Alternative 2
Industry-funded Monitoring Omnibus Amendment Omnibus Alternatives Under Consideration By Carrie Nordeen and Aja Szumylo Observer Policy Committee Meeting December 17, 2014 1
Legal Constraints • Anti-Deficiency Act – prohibits augmenting or improperly shifting appropriations • Criminal prohibition – prohibits supplementing employee salaries • Miscellaneous Receipts Statute – requires funds be deposited in general Treasury 2
Problem Statement 1. Legal constraints prevent NMFS from sharing monitoring costs with the fishing industry. 2. Limited Federal funding for NMFS’s costs prevents NMFS from approving proposals for industry-funded monitoring programs it cannot guarantee funding to support. 3. Need to remedy disapprovals of Herring Am. 5 and Mackerel Am. 14. Need to enhance monitoring of herring, mackerel, river herring, shad, haddock, and other species. 3
Purpose and Need • Allow Councils to implement IFM programs with available Federal funding • Allow Councils and NMFS to prioritize available Federal funding among FMPs • Establish monitoring coverage targets for the Atlantic herring and Atlantic mackerel fisheries
4
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 5
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 6
Omnibus Alternative 1: No action • SBRM coverage by gear, mesh, area • Industry-funded monitoring programs are developed and evaluated on case-by-case basis • Scallops • • • •
Industry required to pay sampling costs Sampling funded by a 1% harvest set-aside Coverage addresses SBRM/ESA/MMPA requirements SBRM and ESA funding available to cover NMFS infrastructure costs
• Groundfish sectors • Monitoring required to meet a 30% CV for groundfish stock catch across sectors • 30% CV met with SBRM and ASM coverage • NMFS has paid for sampling and infrastructure costs for ASM in past years • Sectors are required to cover ASM sampling costs if NMFS cannot • If NFMS cannot cover infrastructure costs, FMP objectives cannot be met
7
Omnibus Alternative 1: No action • No standardized cost responsibilities for NMFS and the fishing industry • No framework process for FMP-specific industry-funded monitoring programs • No standardized administrative requirements for industry-funded monitoring service providers • No process to prioritize available Federal funding for industry-funded monitoring across FMPs 8
Timing of Alternative 1: No Action Year Year 1
Year 2
Month SBRM/ASM/Scallop Schedule (No Action) January to April SBRM analyses are completed late January/early February April to October
October to December
January to February
March April May
Begin analysis for SBRM and sector ASM Work on SBRM discard estimation analysis (November through early February)
Receive Year 2 budget Proposed Rule listing Sector ASM coverage rates Determine scallop compensation rate If funding shortfall, run SBRM prioritization Start of scallop Year 2 Begin Year 2 seaday schedule Final Rule listing Sector ASM coverage rates Begin Sector ASM Year 2 9
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 10
Omnibus Alternative 2: Standardized cost responsibilities NMFS Costs
Industry Costs
Facilities and labor for training and debriefing NMFS-issued gear Certification
Program management and provider overhead Salary and per diem for training and debriefing Equipment
Vessel selection
Deployments and sampling
Data processing
All other costs
Compliance and safety liaison 11
August 2014 Observer Policy Committee Motions • MOTION 4: To include for analysis…alternative that would allow for the direct contracting between a vessel/fishing business and a NMFS approved…monitoring provider to meet the coverage levels... • MOTION 5: To request…the Agency to develop a mechanism to accept outside funding for monitoring... • MOTION 6: To request…the Agency…to review the proposed division of cost responsibilities with the goal being a 50-50 cost-split... 12
August 2014 Observer Policy Committee Motions • MOTION 4: To include for analysis…alternative that would allow for the direct contracting between a vessel/fishing business and a NMFS approved…monitoring provider to meet the coverage levels... • MOTION 5: To request…the Agency to develop a mechanism to accept outside funding for monitoring... • MOTION 6: To request…the Agency…to review the proposed division of cost responsibilities with the goal being a 50-50 cost-split... 13
August 2014 Observer Policy Committee Motions • MOTION 4: To include for analysis…alternative that would allow for the direct contracting between a vessel/fishing business and a NMFS approved…monitoring provider to meet the coverage levels... • MOTION 5: To request…the Agency to develop a mechanism to accept outside funding for monitoring... • MOTION 6: To request…the Agency…to review the proposed division of cost responsibilities with the goal being a 50-50 cost-split... 14
Omnibus Alternative 2: Standardized cost responsibilities NMFS Cost Responsibilities Training and Data Processing Costs
Annual Cost (FY2013)
Facilities and labor for training and debriefing
$805,700
Data processing
$2,057,100
Certification Operational Costs
Developing and executing vessel selection
$2,244,700
Compliance and safety liaison Total
$5,107,500
15
Omnibus Alternative 2: Standardized cost responsibilities Industry Cost Responsibilities
Salary and per diem for travel, deployments and debriefing
Equipment
Cost per observed sea day (FY2013) • Sea day charges paid to providers: $640/day • Travel: $71/day • Meals: $22/day • Hourly rate: $12/hour $11/day
Costs for cancellation without notification $1/day Provider overhead and project management costs
Training: $61/day
Other costs
TBD – depends on implemented program
Total (not including other costs)
$818/day 16
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 17
Omnibus Alternative 2: Framework Adjustment Process • Details of any industry-funded monitoring program (at-sea, dockside, or electronic monitoring) would be specified/modified in a framework to the relevant FMP. • Details may include, but are not limited to: 1. 2. 3. 4. 5. 6. 7. 8.
