NCBF Demand for Electronic Signature Support

Since one of NOAA's main objectives is the protection and preservation of marine resources, the various permit programs were started to collect information about the various entities using these resources. Most of the paper application forms that are used by the various NMFS Regional Offices to collect this information ask applicants for their signature. The signatures on these permit application forms are used not only to confirm the identity of the applicant but also to provide evidence of deliberation and informed consent that the information placed on the application form is true, accurate, and complete in the event a dispute arises and the government needs to protect its interests.

Online logbooks are created (is this really true that there is no reengineering?) are made to mirror a paper equivalent to ensure that electronic logbook applications are collecting the same information as the current paper logbook process. In order for NMFS to be able to protect its interests and switch over to an electronic process for collecting logbook data, NMFS needs an electronic signature solution that ties an end user's identity to the logbook data that that has been submitted. Also, any logbook submission must include an attestation that the end user submitted the information willfully and attested that the information submitted was true, accurate, and complete at the time of the signing.

While the business case to use e-signatures for electronic logbooks might be compelling for NFMS, it is not as clear for end-users. By definition, the end users for this application are not commercial and will use the logbook on a potentially irregular basis. Participation could be 50 to 5,000 vessels.  Even though there is a regulatory mandate for this reporting, it is unclear what down side risk the end-users perceive for non-compliance. Even though an electronic logbook might be more convenient that paper logbooks, it's not clear what will motivate end users to participate voluntarily in electronic reporting. Because the user base is relatively small and the transaction might be infrequent, there is no expectation that third parties, especially commercial software developers, will attempt to intermediate the submission process between the end users and NFMS. This is especially true since NFMS is providing a free-standing, web-based solution. (Still need validation on this point).