Comment from Persistence Analytics Group LLC

Comment on NOAA-NMFS-2025-0570-0024 Electronic Logbook Reporting in Commercial Fisheries of the Gulf of America and Atlantic Persistence Analytics Group LLC / United Grid submits this comment regarding the proposed rule requiring certain commercial fishing logbooks in the Gulf of America, South Atlantic, and Atlantic to be submitted electronically rather than through the current paper format. PAG / United Grid supports the objective of improving the accuracy, timeliness, usability, and efficiency of fisheries data. Reliable data are essential to responsible resource management, stock assessment, enforcement, economic analysis, bycatch monitoring, and long-term public trust. However, the success of this proposed rule should not be judged only by whether reporting becomes electronic. It should be judged by whether electronic reporting produces reliable, usable, secure, and decision-grade evidence without creating avoidable burden, compliance risk, system fragility, or unfair enforcement exposure for commercial fishermen and small operators. The proposed rule rests on several implementation assumptions that should be verified before obligations harden: 1. Data accuracy NMFS expects electronic reporting to improve accuracy and reduce interpretation errors. NMFS should monitor incomplete submissions, corrected reports, software validation errors, user disputes, and actual data-quality improvements compared with paper reporting. 2. Reporting burden NMFS states that burden estimates are not expected to change. That assumption should be tested after implementation, including training time, technical-support needs, device access, software usability, account setup, and submission difficulties. 3. Digital access and system reliability The rule assumes that vessel owners and operators will have workable access to devices, software, internet, power, and support. The final rule should include clear procedures for poor connectivity, device failure, software outages, password/account problems, power loss, and delayed uploads. 4. Redundant reporting NMFS identifies reporting overlap across Federal programs and notes efforts to streamline requirements. The final rule should include a clear path toward reducing duplicative reporting for vessels subject to multiple Federal or regional systems. 5. Enforcement fairness Operators should not be penalized for good-faith reporting failures caused by approved software problems, connectivity gaps, catastrophic conditions, unclear instructions, or platform outages. NMFS should provide safe-harbor procedures where good-faith compliance can be documented. 6. Data governance Electronic reporting increases the importance of protecting commercially sensitive information. NMFS should clearly state who may access the data, how long data will be retained, how data may be shared, and how cybersecurity risks will be managed. 7. Vendor accountability If NMFS-approved software vendors are part of the compliance pathway, vendor performance becomes part of the regulatory system. NMFS should require help-desk availability, service standards, outage reporting, user guidance, and continuity procedures. 8. Catastrophic-condition relief The proposed rule allows reporting deadlines to be modified or waived during catastrophic conditions. The final rule should clarify notification, documentation, and relief procedures when communications infrastructure is disrupted. PAG / United Grid recommends that NMFS finalize the rule only with an implementation-integrity framework that includes: * a phased transition period; * written training and outreach materials; * software and vendor support standards; * safe-harbor procedures for good-faith failures; * post-implementation burden review; * data-quality performance metrics; * cybersecurity and data-governance safeguards; * and a public review after implementation evaluating whether electronic reporting improved accuracy, timeliness, compliance, and administrative efficiency. The broader principle is simple: Digital reporting should not be treated as successful merely because data collection moves from paper to software. It should be treated as successful only if the system produces reliable, usable, secure, timely, and auditable data while minimizing unnecessary burden on regulated parties. Modernization should produce decision-grade evidence, not merely additional compliance activity. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity SAM.gov registered UEI: D3VYU39H6DX9 D-U-N-S: 142849930 CAGE: 19T34 neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/