Level and type of coverage target Rationale for level and type of coverage Minimum level of coverage necessary Consideration of coverage waivers Process for vessel notification and selection Fee collection and administration Standards for monitoring service providers Any other measures necessary 18
COMMITTEE DECISION POINT 1 • Does the Committee agree with the list of details necessary to include in the framework adjustment process? • Does the Committee have any additions to this list?
19
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 20
Omnibus Alternative 2: Monitoring Service Providers • Expanding SBRM observer service provider to apply to at-sea observer and dockside service providers for all New England and Mid-Atlantic FMPs. • Would not implement any new observer or dockside monitoring programs, only a process to approve and certify monitoring service providers. • If the Councils implement any industry-funded monitoring programs through a future action, the process to develop those monitoring programs would be streamlined. 21
COMMITTEE DECISION POINT 2 • Does the Committee agree with the outlined service provider standards for at-sea and dockside observers? • Does the Committee agree with continuing the requirement that observers have a college degree? • Does the Committee have any specific additions related to dockside observer provider standards? 22
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 23
Omnibus Alternative 2: Prioritization Process General Approach: • Individual FMPs specify coverage targets • A prioritization process used to determine actual coverage rates for each FMP based on available Federal funding • Allows NMFS to approve industry-funded monitoring programs contingent upon funding • Process addresses both New England and MidAtlantic FMPs 24
Omnibus Alternative 2: Prioritization Process • Discretionary • Alternative 2.1 – NMFS led • Alternative 2.2 – Council led
• Formulaic • Alternative 2.3 – Proportional • Alternative 2.4 – Coverage Ratio-based
25
Omnibus Alternative 2: Prioritization Process • Discretionary (Alternatives 2.1 and 2.2) Pros
Cons
Discretion over funding priorities
Complexity and workload
Takes objectives and context into account
Requires rulemaking Timeline > 1yr
26
Omnibus Alternative 2: Prioritization Process • Formulaic (Alternatives 2.3 and 2.4) Pros
Cons
Shorter timeline
No discretion
Adaptive to budget changes and timing
Blunt instrument
27
Omnibus Alternative 2: Prioritization Process • Discretionary • Alternative 2.1 – NMFS led • Alternative 2.2 – Council led
• Formulaic • Alternative 2.3 – Proportional • Alternative 2.4 – Coverage Ratio-based
28
Alternative 2.3: Proportional Prioritization If available funding cannot cover all of NMFS costs for all industry-funded monitoring programs: • The funding available to cover NMFS costs for each program would be proportionally reduced. • If there is a 20% shortfall to cover NMFS costs, each industry-funded monitoring program would be allocated 80% of available funding. • Actual coverage would be 80% of coverage target for each industry-funded monitoring program. 29
Alternative 2.4: Coverage Ratio-Based Prioritization • Sequentially eliminate FMP with highest coverage ratio • Coverage Ratio = 𝐷𝑎𝑦𝑠 𝑐𝑜𝑣𝑒𝑟𝑎𝑔𝑒 𝑛𝑒𝑒𝑑𝑒𝑑 𝑓𝑜𝑟 𝑢𝑝𝑐𝑜𝑚𝑖𝑛𝑔 𝑦𝑒𝑎𝑟 𝐷𝑎𝑦𝑠 𝑓𝑖𝑠ℎ𝑒𝑑 𝑖𝑛 𝑝𝑟𝑒𝑣𝑖𝑜𝑢𝑠 𝑦𝑒𝑎𝑟 • Prioritizes the most active fisheries, or fisheries with the fewest days of coverage needed relative to fleet activity
30
Alternative 2.4: Coverage Ratio-Based Prioritization Example: • FMP 1 - 100 days needed/500 days fished = 0.2 • FMP 2 - 50 days needed/500 days fished = 0.1 • FMP 3 - 50 days needed/100 days fished = 0.5 • FMP 3 eliminated, FMP 1 and 2 funded
31
Observer Policy Committee Recommendation from August 2014 • Committee agreed by consensus that PDT/FMAT should analyze elimination of FMPs with the lowest coverage ratio • Purpose of this approach is unclear • Is the Committee’s intent to prioritize least active fisheries, or fisheries with the greatest days of coverage needed relative to fleet activity? 32
Timing of Alternative 2: Formulaic Alternatives Year Year 1
Month
SBRM/ASM/Scallop Schedule (No Action)
Alternatives 2.3 and 2.4
