MACS SS_021011 Part A. rev

SUPPORTING STATEMENT
SOCIAL IMPACTS OF THE IMPLEMENTATION OF CATCH SHARES PROGRAMS
IN THE MID-ATLANTIC
OMB CONTROL NO. 0648-XXXX

INTRODUCTION
This request is for a new information collection.
Catch share systems are being encouraged and considered in a variety of United States (U.S.)
fisheries. Scientists, policy makers, and stakeholders (including fishermen and nongovernmental environmental organizations) have different views about potential social and
economic impacts and outcomes of these output- oriented systems. Thus establishing baselines
for trend analysis and identifying and evaluating impacts over time is essential to assess and
improve such systems and determine whether intended outcomes are realized. Without baselines
we cannot as effectively judge change due to catch shares from change due to other factors. The
largest-ever catch share program (in terms of number of permits) was implemented in the
groundfish fishery in the Northeast region May 1, 2010. An Individual Transferable Quota for
general category scallop permits was established April 1, 2010. Other catch share programs are
being contemplated in the Northeast Region (New England and the Mid-Atlantic) for the near
future. Baselines are rapidly being left behind. A University of Rhode Island survey of fishermen
and former fishermen in New England in 2009/2010 partially captured this baseline for fisheries
in general, as well as some immediate post-implementation impacts for groundfishermen and
general category scallopers in that region. This survey will replicate that survey in the MidAtlantic. Timing is critical in order to capture baselines for fisheries in general, and immediate
post-implementation effects for recently implemented catch shares.
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
Historically, changes in fisheries management regulations have been shown to impact individuals
within the fishery. In promulgating and issuing regulations, the National Marine Fisheries
Service (NMFS) must determine the relative impacts of different management measures (re.
Colburn et al. 2006). Catch shares are currently being highly encouraged as a core strategy to
improve the status of fish stocks and habitat, and also the social and economic status of
communities and individual fishermen (NOAA 2010). Several new catch share programs have
just been implemented or are about to be implemented in the NMFS Northeast Region.
An understanding of social and economic impacts in fisheries – achieved through the collection
of data on fishing communities, and on individuals who fish – is a requirement under multiple
federal laws, including the National Environmental Policy Act of 1969 (NEPA) as amended (42
U.S.C. 4371 et seq.), the Magnuson-Stevens Fishery Conservation and Management Act of 1976
as amended through 2006 (MSA), Executive Order 12898 of February 11, 1994 on
Environmental Justice (E.O. 12898) and the Regulatory Flexibility Act of 1980 as amended by
the Small Business Regulatory Enforcement Fairness Act of 1996, and subsequently (RFA). The
collection of these data, therefore, not only complies with legal requirements for existing
management actions, but will inform future management actions requiring equivalent
information.
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NEPA
NEPA requires federal agencies to consider the interactions of natural and human environments,
and the impacts on both systems of any changes due to governmental activities or policies. This
consideration is to be done through the use of ‘…a systematic, interdisciplinary approach that
will insure the integrated use of the natural and social sciences…in planning and decisionmaking which may have an impact on man’s environment;’ (NEPA Section 102 (2) (A)). Under
NEPA, an Environmental Impact Statement (EIS) or Environmental Assessment (EA) is required
to assess the impacts on the human environment of any federal activity. NEPA specifies that “the
term ‘human environment’ shall be interpreted comprehensively to include the natural and
physical environment and the relationship of people with that environment” (Council on
Environmental Quality NEPA Implementing Regulations 40 CFR 1508.14).
E.O. 12898
E.O. 12898 requires federal agencies to consider the impacts of any action on disadvantaged, at
risk and minority populations. To evaluate these impacts, information about the vulnerability of
certain stakeholders must be better understood. Indicators of vulnerability can include but are not
limited to income, race/ethnicity, household structure, education levels and age. Although some
general information related to this issue is available through census and other quantitative data,
these sources do not disaggregate those individuals or groups that are affected by changes in
marine resource management or the quality of the resource itself. Therefore, other types of data
collection tools must be utilized to gather information related to this executive order.
RFA
The RFA requires federal agencies to prepare an initial and final regulatory flexibility analysis
which ‘…shall describe the impact of the proposed rule on small entities…’. The initial
regulatory flexibility analysis‘…shall also contain a description of any significant alternatives to
the proposed rule which accomplish the stated objectives of applicable statutes and which
minimize any significant economic impact of the proposed rule on small entities. [Section 603
(b)(5)(c)]. In addition, each final regulatory flexibility analysis shall contain ‘…a description of
the steps the agency has taken to minimize the significant economic impact on small entities….’
[Section 604 (a)(5)]. Fishing vessels in the Northeast are predominantly categorized as small
entities. Individual crewmembers are also considered to be small businesses in their status as sole
proprietors.
MSA
Under the MSA there are a variety of requirements related to social, cultural and economic issues
for fishermen and their communities. National Standard 8 (section 301(8)), for instance, requires
that: "Conservation and management measures shall, consistent with the conservation
requirements of this Act (including the prevention of overfishing and rebuilding of overfished
stocks), take into account the importance of fishery resources to fishing communities in order to
(A) provide for the sustained participation of such communities, and (B) to the extent
practicable, minimize adverse economic impacts on such communities. Section 303(b)(6) on
limited entry requires examination of "(A) present participation in the fishery, (B) historical
fishing practices in, and dependence on, the fishery, (C) the economics of the fishery, (D) the
capability of fishing vessels used in the fishery to engage in other fisheries, (E) the cultural and
social framework relevant to the fishery and any affected fishing communities, and (F) any other
relevant considerations." Section 303(a)(9) on preparation of Fishery Impact Statements notes
they "shall assess, specify, and describe the likely effects, if any, of the conservation and
management measures on--(A) participants in the fisheries and fishing communities affected by
the plan or amendment; and (B) participants in the fisheries conducted in adjacent areas under
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the authority of another Council, after consultation with such Council and representatives of
those participants."
CONTEXT FOR PROPOSED RESEARCH
