Program reviews relied on EDR data to document fleet performance with regard to quota usage and leasing, effort levels, vessel operating costs, gross and net earnings, crew participation and crew earnings. This information is also used to document changes in crew employment and compensation and state of residency of crew. Processing labor, employment, and wages are also assessed using EDR data. The 10-year crab program review Social Impact Assessment utilized EDR data along with other data sources to provide, within the bounds of data confidentiality constraints, a quantitative participation description by community, including harvest trends by crab fishery, local community fleet participation, catcher vessel crab harvest volume and value by community, community processor participation, processor volume and value by community by share type, and quota share distribution by community for Alaska, Washington, Oregon, and other U.S. states combined. The 10-year program review also summarizes the social impacts of crab rationalization by community, including discussions of vessel participation, catcher vessel owner shareholdings, crew participation, catcher vessel crew shareholdings, locally operating processors, support services, and local governance and revenues.
a. Annual Catcher Vessel Crab EDR
Any owner or leaseholder of a catcher vessel that landed CR crab in the previous calendar year must submit to the DCA, electronically or at the address provided on the form, a completed catcher vessel EDR for annual data for the previous calendar year. A copy of the form for 2018 data that is required to be submitted in 2019 is attached to this supporting statement.
The following information must be submitted on the Annual Catcher Vessel Crab EDR form:
Catcher vessel crab EDR Certification Page
Catcher Vessel Information
Vessel Name and ADF&G Vessel Registration Number
Crab License Limitation Permit Number(s)
USCG Documentation Number
Current Estimated Market Value of Vessel and Equipment
Replacement Value of Vessel and Equipment
Name of Crab Harvesting Cooperative (if applicable)
Vessel Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business fax Number
Business E-mail address, if available
Vessel Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business fax Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same as the Owner Information block, do not repeat)
Leaseholder (If name and address are the same as the Leaseholder Information block, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business fax Number
Business E-mail address (if available)
EDR filing Status
Check appropriate statement to describe EDR filing status
Buyer/Leaseholder Information (if applicable)
Buyer/Leaseholder Name
Business Address
Telephone No (include area code)
Date of Sale or Lease (day/month/year)
Certification Signature and date signed
Catcher Vessel Crab EDR
CR Crab Ex-vessel Sales, by CR Fishery and Quota Type
Total pounds of BSAI crab landed by this vessel and sold to crab buyers during the previous calendar year
Exclude deadloss crab that is discarded unsold at the landing
Gross revenue from crab delivered to processors during the calendar year
CR Crab Fishing Quota Costs, by CR Fishery and Quota Type Market-Value and Negotiated-Price Transfers Only
Total pounds of transferred crab fishing quota used to land crab caught by the vessel during the previous calendar year
Total gross cost paid as monetary compensation, after taxes or fees are deducted
CR Crab Crew Labor Costs, by CR Fishery
Total amount paid to vessel crew members for fishing labor services in CR fisheries during the previous calendar year, not including any amount paid to individuals as captain or vessel master. Include all post-season adjustments paid as of the date of submitting this EDR
Total payment made to the captain(s) for vessel master services in CR fisheries during the previous calendar year. Include all post-season adjustments paid as of the date of submitting this EDR
Indicate whether you provided paid health insurance or retirement benefits to captain or crew members in addition to labor payments reported above
Vessel Operating Expenses, by CR Fishery
Total cost of food and provisions purchased for use in each CR fishery during the previous calendar year
Total cost of bait purchased for use in each CR fishery during the calendar year
Total gallons of fuel consumed by the vessel while operating in each CR fishery
Vessel Operating Expenses, Annual
Fuel Cost, Annual
Total quantity of fuel purchased for the vessel during the previous calendar year, in gallons
Total payment for fuel purchased for the vessel for all crab, non-crab, and non-fishing operations during the previous calendar year, including all sales taxes and surcharges
Vessel Labor Cost
Total direct payment to vessel crew and captain for labor performed in all vessel operations during the calendar year, including shipyard labor and tendering
Indicate whether the vessel performed tendering in any fishery during the previous calendar year
BSAI Crab Crew Licenses and CFEC Permits
Record either the Alaska Commercial Crew license number or a State of Alaska Commercial Fisheries Entry Commission (CFEC) gear operator permit number for each individual who worked as a captain or crewmember during the previous calendar year
For Commercial Crew Licenses, report the full 7-digit license number.