January to SBRM analyses completed April January/February April to October October to Begin analysis for SBRM Begin analysis to determine December and sector ASM necessary IFM seadays Work on SBRM discard estimation (November through February) 33
Timing of Alternative 2: Formulaic Alternatives Year Year 2
Month
SBRM/ASM/Scallop Schedule (No Action) January Receive Year 2 budget to Proposed Rule for Sector ASM February coverage Determine scallop compensation rate March If funding shortfall, run SBRM prioritization Start of scallop Year 2 April Begin Year 2 seaday schedule Final Rule for Sector ASM coverage May Begin Sector ASM Year 2 June
Alternatives 2.3 and 2.4
If funding shortfall, issue funding based weighting scheme Implement Year 2 IFM coverage levels NMFS briefs Councils on final year 2 IFM seaday allocation 34
Omnibus Alternative 2: Prioritization Process • Discretionary • Alternative 2.1 – NMFS led • Alternative 2.2 – Council led
• Formulaic • Alternative 2.3 – Proportional • Alternative 2.4 – Coverage Ratio-based
35
Alternatives 2.1 and 2.2: NMFS or Council-led Prioritization 1. NMFS or Council uses weighting scheme to develop 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 36
COMMITTEE DECISION POINT 3 • For the Alternative 2.1 (NMFS-led) and Alternative 2.2 (Council-led) does the Committee agree that the best forum to develop the Council’s recommended prioritization is a joint Committee/Council meeting?
37
Alternatives 2.1 and 2.2: NMFS or Council-led Prioritization • Weighting Scheme • Based on a draft process developed by the MAFMC SSC to prioritize research proposals • Transparent, deliberative framework to decide how to allocate resources to cover NMFS costs to achieve coverage targets
38
Alternatives 2.1 and 2.2: Weighting Scheme STEP 1: NMFS/Council weigh 5 criteria • IFM Evaluation Criteria • • • • •
Stock status Ecosystem importance Strong statistical basis SBRM compatibility Risk to management
39
COMMITTEE DECISION POINT 4 • Does the Committee think that the list of 5 criteria to evaluate industry-funded monitoring programs is comprehensive? • Are there any suggested additions to this list?
40
Alternatives 2.1 and 2.2: Weighting Scheme • 5 criteria may not have equal importance • NMFS or Council assigns weights • One on one comparison to facilitate consideration of relative importance • End result is a percentage weight for each criterion (e.g., 15%)
41
Alternatives 2.1 and 2.2: Weighting Scheme Comparison values: • • • • •
1 = criteria are equally important 5 = criterion is more important 10 = criterion is much more important 0.2 = criterion is less important 0.1 = criterion is much less important 42
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
Stock status
Ecosystem importance
Strong statistical basis
Row total
IFM Criterion Weighting
Stock status
x
5
0.1
5.1
0.30
Ecosystem importance
0.2
x
1
1.2
0.07
Strong statistical basis
10
1
x
11
0.63
Grand Total
17.3 43
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
Stock status
Ecosystem importance
Strong statistical basis
Row total
IFM Criterion Weighting
Stock status
x
5
0.1
5.1
0.30
Ecosystem importance
0.2
x
1
1.2
0.07
Strong statistical basis
10
1
x
11
0.63
Grand Total
17.3 44
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
Stock status
Ecosystem importance
Strong statistical basis
Row total
IFM Criterion Weighting
Stock status
x
5
0.1
5.1
0.30
30%
Ecosystem importance
0.2
x
1
1.2
0.07
7%
Strong statistical basis
10
1
x
11
0.63
63%
Grand Total
17.3 45
Alternatives 2.1 and 2.2: Weighting Scheme STEP 2: NMFS/Council rate each IFM program • Rate each industry funded monitoring program for how much it meets each criteria • Rating scale: • • • • •
0 = doesn’t meet criterion at all 1 = slightly meets criterion 2 = somewhat meets criterion 3 = mostly meets criterion 4 = fully meets criterion 46
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
IFM Criteria IFM Criteria IFM Weighting x Weighting x Criteria FMP 1 FMP 2 FMP 1 FMP 2 Weighting Ranking Ranking
Stock status
30%
4
1.2
Ecosystem importance
7%
0
0.0
Strong objective
63%
3
1.9
IFM Program Overall Ranking
FMP 3
IFM Criteria Weighting x FMP 3 Ranking
3.1 47
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
IFM Criteria IFM Criteria IFM Weighting x Weighting x Criteria FMP 1 FMP 2 FMP 1 FMP 2 Weighting Ranking Ranking