The use of catch share programs will have an impact on those individuals participating in the
affected fisheries. Possible impacts include loss of employment opportunities and shoreside
infrastructure, and disruption to social networks. Amendment 16 to the Northeast Multispecies
(groundfish) Fishery Management Plan, implemented on May 1, 2010, is the largest catch share
program in number of permit holders that has ever been implemented in the U.S., and includes
17 group quota or ‘sector’ allocations. Additional Northeast catch share plans instituted in 2009
or 2010 are the Mid-Atlantic golden tilefish ITQ (2009) and the Atlantic sea scallop IFQ for
general category permits (April 2010). Catch shares are under consideration for the upcoming
amendment in the monkfish fishery, and in discussion for other fisheries as well. NMFS is
required to assess the impact of these plans, as well as their impacts relative to other
management measures in place in the Northeast.
The rapid implementation of the groundfish catch share program made capturing a full preimplementation baseline virtually impossible. A University of Rhode Island survey of fishermen
and former fishermen in New England in 2009/2010 partially captured this baseline for fisheries
in general, as well as some immediate post-implementation impacts for groundfish and general
category scallop fishermen in that region. This research aims to study the immediate postimplementation effects on fishermen in the groundfish and general category scallop fisheries in
the Mid-Atlantic, as well as provide a baseline for other fisheries prior to any implementation of
additional catch share programs. The data collected will provide a baseline description of the
affected industry to compare with future assessments of fishermen, and cover 1) demographic
information, 2) participation in management, 3) impacts of management, 4) perspectives on
catch shares, and 5) environmental ethics, job satisfaction and well-being . This information will
lead to a greater understanding of the social impacts this management measure may have on the
individuals in the fishery. To achieve these goals it is critical to collect the necessary data as
quickly as possible, both to capture baselines of fisheries for which catch shares are being
contemplated and to facilitate recall of baseline conditions in the groundfish and scallop fisheries
to capture Year One impacts (i.e., by April 1, 2011).
This study is a post-implementation data collection effort to achieve the above-stated objectives
for the Northeast groundfish fishery and other catch shares just implemented, as well as a preimplementation study for upcoming catch share plan implementations. This is a time-critical
study, as once these baselines are lost it will be impossible to reconstitute them.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
Information sought will be of practical use, as NMFS social scientists will utilize the information
for descriptive and analytical purposes. In addition, in the event of future regulatory action, the
information may be utilized by NMFS to meet the requirements of the regulations described
above under Question 1. Further, this research and the resultant data may be utilized in efforts
that include the development of ecosystem models which incorporate social indicators and other
social information. The results of this research will increase the availability of social data to the
extent that it may significantly benefit new research efforts in ecosystem modeling. Reports will
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also be made available to the New England and Mid-Atlantic Fishery Management Councils and
the public. The exact frequency of the use of the data is unknown at this time and is dependent
in the regulatory actions required in the future as well as public use. However, since this will be
information not previously available, it is expected to have high utility.
The survey form is organized to ease the collection of the data by clearly identifying
the types of data being collected, through the use of clearly defined sections.
The survey will collect information on 1) demographic information, 2) participation in
management, 3) impacts of management, 4) perspectives on catch shares, and 5) environmental
ethics, job satisfaction and well-being. These are data that are unavailable from other sources.
The ordering of questions is based on a similar study conducted in New England in 2009 and
2010 and alternates more complicated questions with less complicated questions to reduce the
likelihood of interviewee fatigue. The sections are further described below.
The Demographic Information section elicits information on the respondent and his/her
age, town of residence, level of education, primary fishery, relative income level compared to
two years ago, relative ability to secure crew compared to two years ago, and family
involvement in the fishing industry. Comparisons between the present and past are intended to
capture general trends in the fishing industry. This standard demographic information will allow
us to better understand the unique characteristics of the Mid-Atlantic fishing industry.
Information collected in this section is comparable to United States (U.S.) Census information,
but on a finer scale. The U.S. Census does not collect or provide the information at a level to be
able to identify a specific population of fishermen, or fishermen as a separate industry.
Information about fishermen in the U.S. Census is aggregated with other industries such as
forestry and agriculture, making it impossible to describe the demographics of any specific
fishing community (re. Clay and Olson 2008 on the concept of fishing community within U.S.
fishery law) through the use of these data. Collection of the data in this section serves to describe
this specific population of fishermen.
This information is related to specifics of how the fishing industry operates and can then be
utilized to better understand impacts on individuals if regulatory actions change how, when or
where fishing may occur.
The Participation in Management section seeks to describe the types of actual involvement in
the fishery management process and individuals’ perceptions of their level of influence in that
process. Information in this section will allow us to better understand the characteristics of those
who participate in management processes, as well as the types of participation that are most
common. This, in turn, can help in better distributing information about management proposals,
and generating greater involvement. Management actions created with greater participation of
stakeholders are better received and more likely to be effective. These questions address
“Governance/Participation” and “Legitimacy/Transparency” under Governance in the Northeast
Social and Economic Performance Measures (Northeast Performance Measures) recently created
by the Social Sciences Branch of the Northeast Fisheries Science Center. The full list of
Performance measures is: Financial Viability, Distributional Outcomes (Equity), Governance,
Stewardship and Well-Being (Clay et al. 2010); detailed indicators are listed under each
performance measure. Resilience was also identified as critical at both the regional and national
levels within NMFS, but was left for the next round of revisions as indicators for this are still
under development. Some questions on this survey will, however, test possible indicators for
resilience.