For Gear Operator Permits, include the fishery code and permit number (e.g. M71B25321N).
Indicate if the number reported is an ADF&G Commercial Crew License number or a CFEC Gear Operator Permit Number. Record one license or permit number per crewmember. Do not record any crewmember more than once.
b. Annual Catcher/Processor Crab EDR
Any owner or leaseholder of a catcher/processor that harvested or processed CR crab in the previous calendar year must submit to the DCA, electronically or at the address provided on the form, a completed catcher/processor EDR for annual data for the previous calendar year.
Catcher/processors participate in both harvesting and processing and therefore, the catcher/processor crab EDR includes elements for the collection of harvesting and processing information.
A copy of the form for 2018 data that is required to be submitted in 2019 is attached to this supporting statement.
The following information must be submitted on the Annual Catcher/Processor Crab EDR form:
Annual catcher/processor crab EDR Certification page
Catcher/processor Information
Catcher/processor Name and ADF&G Processor Code
Registered Crab Receiver Permit Number
Crab License Limitation Permit Number(s)
USCG Documentation Number
Current Estimated Market Value of Vessel and Equipment
Replacement Value of Vessel and Equipment
Name of Crab Harvesting Cooperative (if applicable)
Vessel Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business fax Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business fax Number
Business E-mail address, if available
Person Completing this Report (check one)
Owner (If name and address are the same as Owner Information block, do not repeat)
Leaseholder (If name and address are as Leaseholder Information block, do not repeat)
Designated Representative
Name and Title
Business Telephone Number and Business fax Number
Business E-mail address (if available)
EDR filing Status
Check appropriate statement to describe EDR filing status
Buyer/Leaseholder Information (if applicable)
Buyer/Leaseholder Name
Business Address
Telephone Number (include area code)
Date of Sale or Lease (day/month/year)
Signature and date signed
Annual catcher/processor crab EDR
CR Crab Ex-vessel Sales, by CR Fishery and Quota Type
Total pounds of BSAI crab landed by this vessel and sold to crab buyers during the previous calendar year.
Gross Revenue from crab delivered to processors during the calendar year
CR Crab Product Sales
Species Code for CR crab product sold in previous calendar year
Product Code for each product.
Process Code.
Box Size category code for each product sold
Total finished pounds of each product sold
Gross First Wholesale Revenue: Record the amount you received for each product sold
CR Crab Custom Processing Services Provided, by CR Fishery
CR Fishery Code for each CR fishery in which you provided custom processing services
Product Code for each product
Process Code for each product
Total Raw Pounds of CR crab provided by RCRs receiving custom processing services
Finished Pounds or total pounds of output for each custom processed product
Custom Processing Revenue received for custom processing the specified products
Raw CR Crab Purchases from Delivering Vessels, by CR Fishery and Quota Type
Total pounds of Raw Pounds Purchased
Total Gross value of raw crab purchases, including all post-season adjustments paid to sellers
CR Crab Custom Processing Services Purchased, by CR fishery
CR Fishery Code for each CR fishery in which you purchased custom processing services
Product Code for each product.
Process Code for each product.
Total Raw Pounds of CR crab provided to processors providing custom processing services
Finished Pounds or total pounds of output for each custom processed product
Processing Fee or payment made to custom processors for each crab product
CR Crab Fishing and Processing Quota Costs, by CR Fishery and Quota type - Market-Value and Negotiated-Price Transfers Only
Total pounds of transferred crab fishing (IFQ, CDQ) and/or processing (IPQ) quota used to harvest CR crab on the vessel or purchase CR crab from delivering vessels during the previous calendar year
Total gross cost paid as monetary compensation, before taxes or fees are deducted
CR Crab Crew Labor Cost, by CR Fishery
Total amount paid to vessel fishing crew and processing employees for labor services in CR fisheries during the previous calendar year, not including any amount paid to individuals as captain or vessel master
Total payment made to the captain(s) for vessel master services in CR fisheries during the calendar year
Indicate whether you provided paid health insurance or retirement benefits to captain or crew members in addition to labor payments reported above
Vessel Operating Expenses, by CR Fishery
Total cost of food and provisions purchased for use in each CR fishery during the previous calendar year
Total cost of bait purchased for use in each CR fishery during the calendar year
Total gallons of fuel consumed by the vessel while operating in each of the CR fisheries
Vessel Operating Expenses, Annual
Fuel Cost, Annual
Total quantity of fuel purchased for the vessel during the previous calendar year, in gallons.