FMP 3
IFM Criteria Weighting x FMP 3 Ranking
Stock status
30%
4
1.2
0
0.0
2
0.6
Ecosystem importance
7%
0
0.0
2
0.1
4
0.3
Strong objective
63%
3
1.9
3
1.9
1
0.6
IFM Program Overall Ranking
3.1
2
1.5 48
Alternatives 2.1 and 2.2: Weighting Scheme • FMP 1 is ranked highest, followed by FMP 2, then FMP 3 • NMFS or Councils may now use the rankings to prioritize the allocation of available funding to the FMPs to cover NMFS’s costs. • One possible way is to fully fund the highest ranked program, and then work through the ranking list sequentially. • Funding would not be allocated to a program if the available allocation would fund less than ¼ of the necessary funding. 49
COMMITTEE DECISION POINT 5 • Does the Committee agree that the highest ranked industry-funded monitoring program should receive full funding priority, with remaining funding allocated sequentially until funding is completely allocated? • Are there other ideas about how to allocate funding once the different industry-funded monitoring programs are ranked? 50
Timing of Alternative 2: Discretionary Alternatives Year Year 1
Month
SBRM/ASM/Scallop Alternatives 2.1 and 2.2 Schedule (No Action) January to SBRM analyses completed NMFS (2.1) or Council (2.2) April January/February conducts weighting scheme April to May May to October
Council and NFMS meet to review IFM program ranking Proposed and final rulemaking for IFM programs for Years 2-4 (or for indefinite period). October to Begin analysis for SBRM Begin analysis to determine December and sector ASM necessary IFM seadays Work on SBRM discard estimation (November through February) 51
Timing of Alternative 2: Discretionary Alternatives Year Year 2
Month
SBRM/ASM/Scallop Schedule (No Action) January Receive Year 2 budget to Proposed Rule for Sector ASM February coverage Determine scallop compensation rate March If funding shortfall, run SBRM prioritization Start of scallop Year 2 April Begin Year 2 seaday schedule Final Rule for Sector ASM coverage May Begin Sector ASM Year 2 June
Alternatives 2.1 and 2.2
If funding shortfall, issue funding based weighting scheme Implement Year 2 IFM coverage levels NMFS briefs Councils on final year 2 IFM seaday allocation 52
Timing of Alternative 2: Discretionary Alternatives • Option 1: Weighting scheme revised every 3 years, new/revised industry-funded monitoring programs would have to wait until the 3rd year for incorporation. • Option 2: Entire process occur on an as-needed basis. The weighting scheme is in place indefinitely until new/revised programs industryfunded monitoring programs are approved. • Option 3: Weighting scheme revised every 3 years, unless new/revised industry-funded monitoring programs are approved. 53
COMMITTEE DECISION POINT 6 • What is the Committee’s preference regarding the timing of the discretionary prioritization programs? • Every 3 years? • As-needed when new or adjusted industry-funded programs are finalized? • Every 3 years, unless there are new or adjusted industry-funded programs are finalized?
54
Preliminary Impacts Discussion Alternatives
Target Species Non-Target Species Protected Species
Human Communities
Alternative 1: No Action
Potential low negative • No additional catch monitoring
Potential low negative • Continued uncertainty about true discard rates
Alternative 2: IndustryFunded Monitoring Programs (Action Alternative)
Negligible • Cost responsibilities and framework process Potential low positive • Service provider requirements and prioritization process
Negligible • Cost responsibilities and framework process Potential low positive • Service provider requirements and prioritization process Potential negative • New cost for industry 55
Preliminary Impacts Discussion Alternatives
Alternative 2.1: NMFS-Led Prioritization Process
Target Species Non-Target Species Protected Species Human Communities Potential low positive impact • Process allows an evaluation of program need/design when assigning priority
Alternative 2.2: Council-Led Prioritization Process Alternative 2.3: Proportional Prioritization Process Alternative 2.4: Coverage RatioBased Prioritization Process
Potential low negative • Prioritization is formulaic, and does not allow for prioritization based on program need/design
56
Questions?