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The Impacts of Management section elicits information on relative impact of different types of
management measures on individuals and their fishing enterprises, as well as individuals’ ability
to understand the regulations and will capture perceived impacts related to the implementation of
catch shares. In order to capture responses that reflect the regulations they are most affected by a
predetermined list of potential impacts is not provided. Information in this section will help
generate a profile of the industry that describes impacts on fishing activity, families, and income.
These questions address Stewardship under the Northeast Performance Measures (see above and
Clay et al. 2010 for background): as well as Resilience, and facilitate minimization of impacts to
fishing industries and fishing communities, as required under law (see Question 1 above). These
also relate to the Northeast Performance Measures of Financial Viability and Distributional
Outcomes.
The Perspectives on Catch Shares section elicits information on perceived advantages and
disadvantages of catch share systems. Questions target information that would help to understand
potential positive and negative impacts to the fishing industry. Using open-ended questions, we
expect responses to identify advantages and disadvantages of greatest concern to interviewees
and therefore do not provide a predetermined list of possible responses. This information will
help us describe respondents’ concerns and expectations, and track changes in these subjective
measures over time. We can further track objective changes over time and thus better understand
how the industry and communities may be impacted if additional change is mandated through
regulation. (See Smith and Clay 2010 on the importance of including both subjective and
objective measures,) This section relates to Governance under the Northeast Performance
Measures (see above and Clay et al. 2010 for background).
The Environmental Ethics, Job Satisfaction And Well-Being section elicits information on
individuals’ sense of responsibility for the state of the marine resource, their satisfaction with a
variety of features of fishing that have been shown to be important to commercial fishermen
worldwide, and the individuals’ perceptions of their physical and mental health status (Smith and
Clay 2010; Pollnac et al. 2006[2008]; Pollnac et al. 2008; Pollnac et al. 1988). The job
satisfaction and well-being questions address the Northeast Performance Measure Well-Being
(see above and Clay et al. 2010 for background), and will inform our understanding of the
impacts of changes in management regulations on the well-being of fishermen. The
environmental ethics questions address the Northeast Performance Measure Stewardship and will
inform our understanding of the environmental behavior of fishermen, perhaps helping to explain
why in specific instances they are more or less open to increased regulation (re. Davis et al.
2008).
The goal of the survey with its distinct sections is to provide information on the various aspects
of the industry that will support and enable the measurement of a variety of indicators under the
Northeast Performance Measures (see above and Clay et al. 2010 for background). Aggregate
data from the survey instrument can be used to describe the industry and estimate impacts of any
future regulations on the industry. This research will not only inform the current management
process, but will be relevant to other management issues, as well as support legal requirements
regarding fishing communities and social impact assessments, and provide data on and questions
for important research topics. This research will also increase the utility and quality of other
secondary research, completed and ongoing, by providing more accurate primary data to support
secondary data collection efforts.
It is anticipated that the information collected will be disseminated to the public and/or used to
support publicly disseminated information. As explained in the preceding paragraphs, the
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information gathered has high utility. NOAA’s National Marine Fisheries Service 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. See response to Question 10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed in accordance with NOAA
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.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
Due to the hard-to-find nature of the population to be studied, the survey will be administered inperson. Fishing vessel owners/permit holders are known because they must supply contact
information for their permits. Vessel crew, however, are not licensed or regulated in any way
that provides a sample frame from which to seek respondents. Further, crew may not have a
permanent address or phone number or may live aboard the vessel on which they work (Kitner
2006) and thus can be considered hard-to-find individuals, requiring the use of in-person surveys
administered to individuals by survey personnel. Since in-person surveys are completed in the
presence of the interviewer, that interviewer can facilitate the answering of any questions and the