Total payment for fuel purchased for the vessel during the previous calendar year, including all sales taxes and surcharges
Vessel Labor Cost, Annual
Total direct payment to vessel processing employees, fishing crew, and captain for labor performed in all vessel operations during the calendar year, including shipyard labor and tendering
BSAI Crab Crew Licenses and CFEC Permits
For Commercial Crew Licenses, report the full 7-digit license number.
For Gear Operator Permits, include the fishery code and permit number (e.g. M71B25321N).
c. Annual Processor (Shoreside Processor, Stationary Floating Processor, or Registered Crab Receiver) Crab EDR
Any owner or leaseholder of a shoreside processor or stationary floating processor that processed CR crab, including custom processing of CR crab performed for other crab buyers, in the previous calendar year must submit to the DCA, electronically or at the address provided on the form, a completed processor EDR for annual data for the previous calendar year.
Any holder of a registered crab receiver (RCR) permit that obtained custom processing for CR Program crab in the previous calendar year must submit to the DCA, electronically or at the address provided on the form, a completed processor EDR for annual data for the previous calendar year.
A copy of the form for 2018 data that is required to be submitted in 2019 is attached to this supporting statement.
The following information must be submitted on the Annual Processor EDR form:
Processor EDR Certification page
Processor Information
Facility Name and ADF&G Processor Code
RCR Permit Number
Physical Location (if a land-based plant)
USCG Documentation Number (if a stationary floating processor)
Current Estimated Market Value of Processor and Equipment
Replacement Value of SFCP and Equipment
Owner Information
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business Fax Number
Business E-mail address, if available
Leaseholder Information (if applicable)
Name of company, partnership, or sole proprietorship
Business Telephone Number and Business Fax Number
Business E-mail address, if available
Person Completing this Report
Indicate if owner, leaseholder, or designated representative
If Designated Representative
Name and Title
Business Telephone Number and Business Fax Number
Business E-mail address (if available)
EDR Filing Status
Select the appropriate statement to describe EDR filing status
Buyer/leaseholder Information
Name
Business Telephone Number and Business Fax Number
Business E-mail address (if available)
Signature and date signed
Processor EDR
CR Crab Product Sales
CR Crab Sales to Affiliated Entities
Species Code for CR crab product sold
Product Code for each product
Process Code
Box Size Code for each product sold
Total finished Pounds of each product sold
Gross First Wholesale Revenue you received for each product sold
CR Crab Sales to Unaffiliated Entities
Species Code for CR crab product sold
Product Code for each product
Process Code
Box Size Code for each product sold
Total finished Pounds of each product sold
Gross First Wholesale Revenue you received for each product sold
CR Crab Custom Processing Services Provided, by CR Fishery
CR fishery code for each CR fishery in which you provided custom processing services
Product Code for each product
Process Code
Total raw pounds of CR crab provided by RCRs receiving custom processing services from this facility
Total finished pounds or total pounds of output for each custom processed product
Custom Processing Revenue received for custom processing the specified products
Raw CR Crab Purchases from Delivering Vessels, by CR Fishery and Quota Type
Total Raw pounds purchased
Total gross value of raw crab purchases, including all post-season adjustments paid to sellers
CR Crab Custom Processing Services Purchased, by CR Fishery
CR Fishery Code for each CR fishery in which you purchased custom processing services
Product Code for each product.
Process Code
Total Raw Pounds of CR crab provided to processors providing custom processing services
Finished Pounds or total pounds of output for each custom processed product
Processing Fee or payment made to custom processors for each crab product.
CR Crab Processing Quota Costs by CR Fishery - Market-Value and Negotiated-Price Transfers Only
Total pounds of transferred crab (IPQ) acquired for your use in purchasing landed CR crab during the previous calendar year
Total gross cost paid as monetary compensation, before taxes or fees are deducted. Include all post-season adjustments paid as of the date of submitting this EDR, but do not report any payments not paid by this date
Crab Processing Labor Cost, by CR Fishery
Total Man-Hours or the sum of all hours worked by crab processing workers for each CR fishery
Total Labor Payment or total gross wages paid to crab processing workers in each CR fishery
Computed Average Hourly Wage (web form only)
General Non-processing Labor Expenses, Annual
Number of Employees or the number persons employed in non-processing positions at the processing facility during the previous calendar year
Salaries and wages or total calendar year gross wages for non-processing employees
CR
Crab Processing Employee Residence
Official
locations of residence
Number of individuals employed, by location.