57
Legal Constraints • Anti-Deficiency Act – prohibits augmenting or improperly shifting appropriations • Criminal prohibition – prohibits supplementing employee salaries • Miscellaneous Receipts Statute – requires funds be deposited in general Treasury 2
Problem Statement 1. Legal constraints prevent NMFS from sharing monitoring costs with the fishing industry. 2. Limited Federal funding for NMFS’s costs prevents NMFS from approving proposals for industry-funded monitoring programs it cannot guarantee funding to support. 3. Need to remedy disapprovals of Herring Am. 5 and Mackerel Am. 14. Need to enhance monitoring of herring, mackerel, river herring, shad, haddock, and other species. 3
Purpose and Need • Allow Councils to implement IFM programs with available Federal funding • Allow Councils and NMFS to prioritize available Federal funding among FMPs • Establish monitoring coverage targets for the Atlantic herring and Atlantic mackerel fisheries
4
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 5
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 6
Omnibus Alternative 1: No action • SBRM coverage by gear, mesh, area • Industry-funded monitoring programs are developed and evaluated on case-by-case basis • Scallops • • • •
Industry required to pay sampling costs Sampling funded by a 1% harvest set-aside Coverage addresses SBRM/ESA/MMPA requirements SBRM and ESA funding available to cover NMFS infrastructure costs
• Groundfish sectors • Monitoring required to meet a 30% CV for groundfish stock catch across sectors • 30% CV met with SBRM and ASM coverage • NMFS has paid for sampling and infrastructure costs for ASM in past years • Sectors are required to cover ASM sampling costs if NMFS cannot • If NFMS cannot cover infrastructure costs, FMP objectives cannot be met
7
Omnibus Alternative 1: No action • No standardized cost responsibilities for NMFS and the fishing industry • No framework process for FMP-specific industry-funded monitoring programs • No standardized administrative requirements for industry-funded monitoring service providers • No process to prioritize available Federal funding for industry-funded monitoring across FMPs 8
Timing of Alternative 1: No Action Year Year 1
Year 2
Month SBRM/ASM/Scallop Schedule (No Action) January to April SBRM analyses are completed late January/early February April to October
October to December
January to February
March April May
Begin analysis for SBRM and sector ASM Work on SBRM discard estimation analysis (November through early February)
Receive Year 2 budget Proposed Rule listing Sector ASM coverage rates Determine scallop compensation rate If funding shortfall, run SBRM prioritization Start of scallop Year 2 Begin Year 2 seaday schedule Final Rule listing Sector ASM coverage rates Begin Sector ASM Year 2 9
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 10
Omnibus Alternative 2: Standardized cost responsibilities NMFS Costs
Industry Costs
Facilities and labor for training and debriefing NMFS-issued gear Certification
Program management and provider overhead Salary and per diem for training and debriefing Equipment
Vessel selection
Deployments and sampling
Data processing
All other costs
Compliance and safety liaison 11
August 2014 Observer Policy Committee Motions • MOTION 4: To include for analysis…alternative that would allow for the direct contracting between a vessel/fishing business and a NMFS approved…monitoring provider to meet the coverage levels... • MOTION 5: To request…the Agency to develop a mechanism to accept outside funding for monitoring... • MOTION 6: To request…the Agency…to review the proposed division of cost responsibilities with the goal being a 50-50 cost-split... 12
August 2014 Observer Policy Committee Motions • MOTION 4: To include for analysis…alternative that would allow for the direct contracting between a vessel/fishing business and a NMFS approved…monitoring provider to meet the coverage levels... • MOTION 5: To request…the Agency to develop a mechanism to accept outside funding for monitoring... • MOTION 6: To request…the Agency…to review the proposed division of cost responsibilities with the goal being a 50-50 cost-split... 13
August 2014 Observer Policy Committee Motions • MOTION 4: To include for analysis…alternative that would allow for the direct contracting between a vessel/fishing business and a NMFS approved…monitoring provider to meet the coverage levels... • MOTION 5: To request…the Agency to develop a mechanism to accept outside funding for monitoring... • MOTION 6: To request…the Agency…to review the proposed division of cost responsibilities with the goal being a 50-50 cost-split... 14
Omnibus Alternative 2: Standardized cost responsibilities NMFS Cost Responsibilities Training and Data Processing Costs
Annual Cost (FY2013)
Facilities and labor for training and debriefing
$805,700
Data processing
$2,057,100
Certification Operational Costs
Developing and executing vessel selection
$2,244,700
Compliance and safety liaison Total
$5,107,500
15
Omnibus Alternative 2: Standardized cost responsibilities Industry Cost Responsibilities
Salary and per diem for travel, deployments and debriefing
Equipment
Cost per observed sea day (FY2013) • Sea day charges paid to providers: $640/day • Travel: $71/day • Meals: $22/day • Hourly rate: $12/hour $11/day
Costs for cancellation without notification $1/day Provider overhead and project management costs
Training: $61/day
Other costs
TBD – depends on implemented program
Total (not including other costs)
$818/day 16
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 17
Omnibus Alternative 2: Framework Adjustment Process • Details of any industry-funded monitoring program (at-sea, dockside, or electronic monitoring) would be specified/modified in a framework to the relevant FMP. • Details may include, but are not limited to: 1. 2. 3. 4. 5. 6. 7. 8.
