RWMS SS 031615 Part A_Q10 revised

SUPPORTING STATEMENT

MARINER OPINIONS ON THE NORTH ATLANTIC RIGHT WHALE MANDATORY SHIP REPORTING SYSTEM

OMB CONTROL NO. 0648-XXXX

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.

This is a pilot survey to evaluate mariners’ attitudes and responses to the North Atlantic Right Whale Mandatory Ship Reporting System, hereafter referred to as MSR. This system was implemented after finalization of the Ports and Waterways Safety Act,
33 U.S.C. 25 Section 1221, codified in 33 CFR Part 169, Subchapter P. Although the MSR program has been in effect for over 15 years, the United States (U.S.) Government has not assessed the role, if any, that the MSR has had in reducing ship collisions with right whales. In addition, mariners have not been polled to assess possible difficulties involved in the reporting itself. The goal of the pilot survey is to determine if (a) the reporting procedures required under the MSR are adequately clear to the mariner, (b) the reporting itself is onerous or unwieldy (e.g., it may interfere with other vessel operations), and (c) if and how mariners use the information being sent to them as part of the MSR (e.g., modification of ship operations, distributing information to crew, etc.). The pilot survey will gather information directly from the maritime community to identify ways to improve the MSR program, so as to increase its conservation value while also minimizing impact to ship operations.

Background Information on the MSR

The North Atlantic right whale (Eubalaena glacialis) is one of the most highly endangered marine mammal species in the world. Fatal collisions with large ships are the primary threat to the recovery of this species. To address this threat, the U.S. proposed to the International Maritime Organization the establishment of two Mandatory Ship Reporting (MSR) systems in key right whale habitat in 1998 (Fig. 1). The International Maritime Organization (IMO) endorsed the proposal and the MSR systems were established in July 1999. The United States Coast Guard (USCG) then issued a Final Rule implementing the MSR. The MSR is co-funded and co-operated by the USCG and the National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service (NMFS). The information collection requirements are approved under OMB Control No. 1625-0103.

Under the conditions of the MSR, all vessels 300 gross tons or greater are required to send a message to a shore-based station when entering the two prescribed areas. Thererfore, the requirement applies to a large set of ships in U.S. waters, that are engaged in domestic and international trade. Each reporting ship is required to provide vessel name, call sign, course, speed, location, destination, and route (e.g., waypoints) (http://www.nmfs.noaa.gov/pr/shipstrike/msr.htm). No other aspect of vessel operations are affected. An automatically-generated message is sent directly to the reporting vessel that includes information on right whale locations and procedural guidance to help prevent vessel/whale collisions; mariners are also informed about additional regulations established to protect whales from vessel strikes. The two-way exchange is mediated by satellite-linked communications systems.

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.

The survey consists of 9 questions:

• Questions 1 – 3 are designed to determine how frequently the respondent enters the MSR reporting area (shown in Fig. 1).

• Questions 4 – 5 are designed to determine how frequently the respondent reports and how frequently s/he receives an outreach message about right whales.

• Question 6 is a series of Likert-scale statements designed to understand whether the reporting requirements present a burden to mariners and how mariners change any aspect of ship operations or communications, if at all, after receiving the outreach message. The last two statements ask for the mariners general opinions concerning the MSR system.

• Questions 7 – 9 are basic questions about job experience (number of years working, type of ship, type of company).

We will generate summary statistics that characterize responses to each of the survey questions. These summaries will primarily be used internally by NMFS staff to generate a series of recommendations for leadership for improving the MSR program. Recommendations might include, for example, ways to streamline the reporting requirements, developing ways to better inform mariners what is expected of them when reporting, and improving the automated return message content to ensure it has maximum conservation value. In short, we expect to use the survey data to assess the utility of the program and possible impacts to the mariner toward enhancing the overall effectiveness of the program.

In addition, we will likely prepare a paper for peer-reviewed publication that describes the outcomes of this survey. We believe this is a unique opportunity to evaluate a long-standing government program and we think the results will be of value to others who manage similar programs. 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. 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.

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.

The data will be collected via a voluntary survey that respondents will take online. The survey will be programmed to include prompts and skip patterns that are not viable using a mail survey. Further, the opportunistic sampling method that this survey must employ necessitates the use of an online survey. (See Part B for description of the methodology).