For residence locations in Alaska, list individual Alaska cities
For US locations outside of Alaska, list individual US states
For non-US locations, list individual counties
For each location of residence
Total number of individuals employed processing CR crab
Total number of individuals employed in seafood processing in all fisheries, including CR crab
d. Verification of data
Crab EDRs were developed to aid the Council and NMFS in assessing the success of the program and developing amendments necessary to mitigate any unintended consequences. To ensure that the data submitted by respondents in the EDRs is accurate, PSMFC contracts an auditor, AKT CPAs and Business Consultants. The auditor develops a process to review the data contained within submitted EDRs, including verification audits for those EDRs containing odd or suspicious data values, and conduct random audits for a certain percentage of submitted EDRs. Each year’s audit report is posted on PSMFC’s crab EDR webpage.
The owner or leaseholder must provide copies of additional data to facilitate verification. The auditor may review and request copies of additional data provided by the owner or leaseholder, including but not limited to previously audited or reviewed financial statements, worksheets, tax returns, invoices, receipts, and other original documents substantiating the data.
Auditors will verify records by comparing specific elements of the report with participant accounting records. To make this activity as efficient and non-intrusive as possible, NMFS suggests that participants:
♦ Keep a copy of the completed EDR or certification pages submitted to PSMFC. Copy and attach extra sheets as needed.
♦ Keep a file that has all of the supporting information used in the preparation of the EDR.
♦ Ensure that the EDR agrees to the company's highest level of financial information. For this purpose, the highest level of financial information is defined in order as:
Audited financial statements
Reviewed financial statements
Compiled financial statements
Tax returns.
The verification questions are usually small in number and occur through a telephone call or other short communication made by the auditor. The owner or leaseholder must respond to inquiries by the auditor within 20 days of the date of issuance of the inquiry. The 20-day response period is necessary in case there are EDR verification questions that are sequential based on previous questions.
As described in more detail in the response to Question #8, NMFS prepared a discussion paper reviewing elements of the EDRs and identified the data verification audits as an area of the information collection requirements that need to be re-evaluated and likely revised. Two issues have emerged from experience with the audits to date: 1) in all audits conducted since 2006, there has not been a single finding of intentional misreporting, or of any bias in the direction of reporting errors identified by auditors; and 2) verifying the quality of results produced by auditors requires considerable effort by NMFS and PSMFC, and considerable cost to the industry. On the latter point, contracting for the services of CPA firms to conduct data validation audits is not straightforward, and the tasks involved are unfamiliar to CPAs and require one or two iterations to gain experience. However, CPA firms face staff turnovers and can’t be relied upon to maintain staffing stability for EDR contracts, and PSMFC is required to issue request for proposals to renew ongoing service every three years at minimum.
In the discussion paper, NMFS recommended that the Council re-evaluate the third-party data verification audit requirements and consider removing or reducing these requirements. In April 2019, the Council concurred with this recommendation and recommended that NMFS prepare specific recommendations for revisions to the Council’s Crab FMP and Federal regulations governing the crab EDRs. In addition, the Council also recommended that while revisions to the data verification audit requirements are under development, NMFS should reduce the burden associated with data verification audits as much as possible under existing regulations. NMFS employed this approach for the audits of the 2018 crab EDRs that were submitted by July 31, 2019. Because the third party audits are authorized by regulation, but not required, NMFS chose to not conduct any third party audits in 2019. However, NMFS continues to include a description of the audit process and request for approval to collect information through the audits until regulations governing the audit process can be reviewed by the Council and revised by NMFS.
In January 2020, the Council reviewed an initial draft analysis of proposed fishery management plan and regulatory revisions associated with revising the audit requirements. The Council has not yet scheduled final action on this analysis, but is expected to address it later in 2020 after the Council receives additional updates from NMFS about the comprehensive review of all EDR programs. When revisions to the data verification audits are incorporated into a proposed rule, NMFS will submit a request for a revision to this information collection (0648-0518 Crab EDRs) that describes the revisions and estimates the reduction in burden hours and costs that will result from these revisions.