Level and type of coverage target Rationale for level and type of coverage Minimum level of coverage necessary Consideration of coverage waivers Process for vessel notification and selection Fee collection and administration Standards for monitoring service providers Any other measures necessary 18
COMMITTEE DECISION POINT 1 • Does the Committee agree with the list of details necessary to include in the framework adjustment process? • Does the Committee have any additions to this list?
19
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 20
Omnibus Alternative 2: Monitoring Service Providers • Expanding SBRM observer service provider to apply to at-sea observer and dockside service providers for all New England and Mid-Atlantic FMPs. • Would not implement any new observer or dockside monitoring programs, only a process to approve and certify monitoring service providers. • If the Councils implement any industry-funded monitoring programs through a future action, the process to develop those monitoring programs would be streamlined. 21
COMMITTEE DECISION POINT 2 • Does the Committee agree with the outlined service provider standards for at-sea and dockside observers? • Does the Committee agree with continuing the requirement that observers have a college degree? • Does the Committee have any specific additions related to dockside observer provider standards? 22
Omnibus Alternatives • Alternative 1: No action • Alternative 2: Industry-funded Monitoring Programs • Standardize cost responsibilities for NMFS and the fishing industry • Establish framework process for FMP-specific industry-funded monitoring programs • Standardize administrative requirements for industryfunded monitoring service providers • Establish process to prioritize available Federal funding for industry-funded monitoring across FMPs 23
Omnibus Alternative 2: Prioritization Process General Approach: • Individual FMPs specify coverage targets • A prioritization process used to determine actual coverage rates for each FMP based on available Federal funding • Allows NMFS to approve industry-funded monitoring programs contingent upon funding • Process addresses both New England and MidAtlantic FMPs 24
Omnibus Alternative 2: Prioritization Process • Discretionary • Alternative 2.1 – NMFS led • Alternative 2.2 – Council led
• Formulaic • Alternative 2.3 – Proportional • Alternative 2.4 – Coverage Ratio-based
25
Omnibus Alternative 2: Prioritization Process • Discretionary (Alternatives 2.1 and 2.2) Pros
Cons
Discretion over funding priorities
Complexity and workload
Takes objectives and context into account
Requires rulemaking Timeline > 1yr
26
Omnibus Alternative 2: Prioritization Process • Formulaic (Alternatives 2.3 and 2.4) Pros
Cons
Shorter timeline
No discretion
Adaptive to budget changes and timing
Blunt instrument
27
Omnibus Alternative 2: Prioritization Process • Discretionary • Alternative 2.1 – NMFS led • Alternative 2.2 – Council led
• Formulaic • Alternative 2.3 – Proportional • Alternative 2.4 – Coverage Ratio-based
28
Alternative 2.3: Proportional Prioritization If available funding cannot cover all of NMFS costs for all industry-funded monitoring programs: • The funding available to cover NMFS costs for each program would be proportionally reduced. • If there is a 20% shortfall to cover NMFS costs, each industry-funded monitoring program would be allocated 80% of available funding. • Actual coverage would be 80% of coverage target for each industry-funded monitoring program. 29
Alternative 2.4: Coverage Ratio-Based Prioritization • Sequentially eliminate FMP with highest coverage ratio • Coverage Ratio = 𝐷𝑎𝑦𝑠 𝑐𝑜𝑣𝑒𝑟𝑎𝑔𝑒 𝑛𝑒𝑒𝑑𝑒𝑑 𝑓𝑜𝑟 𝑢𝑝𝑐𝑜𝑚𝑖𝑛𝑔 𝑦𝑒𝑎𝑟 𝐷𝑎𝑦𝑠 𝑓𝑖𝑠ℎ𝑒𝑑 𝑖𝑛 𝑝𝑟𝑒𝑣𝑖𝑜𝑢𝑠 𝑦𝑒𝑎𝑟 • Prioritizes the most active fisheries, or fisheries with the fewest days of coverage needed relative to fleet activity
30
Alternative 2.4: Coverage Ratio-Based Prioritization Example: • FMP 1 - 100 days needed/500 days fished = 0.2 • FMP 2 - 50 days needed/500 days fished = 0.1 • FMP 3 - 50 days needed/100 days fished = 0.5 • FMP 3 eliminated, FMP 1 and 2 funded
31
Observer Policy Committee Recommendation from August 2014 • Committee agreed by consensus that PDT/FMAT should analyze elimination of FMPs with the lowest coverage ratio • Purpose of this approach is unclear • Is the Committee’s intent to prioritize least active fisheries, or fisheries with the greatest days of coverage needed relative to fleet activity? 32
