Supplemental Questions

SUPPORTING STATEMENT

WEST COAST OPEN ACCESS GROUNDFISH, NONTRIBAL SALMON,

CRAB AND SHRIMP ECONOMIC DATA COLLECTION

OMB CONTROL NO.0648-0369T

Project Title: West Coast Open Access Groundfish, Non-tribal Salmon, Crab, and Shrimp 2013 Economic Data Collection

Justification under OMB Generic Clearance:

(Economic Survey of US Commercial Fisheries, OMB Control No. 0648-0369)

This request is for a one-time survey of vessel owners participating in the West Coast open access groundfish, non-tribal salmon, crab, and shrimp fisheries. The survey content is based on previously approved categories as outlined in the generic clearance (0648-0369) supporting statement.

Commercial fisheries economic data collection projects implemented by the Northwest Fisheries Science Center (NWFSC) have contributed to legally mandated analyses required under the Magnuson-Stevens Fishery Conservation and Management Act (MFCMS), the National Environmental Policy Act (NEPA), the Regulatory Flexibility Act (RFA), and Executive Order 12866 (E.O. 12866). Economic data collection has also supported analysis of the size and distribution of economic benefits used in fisheries management, such as economic analysis of the groundfish trawl catch shares program presented in the trawl rationalization Environmental Impact Statement (EIS).

Surveys implemented since 2005 have covered West Coast harvesters, processors, and coastal communities. These surveys have focused on the federally managed groundfish and salmon fisheries as well as the closely related state managed crab and shrimp fisheries. This document describes a data collection covering those harvesting vessels that participate in the open access groundfish, non-tribal salmon, crab, and shrimp fisheries. Data on revenues derived from vessel operations, costs incurred through vessel operations, vessel operating characteristics, and crew compensation will be collected for the 2011 and 2012 vessel fiscal years. This survey updates previously collected data for the 2008 and 2009 vessel fiscal years.

This survey collects data which can be used to calculate economic performance measures, perform economic analysis, and estimate the size and distribution of economic benefits derived from fishery resources.

Responses to Supplemental Questions for PRA Clearance

OMB Review of Individual Instruments

1. The potential respondent universe and any sampling or other respondent selection method to be used and the expected response rate.

Potential Respondent Universe

The population of interest for this survey is all non-tribal commercial fishing vessels with (1) at least $1,000 of West Coast landings during 2012, (2) no limited entry groundfish permit during 2012, and (3) at least 33% of West Coast landings revenue during 2012 from groundfish, salmon, crab, or shrimp (hereafter this survey is referred to as the “open access survey” for simplicity even though it includes vessels participating in three other fisheries). Because landings data for the complete 2012 calendar year is not yet available, the vessel counts presented in this document are based on landings during 2011. There were 1,680 vessels in the survey population during 2011.

Sampling and Other Respondent Selection Methods

This survey sample will include all 1,680 members of the survey population. Each of the 1,680 members of the survey population will be a member of either the telephone sample or the non-telephone sample, based on availability of a telephone number. Because telephone numbers are not available for members of the survey population through vessel registration records or permit records, telephone numbers will be obtained through a public records search. The public records search for vessel owner telephone numbers will be based on vessel owner name and address information obtained from Coast Guard and state vessel registration records. Based on previous experience, the NWFSC expects to obtain telephone numbers for 60% of the vessels in the survey population. As a result, the telephone sample is expected to include approximately 1,008 vessel owners and the non-telephone sample is expected to include approximately 672 vessel owners.

Tests for statistically significant differences in vessel physical characteristics (such as length and engine horsepower) and West Coast landings (by species, weight of landings, revenue from landings, and port of landings) will compare vessels in the telephone and non-telephone samples. Data on vessel physical characteristics is available for vessels in the survey population from vessel registration data, and data on West Coast landings is available for all vessels in the survey population from PacFIN (the Pacific Fisheries Information Network). As a result, it is possible to compare vessels in the telephone sample and non-telephone sample with regard to seasonal patterns, species landed, and location of landings. Comparison of vessels in the telephone sample and non-telephone sample of the previous open access survey using vessel Fiscal year 2008 and vessel Fiscal year 2009 data did not find any statistically significant differences between the two samples.