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.
Section 515 of Public Law 106-554 (the Information Quality Act) requires NMFS to ensure the quality, objectivity, utility, and integrity of information it publicly disseminates. Data collected through the CR EDRs will continue to be disseminated to the public in aggregated and non-confidential form in summary reports, program reviews, or analyses of the impacts of proposed changes to the CR Program. Public dissemination of these data is governed by NOAA's information quality guidelines, which were issued on October 30, 2004. Reports and analyses prepared with EDR data generally fall under NOAA's information quality category "synthesized products." These products have been developed through analysis of original data by applying methods that require some scientific evaluation and judgment, however; these methods of analysis generally are well documented and relatively routine. Therefore, peer review is generally not required for reports and analyses prepared using EDR data. However, peer review will be conducted if the report will be published in a journal that requires peer review. Reports and analyses undergo internal agency review by people familiar with the underlying data and fisheries being described. In addition, analyses presented to the North Pacific Fishery Management Council are reviewed by its Scientific and Statistical Committee.
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.
PSMFC manages a web portal that allows respondents to submit their EDR forms online. PSMFC sends out certified letters each year to respondents that include a new login and password and instructions about how to use the web portal to submit EDR forms online using an electronic signature. The online system provides the option for the respondent to print out the completed forms for their records. Respondents also have the option of downloading the EDR forms, filling them out, and submitting them as attachments to an e-mail to PSMFC, or submitting the completed forms by mail. PSMFC reports that approximately 99 percent of respondents submit their EDRs online using an electronic signature. In 2018, one form was submitted electronically as an attachment to an e-mail and one form was mailed in.
Annual EDR forms for catcher vessels, catcher/processors, shoreside crab processors, and stationary floating crab processors are available on the Pacific States Marine Fisheries Commission (PSMFC) Alaska Crab Rational Program Web site at http://www.psmfc.org/alaska_crab/. Links to PSMFC website are provided on the NOAA Fisheries Alaska Region’s webpage.
4. Describe efforts to identify duplication.
A recent review of the four Alaska Region/North Pacific EDR Programs has identified some areas where the data collected through the EDRs may duplicate data collected through other information collections. NMFS is continuing this review and if specific data fields in the Crab EDR are identified as duplicative of other information already collected, NMFS will revise the Crab EDRs and submit a request to OMB to approve the associated revisions to the data currently collected. This review, which is described in more detail in the response to Question #8, is underway and may be complete in 2021.
5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
None of the respondents to this data collection are small entities under the Regulatory Flexibility Act.
6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.
The crab EDR data is required by regulation in 50 CFR part 680 and supported by section 313(j) of the Magnuson-Stevens Fishery Conservation and Management Act. The data collection was designed by the Council to collect information for each participant in the Crab Rationalization fisheries on an annual basis to achieve the objectives of collecting the data necessary to monitor and evaluate the CR Program, a program that provides significant economic benefits to participants and impacts individuals and communities reliant on the crab fisheries.
In April 2019, NMFS and the Council initiated a comprehensive review of the crab EDR, along with the three other Alaska Region/North Pacific EDR Programs. One of the issues that will be addressed in the review of the EDRs is whether annual submission of data by each respondent continues to be necessary to provide the data needed to monitor and evaluate the Crab Rationalization Program.
7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
No circumstances require the crab EDR data to be conducted in a manner inconsistent with OMB guidelines.
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 notice informing the public that this information collection was under consideration for renewal and soliciting comments was published in the Federal Register on March 2, 2019 (84 FR 8307). The comment period ended on May 7, 2019. NMFS received no public comments on this information collection renewal.
During this comment period, NMFS staff prepared and presented a discussion paper to the Council about the Alaska Region’s four economic data collection programs, one of which is the crab EDR. The Council requested this discussion paper in response to comments it received at several meetings in 2018 about the time burden and cost of the EDRs. The discussion paper described the EDR requirements for all four programs, explained how the data are used, and provided estimates of the costs of complying with the EDR requirements. The discussion paper was made available to the public and affected industry on March 22, 2019, by posting on the Council’s website and was discussed by the Council in a public meeting on April 7, 2019. At the time the discussion paper was released, NMFS staff contacted the representative of the Alaska Bering Sea Crabber’s, an organization representing participants in the Bering Sea crab fisheries, to let them know about the discussion paper and the opportunity to provide comments on the crab EDR to the Council.
