Omnibus Industry-Funded Monitoring Amendment Management - - PowerPoint PPT Presentation

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 and debriefing Program management 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.
• bservers, have not been a cost savings

– Does Committee support carrying forward SBRM

• bserver 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

Prioritization Process $$$

Fluke dockside monitoring

Herring

• bserver

coverage

Red Crab at-sea monitoring

Funding Needs Funding Allocation

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

PDT/NMFS develop recommendation Joint prioritization meeting NMFS publishes proposed rule 30-day public comment period NMFS publishes final rule 30-day cooling off period NMFS receives budget Determine IFM coverage levels Begin IFM coverage

Begin January Year 1  End March Year 2

Prioritization Sub-Options

• Alt. 2.1/2.2 Discretionary process

Pros Cons Discretion over funding priorities Complexity and workload Takes objectives and context into account Changes from year-to-year 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

NMFS prepares analysis of seaday needs NMFS identifies funding needs NMFS receives budget Determine IFM coverage levels Begin IFM coverage

Begin October Year 1  End March Year 2

• 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

• riginal FMP action

No discretion Shorter timeline Could underfund all or most important programs Adaptive to budget changes and timing Blunt instrument

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
• f 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
• n vessels under catch cap, with waivers
• Alt. 2.4 Coverage up to performance standard
• n 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