Expected Response Rate

The expected response rate differs for vessel owners in the telephone sample and vessel owners in the non-telephone sample, as having a telephone number for the vessel owner makes it possible to recruit survey participation over the telephone. The previous open access survey conducted by the NWFSC and the Pacific States Marine Fisheries Commission (PSMFC) obtained a 59% response rate for vessel owners in the telephone sample and a 23% response rate for vessel owners in the non-telephone sample. Because the survey described in this document has a similar survey population and similar survey fielding protocols, the response rates obtained during the previous survey are the most reliable predictor of response rates for this survey. These response rates imply 595 responses from vessel owners in the telephone sample and 155 responses from vessel owners in the non-telephone sample, for a total of 750 survey responses

2. Data collection procedures, including the statistical methodology for stratification and sample selection, the estimation procedure, the degree of accuracy needed for the intended purpose, expected dates of survey implementation, and any unusual problems requiring specialized sampling procedures.

Stratification and Sample Selection

The population of interest for this survey is all non-tribal commercial fishing vessels with (1) at least $1,000 of West Coast landings during 2012, (2) no limited entry groundfish permit, and (3) at least 33% of West Coast landings revenue from groundfish, salmon, crab, or shrimp landings. Active fishing vessels are defined as having at least $1,000 of West Coast (Washington, Oregon, and California) landings during 2012. Each of the 1,680 vessels in the survey population is allocated to either the telephone sample or the non-telephone sample, depending on whether or not a telephone number is available for the vessel owner. All 1,680 vessels in the population will receive the survey.

Desired Accuracy Needed for the Intended Purpose

Important objectives of survey design include data accuracy and data precision. Data precision is discussed in the next sub-section. Measuring and minimizing non-response bias (an important aspect of assuring accurate data) is addressed under Question 3. The degree of accuracy needed is not established by economic theory or legislative mandates. Data collected through this survey will be used for both statistical inference of population values from sample respondents and for estimation of econometric models used for fisheries management. While more accurate data is clearly preferred, standards do not exist regarding the accuracy of data required for estimation of an econometric model. Factors such as the minimization of model specification error also affect the quality of the empirical results obtained using survey data. It is not possible to state a level of accuracy that is required for all uses and applications of data collected by this survey. As discussed in the response to Question 3, data on vessel characteristics and landings (location, timing, species, weight, and revenue) is available for both survey respondents and non-respondents, and will be used to test the representativeness of survey respondents. This data will also be used to adjust the models and/or data for any response bias that is detected.

Desired Precision and Response Rate

The desired degree of precision, and corresponding desired response rate, depends upon the application for which the data is being used. Some applications may use data from all survey respondents, while others applications will only use data from vessels that operate in specific fisheries or geographic locations. A basic application of the survey data will be the inference of population mean values from the respondent’s mean values. While the NWFSC do not have any information about the cost variables which will be collected in the survey, the NWFSC does already know revenue from West Coast landings for all members of the survey population. Using this revenue data, we can calculate the number of vessels from which revenue data would be needed in order to infer revenue for the entire population of vessels, based on the mean value and variation in revenue across vessels. The following table shows the number of responses (and corresponding response rate) needed to get a response sample mean for per vessel landings revenue within 10%, 15%, and 25% of the population mean of per vessel annual landings revenue at the 95% confidence level. In this calculation, revenues associated with West Coast landings (which are known for all vessels) are used as a proxy for revenues from other sources and for expenditures (which are not known and are the focus of this survey).