clarification of data being collected, and respond to any concerns of the research participant. In
addition to administering the survey in-person, the researcher can then discuss any concerns that
the interviewee may have. In order to maintain comparability across respondents all surveys,
both crew and owner must be in-person. Therefore we are not providing an internet option.
No technology will be used or provided to complete the survey forms.
4. Describe efforts to identify duplication.
NOAA Fisheries social scientists and contractors work closely with regional academics,
community-based organizations, industry groups and other parties interested in this type of
information. We have been in specific contact with regard to this survey and/or are aware of the
current research activities of key government and academic research institutions that gather
fisheries information in the Northeast, including the New England Fishery Management Council,
the Mid-Atlantic Fishery Management Council, the Atlantic States Marine Fisheries
Commission, the University of Rhode Island, the MIT Sea Grant Program, the University of
New Hampshire, the University of Maine, the Gulf of Maine Research Institute, the University
of Massachusetts, the Rutgers University, and the Virginia Institute of Marine Science.
Further, we have conducted a thorough literature review of related studies in the Northeast and
elsewhere to assure there is no duplication with current activities. An earlier version of this
survey was conducted by the University of Rhode Island in New England in 2009-2010. A subset
of the questions in that and the planned Mid-Atlantic survey was included in a survey of New
England groundfish permit holders conducted by the Gulf of Maine Research Institute in 2009. A
subset of the questions in this survey will be included in a future ongoing, periodic survey
planned to first be implemented in 2012. The information collection submission for that survey
is in preparation but not yet submitted. These repetitions and overlaps have occurred in different
time frames or were aimed at different populations, so were not duplicative. No one responded
to more than one of these surveys within a given year, and these data are specific to the years in
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which they are collected. Therefore, the existence of data for any given question from a prior
year does not invalidate the need for data collection during the timeframe of this survey.
The data requested in this survey are informed by the recently developed Northeast Performance
Measures (see above and Clay et al. 2010 for background) and recent Northeast and national
NMFS social science workshops (scroll down at
http://www.nefsc.noaa.gov/read/socialsci/catchshares/ to see presentations from these two
workshops). Prior and/or ongoing research projects in the Northeast on community profiles,
community supported fisheries and sectors will inform and/or complement this data collection
but not duplicate it.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
This request includes the collection of data on individuals and those whom may be linked to or
represent small businesses. Prior to contacting these respondents, researchers will gather any
publicly available answers to the questions. Only those questions that cannot be reliably
answered through this manner, and may change with perspective of the respondent, will be
asked. In addition, participation in data collection will be voluntary.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Not collecting this information will mean the loss of a vital baseline for information needed to
evaluate the impacts of introducing catch share programs in the Northeast. In the absence of
current information, NOAA Fisheries and Regional Councils will be unable to adequately
understand and predict the potential impacts of policy decisions on people, particularly those
people who do not regularly attend public meetings, but are nonetheless affected by the
decisions. Loss of a baseline, further, will make it impossible to fully evaluate the impacts as
required under NEPA and the MSA (see response to Question 1).
A significant concern related to the quality of these analyses is the risk of being vulnerable to
litigation for not fulfilling the mandates and executive orders described under Question 1.
Therefore not collecting this information may lead to incomplete representation of the science
and information. This could impact the decision making process and negatively impact the
individuals and communities subject to the decisions.
This particular collection will be conducted only once, though a subset of its questions will be
incorporated into a planned ongoing survey (estimated to begin in 2012) which has not yet been
submitted for OMB approval. Details for the ongoing survey will be addressed in the submission
for that survey.
There is a time constraint to commence the survey due to the initial year of the groundfish a
catch share program having begun May 1, 2010 and the scallop general category catch share
program having begun April 1, 2010. To not only capture initial year impacts but understand the
baseline, this survey must be implemented as quickly as possible after April 1, 2011 in order to
maximize respondent recall.