After reviewing the discussion paper and hearing public comment, the Council recommended further review and consideration of revisions to all of the EDR programs, including the crab EDR. Specifically, the Council requested analysts prepare a “Regulatory Impact Review” (RIR), which is an analysis required for any proposed revision to Federal regulations. The RIR would analyze proposed revisions to improve the usability, efficiency, and consistency of the EDRs and to minimize cost to industry and the Federal government. The proposed revisions would remove the requirement for third party data verification audits and “blind-data” protocols and revise the data aggregation protocol to be the same as is used for all other fishery statistics. NMFS Alaska Region staff presented the draft RIR for these proposed revisions to the Council at its January 2020 meeting. After consideration of the staff reports, committee reports, and public testimony, the Council modified the purpose and need for the proposed action and the alternatives to be analyzed. These modifications will require additional analysis and Council scheduling of the revised analysis for future consideration by the Council. More information about the Council action is on the Council’s January 2020 meeting agenda.
As a longer term issue, the Council also requested its Social Science Planning Team (SSPT) review the discussion paper and make recommendations about an approach to conducting a more comprehensive review of all of the data collected under the EDRs. The SSPT met in early May 2019 and again in November 2019 to discuss an approach to reviewing all of the four existing EDRs. The SSPT provided a status report to the Council at its January 2020 meeting. The Council requested that the SSPT “focus its immediate work on recommending revisions to the current Economic Data Reporting requirements with the primary objectives to improve utility to inform Council decision documents and data quality.” The Council also hired a meeting facilitator to assist with developing an industry workshop that they hope can be held in the summer or fall of 2020. Revisions to this supporting statement will be submitted to OMB for review if any revisions are recommended by the Council in the future to either the crab EDR regulations or forms.
9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.
No payment or gift will be provided under this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.
EDR data records are considered confidential information and are protected from public disclosure consistent with MSA Section 402(b), 50 CFR 600.402-425, and NOAA Administrative Order 216-100. Access to confidential EDR records is limited to agency personnel, PSMFC staff, contractors, and Council staff that are authorized to access confidential fishery data. All staff and contractors with access to the crab EDR data sign a confidentiality agreement attesting that they have read and understand the confidentiality requirements and penalties for disclosing confidential information, and agreeing not to disclose confidential information.
In addition to data confidentiality requirements that apply to other categories of confidential fisheries data, additional protocols apply to the EDR data. Regulations at § 680.6 require that the data collection be conducted by a “Designated Data Collection Agent” (DCA), and the Crab FMP limits release of unaggregated EDR data in blind format only. As noted earlier, the Pacific States Marine Fisheries Commission (PSMFC) is the DCA for all of the NMFS Alaska Region EDRs. PSMFC staff maintain analytical versions of the crab EDR data tables, integrated with ancillary data and with identifiers replaced with anonymous record IDs for use by authorized analysts. In addition, due to concerns regarding the sensitivity of proprietary cost data collected in EDRs, the Council requested that NMFS develop enhanced confidential data protocols for EDR data following the initial collection of annual Crab EDRs in 2006. Based on a review of OMB guidance and best practices for nondisclosure control and interagency consultation, it was determined that a minimum aggregation standard of 5 data records would be employed for public disclosure of aggregate statistics reporting EDR results (compared to a minimum of three records required for all other federal and state sources of North Pacific fishery data). The same “rule of 5” standard has subsequently been applied to all public release of statistics derived from EDR Program data. As noted in the response to Question 8, NMFS and the Council are undertaking a review of the blind data requirements and additional aggregation protocols, so these provisions may be removed or revised in the future.
This information collection also is covered by the Privacy Act System of Records Notice (SORN) COMMERCE/NOAA-16, Economic Data Reports for Alaska Federally Regulated Fisheries off the Coast of Alaska.
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 the collection of information of a sensitive nature as described in this question.