N Population	N 10%	N 15%	N 25%	Response Rate 10%	Response Rate 15%	Response Rate 25%
1680	826	505	225	49%	30%	13%

As shown in the accompanying table, having a sample mean within 15% of the population mean at the 95% confidence level requires 505 responses (a response rate of 30%). Since 750 responses are expected, this survey is expected to provide estimates within 15% of survey population means at the 95% confidence level. At least two reasons can be identified for desiring higher response rates than those needed to support inference of population means from sample means:

1. Data from this survey will be used to develop a variety of economic models covering applications such as fleet efficiency and fishery participation. In these applications, error will arise not only from the representativeness of data used for model development, but also from model specification and estimation. Since it is not possible to completely avoid specification and estimation error in model development, there is good reason to desire a higher response rate and higher degree of accuracy in the data collection process.

2. Future applications of the data may require further disaggregating the population into smaller groups according to factors such as state of operation or species targeted. Identification of all such future disaggregated data needs is not possible at the present time. A higher response rate and higher degree of accuracy in the current data collection process will facilitate such future population disaggregation.

Survey Fielding

The PSMFC and its subcontractors will field the survey. For the 1,008 members of the telephone sample, the PSMFC will send an initial mailing with a cover letter, a copy of the questionnaire, and an explanation of how data collected by the survey will be used by economists. This will provide survey recipients with an opportunity to (i) see first-hand the data being collected by the survey prior to in-person interviews and (ii) collect the requested data prior to the in-person interview. About one week after the initial mailing, attempts to contact all non-respondents via telephone will begin. These calls will be made by an expert recruiter with the objective of getting the survey recipient to agree to participate in the survey, and determining the response method (in-person interview, telephone interview, on-line response, or mail response). For those choosing an in-person interview, an interview time and location will be scheduled. For those choosing a telephone interview, an interview time will be scheduled.

The 672 members of the non-telephone sample will receive an initial mailing that includes a letter describing the survey and its purpose. The initial mailing will also include a copy of the questionnaire and a self addressed stamped envelope for returning the questionnaire. The letter will also contain instructions for completing the survey using an on-line questionnaire. Each letter will provide the vessel owner with a unique personal identification number (PIN) which must be entered into the on-line survey. About two weeks after the mailing, PSMFC will send a reminder letter to all non-respondents. A second reminder letter will be sent about four weeks after the initial mailing to non-respondents. A copy of the questionnaire will be included in each reminder letter.

Expected Dates of Survey Implementation

Seasonal patterns of activity vary by vessel, depending upon the species targeted most frequently and geographic location. Vessels targeting groundfish are most active during the summer months while crabbers are most active between December and February. The period between March 1 and May 31 avoids peak season for most members of the survey population. The target period for survey fielding is March, April, and May 2013.

3. The methods used to maximize response rates and address non-response. The accuracy and reliability of the information collected must be shown to be adequate for the intended uses.

Methods Used To Maximize Response Rates

A number of methods were used to maximize survey response during the previous open access survey, and will also be used during this survey:

1. Respondents are asked to provide information not available from other sources.

2. All members of the survey population for whom a telephone number is available will have the opportunity to respond through an in-person interview. In-person interviews typically have higher response rates than mail surveys, telephone surveys, or on-line surveys.

3. All members of the survey population for whom a telephone number is not available will have the option of responding on-line as well as by returning a written questionnaire in a self-addressed stamped envelope.

4. There will be extensive follow-up telephone calls and mailings after the initial letter/questionnaire mailing in order to schedule in-person interviews and obtain responses from vessel owners in the telephone sample. These follow-up telephone calls to non-respondents in the telephone sample will be distributed among weekend/weekday and day/evening time periods to maximize the likelihood of reaching the contact person. About one week after the questionnaire is mailed to all members of the telephone sample, attempts to schedule in-person interview dates by telephone will begin. Up to twelve attempts to schedule an interview will be made for each member of the in-person survey.

5. Up to three attempts (including the initial mailing) will be made to obtain responses from each member of the non-telephone sample. .

Addressing Non-Response

Testing for non-response bias will be based on the considerable amount of data that is available for all members of the survey population. Variables that will be used for non-response bias testing fall into the categories of vessel physical characteristics and vessel landings.