Timing of Alternative 2: Formulaic Alternatives Year Year 1
Month
SBRM/ASM/Scallop Schedule (No Action)
Alternatives 2.3 and 2.4
January to SBRM analyses completed April January/February April to October October to Begin analysis for SBRM Begin analysis to determine December and sector ASM necessary IFM seadays Work on SBRM discard estimation (November through February) 33
Timing of Alternative 2: Formulaic Alternatives Year Year 2
Month
SBRM/ASM/Scallop Schedule (No Action) January Receive Year 2 budget to Proposed Rule for Sector ASM February coverage Determine scallop compensation rate March If funding shortfall, run SBRM prioritization Start of scallop Year 2 April Begin Year 2 seaday schedule Final Rule for Sector ASM coverage May Begin Sector ASM Year 2 June
Alternatives 2.3 and 2.4
If funding shortfall, issue funding based weighting scheme Implement Year 2 IFM coverage levels NMFS briefs Councils on final year 2 IFM seaday allocation 34
Omnibus Alternative 2: Prioritization Process • Discretionary • Alternative 2.1 – NMFS led • Alternative 2.2 – Council led
• Formulaic • Alternative 2.3 – Proportional • Alternative 2.4 – Coverage Ratio-based
35
Alternatives 2.1 and 2.2: NMFS or Council-led Prioritization 1. NMFS or Council uses weighting scheme to develop 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 36
COMMITTEE DECISION POINT 3 • For the Alternative 2.1 (NMFS-led) and Alternative 2.2 (Council-led) does the Committee agree that the best forum to develop the Council’s recommended prioritization is a joint Committee/Council meeting?
37
Alternatives 2.1 and 2.2: NMFS or Council-led Prioritization • Weighting Scheme • Based on a draft process developed by the MAFMC SSC to prioritize research proposals • Transparent, deliberative framework to decide how to allocate resources to cover NMFS costs to achieve coverage targets
38
Alternatives 2.1 and 2.2: Weighting Scheme STEP 1: NMFS/Council weigh 5 criteria • IFM Evaluation Criteria • • • • •
Stock status Ecosystem importance Strong statistical basis SBRM compatibility Risk to management
39
COMMITTEE DECISION POINT 4 • Does the Committee think that the list of 5 criteria to evaluate industry-funded monitoring programs is comprehensive? • Are there any suggested additions to this list?
40
Alternatives 2.1 and 2.2: Weighting Scheme • 5 criteria may not have equal importance • NMFS or Council assigns weights • One on one comparison to facilitate consideration of relative importance • End result is a percentage weight for each criterion (e.g., 15%)
41
Alternatives 2.1 and 2.2: Weighting Scheme Comparison values: • • • • •
1 = criteria are equally important 5 = criterion is more important 10 = criterion is much more important 0.2 = criterion is less important 0.1 = criterion is much less important 42
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
Stock status
Ecosystem importance
Strong statistical basis
Row total
IFM Criterion Weighting
Stock status
x
5
0.1
5.1
0.30
Ecosystem importance
0.2
x
1
1.2
0.07
Strong statistical basis
10
1
x
11
0.63
Grand Total
17.3 43
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
Stock status
Ecosystem importance
Strong statistical basis
Row total
IFM Criterion Weighting
Stock status
x
5
0.1
5.1
0.30
Ecosystem importance
0.2
x
1
1.2
0.07
Strong statistical basis
10
1
x
11
0.63
Grand Total
17.3 44
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
Stock status
Ecosystem importance
Strong statistical basis
Row total
IFM Criterion Weighting
Stock status
x
5
0.1
5.1
0.30
30%
Ecosystem importance
0.2
x
1
1.2
0.07
7%
Strong statistical basis
10
1
x
11
0.63
63%
Grand Total
17.3 45
Alternatives 2.1 and 2.2: Weighting Scheme STEP 2: NMFS/Council rate each IFM program • Rate each industry funded monitoring program for how much it meets each criteria • Rating scale: • • • • •
0 = doesn’t meet criterion at all 1 = slightly meets criterion 2 = somewhat meets criterion 3 = mostly meets criterion 4 = fully meets criterion 46
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
IFM Criteria IFM Criteria IFM Weighting x Weighting x Criteria FMP 1 FMP 2 FMP 1 FMP 2 Weighting Ranking Ranking
Stock status
30%
4
1.2
Ecosystem importance
7%
0
0.0
Strong objective
63%
3
1.9
IFM Program Overall Ranking
FMP 3
IFM Criteria Weighting x FMP 3 Ranking
3.1 47
Alternatives 2.1 and 2.2: Weighting Scheme IFM Evaluation Criteria