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7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The information collection is consistent with OMB Guidelines for Information Collections.
8. Provide information on the PRA Federal Register Notice that solicited public comments
on the information collection prior to this submission. Summarize the public comments
received in response to that notice and describe the actions taken by the agency in response
to those comments. Describe the efforts to consult with persons outside the agency to
obtain their views on the availability of data, frequency of collection, the clarity of
instructions and recordkeeping, disclosure, or reporting format (if any), and on the data
elements to be recorded, disclosed, or reported.
A Federal Register Notice published on September 10, 2010 (75 FR 55306) solicited public
comment.
Two (2) requests for information were received in response to the Federal Register Notice. One
person from the Mid-Atlantic Fishery Management Council asked for a copy of the Federal
Register notice. This person, who had not yet read the Notice, was requested by his superior to
inquire about the content of the survey with regards to any potential duplication of effort with a
possible future survey that the Council was considering implementing. He did not request a copy
of the survey and there were no further comments or requests for information from this person.
Another person from the Northwestern University requested “the questionnaire or schedule, as
well as a copy of the research proposal itself, talking about the purpose, value, etc. of this
information collection, as noted below in today's Federal Register. Please also include a copy of
the "NOAA Draft Catch Share Policy" noted below, as well as a copy of the University of Rhode
Island study, also referenced below. Finally, please include a paper copy of Amendment 16 to
the Multispecies (groundfish) Fishery Management Plan.” These documents were supplied with
the exception of the URI study as the final report is not yet due for that study. No specific
comments were made or further information requested.
As described in Part B Question 1, this study is modeled after a prior study conducted in New
England by the University of Rhode Island in 2009/2010. Prior to the implementation of that
study a literature review was conducted to find other surveys with questions on the topics of
interest, so as to have as many questions as possible that had already been tested by other
researchers. In addition that survey was pretested, both with regard to the questions and to their
sequencing. During the pretest of that study, consultations were made with fishermen regarding
the availability of similar data and clarity of instructions. Further, that study was funded in part
by a fishing industry-supported research foundation, Commercial Fisheries Research Foundation,
http://www.cfrfoundation.org/, due to the lack of the data which we are now proposing to collect.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts will be provided to respondents.