Vessel physical characteristics provide an indication if whether the data collected through the survey on fixed cost items such as repair, maintenance, and improvements is likely to differ for survey respondents and survey non-respondents. Other vessel characteristics such as engine horsepower indicate whether variable costs such as fuel consumption vary between survey respondents and non-respondents.

Tests for non-response bias will be based not only on vessel physical characteristics, but also on vessel landings. PacFIN (Pacific Fisheries Information Network) provides vessel level information on West Coast (Washington, Oregon, and California) landings by date, species, and port for all vessels in the survey population. As a result, it is possible to compare respondents and non-respondents with regard to seasonal patterns, species landed, and location of landings.

Data on vessel landings makes possible a comparison between respondents and non-respondents of species targeted, location of landings, and gear type. Available landings data will allow testing for differences between respondents and non-respondents for total dollar value and weight of landings, dollar value and weight of groundfish landings, dollar value and weight of whiting landings, dollar value and weight of crab landings, dollar value and weight of shrimp landings, and dollar value and weight of salmon landings.

If non-response bias is detected, procedures will be used to reweight the data or the estimated model to correct for any known bias.

Adequacy of Accuracy and Reliability of Information for Intended Uses

National Marine Fisheries Service (NMFS) needs to measure the economic performance of West Coast commercial fisheries in order to meet legal and regulatory requirements, support fisheries management decision making, and undertake economic research. Currently available cost earnings data for 2011 and 2012 from non-survey sources is very limited and does not meet these needs. The NWFSC’s Cost Earnings Program will collect the additional data that is needed to construct key economic performance measures such as profitability, productivity, and economic impacts. The data gathered and performance measures constructed will be used to address a wide range of issues. While the data will be used to comply with legal and regulatory requirements, these requirements do not specify a level of data accuracy.

4. How the survey instrument was developed, including the steps taken to validate the questionnaire design.

The survey instrument is an updated version of the survey instrument used for the previous open access survey. Since the survey development process for the prior surveys has already been documented in prior OMB submissions, it is provided in a footnote in this document.¹

The process of reviewing and updating the previous questionnaire began with distribution of the previous questionnaire to a group of economists and survey researchers employed by the National Oceanic and Atmospheric Administration’s (NOAA’s) NWFSC, NOAA’s Northwest Regional Office (NWR), NOAA’s Southwest Fisheries Science Center (SWFSC), and the Pacific States Marine Fisheries Commission (PSMFC). Because data from the open accesss survey will be used with data from the mandatory EDC (Economic Data Collection) survey of catcher vessels in the limited entry groundfish trawl fishery and the voluntary limited entry groundfish fixed gear survey, the questionnaires used in for these surveys were also examined to insure that data gathered by this open access survey could be combined with data from previous surveys.² Key changes to the questionnaire since the previous open access survey include (i) revising the cost categories to match those used on the mandatory groundfish trawl economic data collection (EDC) catcher vessel questionnaire, (ii) including tendering as a possible source of revenue (in response to comments received during the previous open access survey), and (iii) adding a question about days at sea in various fisheries (this information will be used to allocate joint costs to individual fisheries).

5. The reporting and use of the results of the survey.

Use of Survey Results

NMFS needs to measure the economic performance of West Coast commercial fisheries in order to meet legal and regulatory requirements, support fisheries management decision making, and undertake economic research. The NWFSC’s Cost Earnings Program is an on-going program that collects data, which when combined with other existing sources of data, provides data that is needed to construct key economic performance measures such as profitability, capacity utilization, efficiency, productivity, and regional economic impacts. Analysis of data collected by previous surveys conducted by the NWFSC and PSFMC has played a key role in evaluating the likely impact (in terms of vessel consolidation and cost reduction) of implementing a catch share management regime in the limited entry trawl fishery, the economic impact of the 2006 reductions in salmon harvest on the economic welfare of fishery participants, and the development of an IMPLAN based regional economic model for evaluation the effect of fishery management measures on economic conditions in coastal communities.