12. Provide an estimate in hours of the burden of the collection of information.
Information Collection |
Number of respondents |
Frequency of annual responses per entity |
Total annual responses |
Estimated time per response |
Total annual burden hours |
Total labor cost 1 |
Annual Catcher Vessel Crab EDR |
70 – full EDR |
1 |
70 |
20 hr |
1,400 |
$0 |
1 – cert. only2 |
1 |
1 |
1 hr |
1 |
$0 |
|
Annual Catcher/Processor Crab EDR |
2 – full EDR |
1 |
2 |
20 hr |
40 |
$0 |
0 – cert. only2 |
1 |
0 |
1 hr |
0 |
$0 |
|
Annual Processor Crab EDR |
18 – full EDR |
1 |
18 |
16 hr |
288 |
$0 |
4 – cert. only2 |
1 |
4 |
1 hr |
4 |
$0 |
|
Verification of Data |
16 CVs |
1 |
16 |
8 hr |
128 |
$0 |
0 CPs |
1 |
0 |
8 hr |
0 |
$0 |
|
4 processors |
1 |
4 |
8 hr |
32 |
$0 |
|
Total for collection |
953 |
- |
115 |
- |
1,893 |
$0 |
1 Respondents hire an accountant to complete the collection of information. This cost is reported under Question 13 in the table for miscellaneous costs.
2 Respondents submit only the certification page indicating that they are not required to complete the full EDR.
3 The total respondents for the collection consists of unique entities only. Some respondents submit an EDR and a verification of data; therefore, the number of unique entities is used to show the estimated annual number of individual participants who are expected to submit information during the 3-year renewal period for this ICR (i.e., the 16 CVs and 4 processors are not counted towards the total number of respondents to avoid double counting).
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).
Information Collection |
Total annual responses |
Total annual miscellaneous cost per response1 |
Total annual miscellaneous cost for respondents |
Annual Catcher Vessel Crab EDR |
70 – full EDR |
Accountant fee ($165/hr x 20 hr = $3,300) Photocopy full EDR ($0.15 x 16 pp = $2.40) 1 of the 70 EDRs was submitted by mail = $15.00 Online or email submittal ($0)3 |
$231,000 + $168 + $15 + $0 = $231,183 |
1 – cert. only2 |
Accountant fee ($165/hr x 1 hr = $165) Photocopy cert. only ($0.15 x 2 pp = $0.30) Online or email submittal ($0)3 |
$165 + $0.30 + $0 = $165 |
|
Annual Catcher/Processor Crab EDR |
2 – full EDR |
Accountant fee ($165/hr x 20 hr = $3,300) Photocopy full EDR ($0.15 x 24 pp = $3.60) Online or email submittal ($0)3 |
$6,600 + $7.20 + $0 = $6,607 |
0 – cert. only2 |
Accountant fee ($165/hr x 2 hr = $330) Photocopy cert. only ($0.15 x 2 pp = $0.30) Online or email submittal ($0)3 |
$0 |
|
Annual Processor Crab EDR |
18 – full EDR |
Accountant fee ($165/hr x 16 hr = $2,640) Photocopy full EDR ($0.15 x 24 pp = $3.60) Online or email submittal ($0)3 |
$47,520 + $64.80 + $0 = $47,585 |
4 – cert. only2 |
Accountant fee ($165/hr x 1 hr = $165) Photocopy cert. only ($0.15 x 2 pp = $0.30) Online or email submittal ($0)3 |
$660 + $1.20 + $0 = $661 |
|
Verification of Data |
16 CVs |
Accountant fee ($165/hr x 8 hr = $1,320) Photocopy full EDR ($0.15 x 20 pp = $3.00) |
$21,120 + $48 = $21,168 $0 $5,280 + $12 = $5,292 |
0 CPs |
|||
4 processors |
|||
Total for collection |
115 |
- |
$312,661 |
1 Estimated cost of an accountant hired to prepare the crab EDR, certification page, and information requested for the verification process is $165 per hour.
2 Respondents submit only the certification page indicating that they are not required to complete the full EDR.
3 Although responses are accepted by mail, all respondents are expected to complete the online form or submit a pdf form via email.