4. Describe efforts to identify duplication.

No previous efforts of this type have been undertaken. As the primary purpose of the survey is to assist NOAA Fisheries in improving and evaluating an existing program, previous efforts, had any existed, would have been coordinated with and communicated to NOAA Fisheries.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

Not Applicable.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

As stated above, NOAA Fisheries has not previously evaluataed the North Atlantic Right Whale MSR system to understand it’s impact on mariners and their attitudes and behavioral responses to the program. Without the information collected in this survey, it is difficult to improve the program in a way that benefits mariners and to understand the extent to which the MSR education and outreach messages are used by ship captain and crew.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

To the best of our knowledge, a survey of this universe – the maritime industry - for this purpose has not been previously conducted. The individuals whose responses are targeted in this survey include ship captains and crew who (have) traverse(d) the MSR reporting area at least once. Many of these individuals are employees of private firms, and access to their contact information, as well as information concerning whether they entered the MSR reporting area, would be prohibitively expensive to collect, if it could be collected at all. The most cost-efficient method (and perhaps the only method) to implement a large-scale survey targeting these individuals is through a non-random, opportunistic sampling method. Therefore the survey will be programmed online and hosted on a specific website, and the link to the survey will be broadly distributed via a number of entities associated with the maritime industry. The survey will be 2 pages long and takes approximately 5 – 10 minutes to complete.

8. Provide a copy of 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 record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

A Federal Register Notice ‘Mariner Opinions of the Right Whale Mandatory Ship Reporting System (RWMS)’ published on December 9, 2014, solicited public comment. One comment was received and is posted on the documents page. The summary of the comment and response is provided below.

NOAA Fisheries received one response to the request for public comment on the proposed information collection. The commenter made essentially two points. The first disagreed with NOAA Fisheries’ statement that there has been no effort to assess the role of the MSR in reducing ship collisions with right whales. In support of this, the commenter also noted that MSR data have been used to characterize vessel traffic in certain areas and to establish additional ship-strike reduction measures.

NOAA Fisheries agrees that the MSR program has been useful in describing the features of ship traffic and in further developing ship strike reduction measures. For example, MSR data were used in a recently completed study to describe vessel traffic volume over the last 15 years. We agree that the program may have had a positive influence in reducing strikes of whales, as intended, but to our knowledge there has been no attempt to assess the program’s effectiveness in reducing fatal strikes. In addition, there has been no attempt to review either vessel operator understanding of the reporting requirements or the efficacy of the information returned to mariner.

The commenter also emphasized the importance of the MSR program as an outreach and education vehicle for reducing vessel collisions with right whales. We believe this comment is based on a concern that the proposed survey is focused on doing away with the program; but that is not the objective of the survey. Instead, the purpose of this survey is to assess and better understand the clarity of instructions being provided to reporting vessel operators, the relative difficulty of reporting for mariners, and how, if at all, the return message information is being used by the mariner.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts are made.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

As stated on the survey instrument, the data collected will not be released for public use except in aggregate statistical form without identification as to its source.  Moreover, the survey will be taken on line with no contact information requested; therefore, all respondents will remain completely anonymous to us.  No personal, private, or confidential information is requested. 

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.

There are no questions of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.

The proposed collection will require approximately 83.3 (83) burden hours (500 estimated respondents at 5 – 10 minutes per response, with calculations based on the maximum of 10 minutes).

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).

There are no start-up, capital, or maintenance costs associated with this collection. No new or specialized equipment is needed to respond to this collection. There is no recordkeeping/reporting cost, as the survey will be conducted online.

14. Provide estimates of annualized cost to the Federal government.

The duration of this survey will be for approximately 6 months, thus the annualized cost is the one-time cost of the survey. The estimated Cost to Government is $10,000 for programming the survey and maintaining the data until the survey period ends. All analysis and reporting will be done as part of regular duties: 80 hours total X (wage rate $68) = $5,440.

Total cost to Government for analysis and reporting is $15,440.

15. Explain the reasons for any program changes or adjustments.

This is a new submission.

16. For collections whose results will be published, outline the plans for tabulation and publication.

All results will be entered in a database using standard quality assurance/quality control procedures in survey research. Economists from NOAA Fisheries will analyze the data using standard software (e.g., SAS) and standard statistical procedures that are appropriate for survey data. Results from this collection may be used in scientific, management, technical or general informational publications, and would follow prescribed statistical tabulations and summary table formats. Data will be available to the general public on request in summary form only.

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.

Not Applicable.

18. Explain each exception to the certification statement.

Not Applicable.

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