Reporting of Survey Results

A descriptive summary of results from the survey will be prepared and posted on the NWFSC web site. This summary will include descriptive statistics (such as mean and standard deviation) of the various cost and earnings categories being collected. This descriptive summary will also be distributed to survey respondents via paper mail.

Survey results will be reported over time through a series of studies prepared for fisheries management. It is anticipated that results will also be reported through academic publications, presentations at conferences, and technical guides. All reporting of survey results will conform to data confidentiality requirements.

Information Quality Guidelines and Confidentiality

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NMFS will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. In particular, the data collected will be kept confidential as required by section 402(b) of the Magnuson-Stevens and NOAA Administrative Order 216-100, Confidentiality of Fisheries Statistics, and will not be released for public use except in aggregate statistical form without identification as to its source.

The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106‑554.

6. Contact information for agency coordinator and principle investigator.

Agency Coordinator:

Carl Lian

Northwest Fisheries Science Center

2725 Montlake Boulevard East

Seattle, WA 98112

206-302-2414 (voice)

206-860-6792 (fax)

[email protected] (email)

Principal Investigator:

Dave Colpo

Pacific States Marine Fisheries Commission

205 SE Spokane Street

Portland, OR 97202

503-595-3100 (voice)

503-595-3232 (fax)

[email protected] (email)

7. Estimated burden and number of respondents.

Reviewing the survey, collecting requested data, and completing the survey is expected to take three hour per respondent. A total of 750 responses are expected from the telephone sample and the non-telephone sample. As a result, the survey is expected to impose a total of 2,250 burden hours on the west coast limited entry trawl fleet.

Note: this response time has increased in estimate from one hour. Recently, NMFS contacted seven respondents to the limited entry survey to determine their average interview preparation time. Their reported preparation times ranged from 30 to 150 minutes and averaged 105 minutes per interview. Given that the types of questions and the average interview times were similar for the (limited entry and open access), NMFS believes that the average preparation time was about the same for both surveys. Therefore, the estimated average total burdens per respondent are 187 minutes and 182 minutes, respectively, for the limited entry survey and the open access survey (105 minutes added to the previous 60 minutes estimated which took only the interview into account).

1 Survey development for the previous open access groundfish and salmon troller survey began with the formulation of the Cost Earnings Program Plan. This plan outlines the reasons for collecting cost earnings data, identifies the population(s) of interest among west coast vessel owners, and prioritizes data needs. Based on this long-term plan, objectives for this survey and survey content were developed through a series of meetings by representatives of the NWFSC, Northwest Regional Office (NWR), Southwest Fisheries Science Center (SWFSC), and Pacific States Marine Fisheries Commission (PSMFC). These meetings identified key objectives as collecting data which could be used to measure fisheries profitability, economic impacts, efficiency, and economic benefits of regulatory measures. The academic literature, both within and outside of fisheries, was reviewed in order to determine the data requirements of models which would likely be used to measure fisheries profitability, economic impacts, efficiency, and economic benefits of regulatory measures.

This process allowed prioritization of data needs and choice of survey content. After survey content was determined, a draft questionnaire was prepared. This draft questionnaire was discussed with members of the limited entry trawl fleet by PSMFC personnel. In addition, NOAA personnel provided a presentation on survey content and timing to the Pacific Fisheries Management Council Groundfish Advisory Panel (a group of fishing industry members including harvesters and processors) and the Council’s Scientific and Statistical Committee (a group responsible for reviewing the methodology used in scientific and statistical studies) . Comments received through these discussions and presentations improved questionnaire content and format.

2 Vessels operating in fisheries such as crab and shrimp are in the survey population for not only the open access survey but also the mandatory limited entry groundfish trawl EDC and the voluntary limited entry groundfish fixed gear cost earnings survey. Economic analysis of vessels participating in these fisheries requires combining data from multiple surveys.

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