14. Provide estimates of annualized cost to the Federal government.
The cost of the Crab EDR Program to the Federal government includes the costs of the PSMFC and their subcontractors in their role as NMFS’s data collection agent. PSMFC provides administrative support for the data collections, software development, web services, and database administration. Costs also include NMFS staff at the Alaska Fisheries Science Center for oversight of PSMFCs work, performing additional data quality evaluations, form development and refinement, collaboration on PRA clearance and publication of authorizing regulations, and associated public outreach (meetings, consultations and user support). AFSC also provides office space, computer equipment, and other administrative services. The estimated costs to the Federal government in 2017 was $180,168.
Section 303A(c)(9)(e) of the Magnuson-Stevens Fishery Conservation and Management Act authorizes NMFS to implement a fees on the permit holders in the Crab Rationalization Program to recover the costs of management, data collection and analyses, and enforcement activities for the program. The crab EDRs fall under the category of costs that are recovered from participants in the Crab Rationalization Program. Under this program, the $180,168 in costs for the crab EDRs in 2017 has been recovered and deposited into the U.S. Treasury. Therefore, the costs to the Federal government for this information collection program are zero.
15. Explain the reasons for any program changes or adjustments.
The following tables show the changes in the number of respondents, responses, time estimates, labor costs, and miscellaneous costs; and explains the reasons for these changes.
|
Respondents |
Responses |
Burden Hours |
Reason for change or adjustment |
|||
Current |
Previous |
Current |
Previous |
Current |
Previous |
|
|
Annual Catcher Vessel Crab EDR |
71 |
2 |
71 |
2 |
1,401 |
40 |
The number of respondents for the Catcher Vessel EDRs and Catcher/Processor EDRs were inadvertently reversed in the currently approved supporting statement. |
Annual Catcher/Processor Crab EDR |
2 |
75 |
2 |
75 |
40 |
1,482 |
The number of respondents for the Catcher Vessel EDRs and Catcher/Processor EDRs were inadvertently reversed in the currently approved supporting statement. |
Annual Processor Crab EDR |
22 |
22 |
22 |
22 |
292 |
310 |
|
Verification of Data |
20 |
99 |
20 |
99 |
160 |
792 |
Fewer verifications of data are expected because automated validation routines now allow PSMFC to identify most errors and obtain corrections from submitters shortly after EDRs are submitted. |
Total for Collection |
952 |
992 |
115 |
198 |
1,893 |
2,624 |
|
2 The total respondents for the collection consists of unique entities only. Some respondents submit an EDR and a verification of data; therefore, the number of unique entities is used to show the estimated annual number of individual participants who are expected to submit information during the 3-year renewal period for this ICR.
|
|
Labor Costs |
Miscellaneous Costs |
Reason for change or adjustment3 |
||
Current |
Previous |
Curren4 |
Previous |
|
||
Annual Catcher Vessel Crab EDR |
|
$0 |
$0 |
$231,348 |
$6,242 |
Corrected the number of respondents (due to previous reversal of catcher vessel and catcher/processor numbers) and increased photocopy cost. |
Annual Catcher/Processor Crab EDR |
|
$0 |
$0 |
$6,607 |
$244,575 |
Corrected the number of respondents (due to previous reversal of catcher vessel and catcher/processor numbers) and increased photocopy cost. |
Annual Processor Crab EDR |
|
$0 |
$0 |
$48,246 |
$51,163 |
Increased number of respondents submitting the certification page (see table above), and increased photocopy cost. |
Verification of Data |
|
$0 |
$0 |
$26,460 |
$16,434 |
Decreased number of verifications of data (see table above) and increased photocopy cost. |
Total for Collection |
$0 |
$0 |
$312,661 |
$318,414 |
|
|
3 Photocopy cost per page increased from $0.05 to $0.15.
16. For collections whose results will be published, outline the plans for tabulation and publication.
An annual summary of crab EDR data is prepared as part of the Economic Status of the Bering Sea and Aleutian Islands King and Tanner Crab Fisheries off Alaska. This is an annual publication of the NMFS Alaska Fisheries Science Center (AFSC) that is provided to the public via the AFSC’s website and is presented to the North Pacific Fishery Management Council’s Crab Plan Team and Scientific and Statistical Committee. Statistics on harvesting and processing activity; effort; revenue; labor employment and compensation; operational costs; and quota ownership, usage and disposition among participants in the fisheries are provided.
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.
The expiration date will be displayed on all instruments.
18. Explain each exception to the certification statement.
There are no exceptions for compliance with provisions in the certification statement.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-01-16 |