Socioeconomic Research and Monitoring Program for the Florida Keys National Marine Sanctuary: Recreation/Tourism in the Florida Keys - A Ten-year Replication
ICR 200612-0648-005 · OMB 0648-0572 · Historical Active
Socioeconomic Research and Monitoring Program for the Florida Keys National Marine Sanctuary: Recreation/Tourism in the Florida Keys - A Ten-year Replication
New collection (Request for a new OMB Control Number)
In accordance with 5 CFR 1320.10(c), at the formal request of the agency, OMB assigns an OMB Control Number to this collection, valid for one year. However, this approval does not represent an assessment by OMB that this information collection satisfies the principles of the PRA. OMB continues to have serious concerns about the practical utility of this collection due to questions about the soundness and appropriateness of the methods employed in the collection. NOAA has also not provided sufficient justification for the burden being imposed on the public for some components of this collection. Some of the specific concerns and issues include the following:
1. It is unclear why the 10-year retrospective on the tourism/recreation survey has been expanded to include additional surveys on "Global Climate Change and Coral Bleaching," "Coral Ecosystem Services: Societal Preferences and Policy/Management," and "Florida Reef Resiliency Program." NOAA has not justified why these surveys are being included with the 10-year retrospective, nor has NOAA described clearly which components of ICR pertain to 10-year retrospective.
2. NOAA fails to discuss the analytical methods that will be used to analyze the data gathered through this ICR. Without sufficient discussion, the evaluation of the practical utility of the information is not possible.
3. The resident and visitor surveys are extensive as currently written, but there is little emphasis on surveying businesses. NOAA does not explain the relative lack of focus on the business community.
4. Resident surveys
Respondents are asked to recall and provide highly detailed information on recreational activities including activities by location, type of activity, number of days, etc. NOAA has not provided results from pretesting or other research that respondents are able to recall and report this information accurately.
The nature of the good being valued in the contingent valuation questions is not discussed. NOAA also fails to discuss how the bid amounts are generated. There is no discussion in the supporting statement on how the data from these questions will be analyzed.
No information is provided on the coverage or quality of the sampling frames for the resident survey of Monroe County.
5. Visitor surveys (auto, air and cruise ships)
Respondents are asked to recall and provide detailed information on expenditures. NOAA has not provided results from pretesting or other research that respondents are able to recall and report this information accurately.
6. Visitor CUSTOMER surveys.
Substitution surveys:
Sampling for the CUSTOMER survey does not use sound statistical methodology that can be generalized to the universe of study in violation of (5 CFR 1320.5(d)(2)(vi) .
Respondent's "favorite" and "most common" reefs may not be interchangeable. NOAA has not provided pretesting results that demonstrate that these terms are interchangeable.
The answer categories in the hypothetical behavior questions are forced to be artificially mutually exclusive. NOAA fails to discuss the basis for this design.
There is no discussion on how the hypothetical behavior data will be analyzed. The data seem suited to be used in RUM, but no such discussion is provided.
With the conjoint questions, NOAA fails to discuss the results from pretesting that evaluated the appropriateness of the design and the design values.
NOAA did not discuss the potential impact of the length of the questionnaire on data quality due to respondent fatigue or satisficing behavior. NOAA has not provided the results from pretesting on this issue.
On-site survey:
Respondents are asked to recall and provide detailed information on expenditures. It¡¦s not clear whether NOAA conducted pretests or other research to ensure that the respondents are able to recall and report this information accurately.
Coral bleaching survey:
What are the bases for the policy scenarios described in the conjoint questions? Also, are the respondents likely to believe the policy scenarios? Please report pre-test results. What are the bases for design values in the policy scenarios?
7. Questionable research protocols are use to recruit respondents without discussion of alternatives: Using off-duty police officers to force sampled vehicles to leave the highway and enter a parking lot where they are solicited to participate in the voluntary survey seems coercive and ethically questionable.
The expected response rates are low, and NOAA's plans to analyze non-response bias focus solely on demographic factors, not key substantive variables from the surveys.
8. Burden level seems excessive and was inadequately justified.
The design calls for sampling more than a quarter of the households in Monroe county with responses expected from more than 13% . It is not clear why such a high fraction of the population should be burdened with this collection.
In general, clear precision requirements were not provided to justify the sample sizes. Sample sizes were described as exceeding "those achieved in previous studies" and exceeding by 50% or more the minimum requirements set by Dr. Chi-OK Oh, the designer of the choice experiment. No justification was provided for why it is necessary to exceed these levels and impose this greater level of burden on the public.
9. NOAA notes in Supporting Statement Part B (4) that this ICR requires no pretesting since some of the questionnaires are replication of past work and NOAA is relying on past experiences to inform new questionnaires. OMB disagrees with this assessment. This ICR is introducing new questionnaires with concepts not present in the previous surveys (e.g., Coral reef bleaching), and the environment in which the surveys are being conducted have changed significantly (e.g., declining response rates for some modes) to warrant new pretests.
10. The ICR does not discuss the relevant Institutional Review Board (IRB) review, and approval by University of Massachusetts-Amherst. If the ICR is revised in any way in response to the IRB review, including changes to methodologies or instruments, DOC/NOAA must resubmit the ICR for review.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
11/30/2008
36 Months From Approved
25,498
0
0
10,539
0
0
0
0
0
This is an approximate ten-year replication of the study "Linking the Economy and Environment of the Florida Keys/Florida Bay" which established baseline measurements for recreation/tourist uses of the Florida Keys National Marine Sanctuary (FKNMS). The baseline measurements were taken in 1995-96 for the broader recreation/tourist uses, while for reef use the baseline measurements were taken in 2000-2001. Baseline measurements were taken on number of users and recreation/tourist uses of the Florida Keys, along with estimates of economic value of resource use, economic impact associated with these uses on the local and regional economies, importance/satisfaction ratings for 25 natural resource attributes, facilities and services, and demographic profiles of users. This application also includes establishment of new baselines for knowledge, attitudes & perceptions of Sanctuary management strategies and regulations for recreation/tourist user groups, adds evaluations of management alternatives for coral reefs, and adds information that will support better predictions of how users will respond to management/regulations.
US Code:
16 USC 1431
Name of Law: National Marine Sanctuaries Act
This is a new information collection with a maximum estimate of 25,498 responses and 10,539 hours. There are no costs other than time, for the respondents.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Visitor CUSTOMER surveys
FKNMS SS Part B AND REFERENCES.pdf
Visitor CUSTOMER surveys