Omnibus Industry-Funded Monitoring Amendment Management Alternatives Under Consideration PDT/FMAT Report By Melissa Hooper Observer Policy Committee Meeting August 19, 2014
Purpose and Need • Allow Councils to implement IFM programs when limited Federal funding • Allow Councils and NMFS to prioritize available Federal funding among FMPs • Enhance monitoring of at-sea catch of herring, mackerel, river herring, shad, other species in the herring and mackerel fisheries
Action Alternatives • Omnibus Alternatives – Alternative 1: No action – Alternative 2: Industry-funded Monitoring Programs • Herring Alternatives – Alternative 1: No action – Alternative 2: Industry-funded observer program for herring fishery • Mackerel Alternatives – Alternative 1: No action – Alternative 2: Industry-funded observer program for mackerel fishery
Omnibus Alternatives • Alt. 1 No Action – Status quo, NMFS evaluates IFM programs on case-by-case basis • Alt. 2 Industry Funded Monitoring Programs – General requirements for programs – Cost responsibilities – General provider standards – IFM programs frameworkable – Sub-options for a prioritization process
Omnibus Alternative 2 NMFS Costs Industry Costs Facilities and labor for training Program management and debriefing Certification Equipment Vessel selection Salary and per diem for training and debriefing Data processing Deployments and sampling Compliance and safety liaison All other costs
Omnibus Alternative 2 • SBRM amendment contains “observer” provider standards • Omnibus would add general provider standards for at-sea, dockside, EM • Different educational requirements for ASMs vs. observers, have not been a cost savings – Does Committee support carrying forward SBRM observer standards? – Should omnibus standards supersede groundfish ASM standards?
Prioritization Sub-Options General Approach: • Individual FMPs specify coverage targets and what happens when funding not sufficient • An annual prioritization process used to determine actual coverage rates for each FMP based on Federal non-SBRM funding • Allows NMFS to approve monitoring proposals contingent upon funding • Process addresses both New England and Mid- Atlantic FMPs
Red Crab Funding Needs at-sea monitoring Prioritization Fluke Process dockside monitoring $$$ Herring observer Funding Allocation coverage
Prioritization Sub-Options Alt. 2.1/2.2 Discretionary Process 1. NMFS or PDT develops proposed allocation of resources across FMPs. a. If funding is sufficient, fully implement coverage targets for all FMPs. b. If funding is not sufficient, prioritize among FMPs using certain criteria. 2. At joint meeting, NMFS and Councils discuss recommendation, make modifications 3. NMFS presents final coverage levels to Councils at a public meeting
Begin January Year 1 End March Year 2 PDT/NMFS 30-day cooling off NMFS receives develop period budget recommendation Joint NMFS publishes Determine IFM prioritization final rule coverage levels meeting NMFS publishes 30-day public Begin IFM proposed rule comment period coverage
Prioritization Sub-Options • Alt. 2.1/2.2 Discretionary process Pros Cons Discretion over funding Complexity and workload priorities Takes objectives and context Changes from year-to-year into account Requires rulemaking Timeline > 1yr
Prioritization Sub-Options Formulaic alternatives: Alt. 2.3 Proportional Prioritization Process • Alt. 2.4 Cost-based Prioritization Process • Alt. 2.5 Coverage ratio-based Prioritization • Process
Begin October Year 1 End March Year 2 NMFS prepares analysis of seaday needs NMFS identifies Begin IFM funding needs coverage NMFS receives Determine IFM budget coverage levels
Alt. 2.3: Proportional Prioritization Amount of shortfall deducted from each FMP’s allocation, proportional to its share of funding need. Example: If there is a 20% shortfall, each monitoring program would operate at 80% funding. Could result in insufficient funding for all programs
Alt. 2.4: Cost-based Prioritization Sequentially eliminate FMP with highest funding need until available funding meets need. Example: Total available funding = $8M FMP 1 needs $1M gets eliminated FMP 2 needs $500K gets $500K FMP 3 needs $250K gets $250K Could eliminate most important program
Alt. 2.5: Coverage ratio-based Prioritization Sequentially eliminate FMP with highest ratio of projected coverage days needed to days fished in previous year. Example: FMP 1 ratio 100 days/500 days = 0.2 FMP 2 ratio 50 days/500 days = 0.1 FMP 3 ratio 50 days/100 days = 0.5 FMP 3 eliminated, FMP 1 and 2 funded
Prioritization Sub-Options Formulaic alternatives: Pros Cons Complexity and workload in No discretion original FMP action Shorter timeline Could underfund all or most important programs Adaptive to budget changes and Blunt instrument timing
Prioritization Sub-Options • Additional PDT work to develop additional sub-option similar to Alt. 2.1/2.2 with a weighting scheme in omnibus – Combination discretionary/formulaic – Make changes frameworkable
What does this mean for groundfish and scallops? • Because scallop coverage “counts” toward SBRM coverage, infrastructure funded by SBRM money • Groundfish ASM infrastructure is funded by non-SBRM money, so falls under omnibus • Groundfish ASM based on a requirement, so would have to be funded first • Any new scallop or groundfish IFM program would fall under this omnibus
Omnibus Alternatives • Alternative 3 – Vessel cancellation charge to address high costs of observer deployments to trips that were cancelled without notice • Legal advice is that NMFS cannot dictate terms of private transactions PDT recommends move to CBR
Herring Monitoring Alternatives • Alt. 1 No Action – SBRM Coverage Levels – 100% observer coverage required on MWT vessels fishing in closed areas • Alt. 2 Industry-funded observer coverage – Establishes industry-funding for observer coverage above SBRM – Sub-options for coverage levels – Sunset provision
Herring Monitoring Sub-Options • Alt. 2.1 Up to 100% coverage target on Cat A & B vessels using MWT, SMBT, and purse seine gear, with waivers • Alt. 2.2 100% coverage on Cat A & B vessels using MWT, SMBT, and purse seine gear, no waivers • Alt. 2.3 Coverage up to performance standard on vessels under catch cap, with waivers • Alt. 2.4 Coverage up to performance standard on vessels under catch cap, no waivers
Year 1 Implementation • IF funding is available… – Determine funding allocations to IFM programs through prioritization process: sector ASM, sector exemptions herring, mackerel, – Set up NMFS and industry/provider infrastructure – NMFS review and approve providers – Industry contracts with providers – NMFS trains observers • Likely delayed effectiveness of coverage requirements
Year 1 Implementation • IF funding is not available … – Only SBRM coverage – Run prioritization in preparation for later fishing years • Councils could specify one-time priorities list in omnibus to save time
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