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10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
No personally identifiable information will be collected. The survey is anonymous. No data can
be connected to an individual; there is no identifying information retained whatsoever. Thus
even protections under Section 402(b) of the Magnuson-Stevens Act as amended in 2006 (16
U.S.C. 1801, et seq.) do not apply.
Because no proprietary data are collected (i.e., landings or value, fishing grounds), there are no
issues of confidentiality with regard to business information.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
No sensitive questions will be asked.
12. Provide an estimate in hours of the burden of the collection of information.
The total number of burden hours is projected to be approximately 112.5 (113) hours. The study
involves in-person surveys. As described in Part B, Question 1, the estimated number of
respondents is 270 based on a targeted number of 300 respondents and a 90% response rate. The
time to complete the survey per respondent is estimated at 25 minutes, for a total survey burden
of 113 hours. It is expected that 10 oral histories will be conducted with individuals not included
in the target population to provide an in-depth understanding of the social context of the effects
of the implementation of the catch shares program. To choose subjects for these oral histories,
individuals knowledgeable about the fishing industry will be selected within ports chosen based
on the multivariate criteria discussed in Section B. 2 below. The oral histories are not included in
the below estimates as oral histories are not subject to PRA requirements.
This collection will occur only once.

Description

Total
burden

Targeted No.
of
Respondents

No. of
Responses
based on a 90%
response rate

300

270

Time to
complete the
survey

Estimated
Burden
Hours
(25x270)

Labor Cost in
$25 in Public
per Burden
Hour,
Annualized

25 minutes

113

$2,8125

13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in Question
12 above).
No additional cost to the public other than labor cost is expected.

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14. Provide estimates of annualized cost to the Federal government.
Total estimated annual cost to the federal government is $64,369. The survey will be conducted
by the contractor and students with assistance from NMFS federal staff. In addition to contractor
costs, travel costs will be incurred to various field sites, and there will be costs for printing of
surveys, and for supplies. Survey design, data collection and processing, and report development
will be conducted by both the contractor and NMFS federal employees. Costs for the contractor
have been included in the list below. Please see table below for itemized costs.
Cost FY2010
Budget

Description
Contractor /student
wages
Contractor/student travel (Lodging, per diem,
and mileage)
NMFS* Travel (Lodging,
per diem, and mileage)
Printing

$ 46,819
15,000
1,250
100

Supplies
Total

1,200
$ 64,369

*National Marine Fisheries Service (NMFS)

15. Explain the reasons for any program changes or adjustments.
This is a new collection.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
Survey numerical and textual information will be a product of this study. Textual information
will be numerically coded and used for categorical analysis. Survey data will be analyzed using
standard social science quantitative data analysis methods. Where possible and relevant, final
reports and other relevant portions of the research process will be posted on
http:/www.nefsc.noaa.gov. Where relevant, studies in their entirety will be published as internal
reports and in part will be submitted for publication in peer-reviewed journals to encourage
additional analysis and review of data collected through this process, as well as to disseminate
findings.
Timeline
1
ACTIVITY
Prepare instruments x
Review 2ndry data
x
Select sample
x
Survey
Data analyses
Report preparation
Final report

2

3

4

x

x

MONTH
5 6 7 8

9

10

11

x
x

x
x

12

x
x

x

x

x

x
x

x
x

x

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17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
NA.
18. Explain each exception to the certification statement.
NA.

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