IFM Criteria IFM Criteria IFM Weighting x Weighting x Criteria FMP 1 FMP 2 FMP 1 FMP 2 Weighting Ranking Ranking
FMP 3
IFM Criteria Weighting x FMP 3 Ranking
Stock status
30%
4
1.2
0
0.0
2
0.6
Ecosystem importance
7%
0
0.0
2
0.1
4
0.3
Strong objective
63%
3
1.9
3
1.9
1
0.6
IFM Program Overall Ranking
3.1
2
1.5 48
Alternatives 2.1 and 2.2: Weighting Scheme • FMP 1 is ranked highest, followed by FMP 2, then FMP 3 • NMFS or Councils may now use the rankings to prioritize the allocation of available funding to the FMPs to cover NMFS’s costs. • One possible way is to fully fund the highest ranked program, and then work through the ranking list sequentially. • Funding would not be allocated to a program if the available allocation would fund less than ¼ of the necessary funding. 49
COMMITTEE DECISION POINT 5 • Does the Committee agree that the highest ranked industry-funded monitoring program should receive full funding priority, with remaining funding allocated sequentially until funding is completely allocated? • Are there other ideas about how to allocate funding once the different industry-funded monitoring programs are ranked? 50
Timing of Alternative 2: Discretionary Alternatives Year Year 1
Month
SBRM/ASM/Scallop Alternatives 2.1 and 2.2 Schedule (No Action) January to SBRM analyses completed NMFS (2.1) or Council (2.2) April January/February conducts weighting scheme April to May May to October
Council and NFMS meet to review IFM program ranking Proposed and final rulemaking for IFM programs for Years 2-4 (or for indefinite period). October to Begin analysis for SBRM Begin analysis to determine December and sector ASM necessary IFM seadays Work on SBRM discard estimation (November through February) 51
Timing of Alternative 2: Discretionary Alternatives Year Year 2
Month
SBRM/ASM/Scallop Schedule (No Action) January Receive Year 2 budget to Proposed Rule for Sector ASM February coverage Determine scallop compensation rate March If funding shortfall, run SBRM prioritization Start of scallop Year 2 April Begin Year 2 seaday schedule Final Rule for Sector ASM coverage May Begin Sector ASM Year 2 June
Alternatives 2.1 and 2.2
If funding shortfall, issue funding based weighting scheme Implement Year 2 IFM coverage levels NMFS briefs Councils on final year 2 IFM seaday allocation 52
Timing of Alternative 2: Discretionary Alternatives • Option 1: Weighting scheme revised every 3 years, new/revised industry-funded monitoring programs would have to wait until the 3rd year for incorporation. • Option 2: Entire process occur on an as-needed basis. The weighting scheme is in place indefinitely until new/revised programs industryfunded monitoring programs are approved. • Option 3: Weighting scheme revised every 3 years, unless new/revised industry-funded monitoring programs are approved. 53
COMMITTEE DECISION POINT 6 • What is the Committee’s preference regarding the timing of the discretionary prioritization programs? • Every 3 years? • As-needed when new or adjusted industry-funded programs are finalized? • Every 3 years, unless there are new or adjusted industry-funded programs are finalized?
54
Preliminary Impacts Discussion Alternatives
Target Species Non-Target Species Protected Species
Human Communities
Alternative 1: No Action
Potential low negative • No additional catch monitoring
Potential low negative • Continued uncertainty about true discard rates
Alternative 2: IndustryFunded Monitoring Programs (Action Alternative)
Negligible • Cost responsibilities and framework process Potential low positive • Service provider requirements and prioritization process
Negligible • Cost responsibilities and framework process Potential low positive • Service provider requirements and prioritization process Potential negative • New cost for industry 55
Preliminary Impacts Discussion Alternatives
Alternative 2.1: NMFS-Led Prioritization Process
Target Species Non-Target Species Protected Species Human Communities Potential low positive impact • Process allows an evaluation of program need/design when assigning priority
Alternative 2.2: Council-Led Prioritization Process Alternative 2.3: Proportional Prioritization Process Alternative 2.4: Coverage RatioBased Prioritization Process
Potential low negative • Prioritization is formulaic, and does not allow for prioritization based on program need/design
56
Questions?
57
