CFCC ss 042815 Part A

SUPPORTING STATEMENT

U.S. CARIBBEAN COMMERCIAL FISHERMEN CENSUS

OMB CONTROL NO. 0648-XXXX

A. JUSTIFICATION

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

This request is for a new information collection to enhance the management of fishery resources in the Commonwealth of Puerto Rico and in the United States Virgin Islands (USVI).

The National Marine Fisheries Service (NMFS) proposes to conduct a survey of commercial small scale fishermen operating in the United States (U.S.) Caribbean. The proposed socio-economic study will collect information on demographics, fishing and marketing practices, capital investment on fishing vessels, gear, and equipment, and miscellaneous attitudinal questions. The data gathered will be used for the development of fishery management plans and amendments which require descriptions of the human and economic environment and to conduct socio-economic analyses of regulatory proposals.

The paucity of socio-economic data is a significant hurdle in evaluation of regulatory proposals in the region. Local trip tickets are the only continuous data collection in the region. These programs mainly collect landings and fishing effort data. Therefore, periodic socio-economic data collections are required to gather current cultural, economic, and social information for the development of amendments to fishery management plans. Up-to-date socio-economic data is needed to support the Agency’s conservation and management goals, to strengthen and improve decision-making, and to satisfy legal mandates under the Reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), the Regulatory Flexibility Act (RFA), the Endangered Species Act (ESA), and the National Environmental Policy Act (NEPA), Executive Order 12866 (EO 12866), and other pertinent statutes.

The MSA mandates that conservation and management measures prevent over-fishing and obtain an optimum yield (OY) on a sustained basis. It also established new requirements to end and prevent overfishing with the use of annual catch limits (ACLs) and accountability measures (AMs). Moreover, MSA requires that conservation and management measures 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 any adverse economic impacts on such communities.

The need and the authorization to collect these socio-economic data are found in the MSA, 16 U.S.C. 1801 et seq., the RFA, 5 U.S.C. 601 et seq., the NEPA, 42 U.S.C. 4372 et seq., and EO 12866. The MSA states that the collection of reliable data is essential to the effective conservation, management, and scientific understanding of the fishery resources of the United States. The nation's fisheries should be "conserved and maintained so as to provide OYs on a continuing basis". Furthermore, eight of the ten National Standards under the MSA, which provide guidance to the regional fishery management councils, have implications for economic analyses. For example, under section 303 (a) (9) of the MSA, a fishery management plan must include a Fishery Impact Statement (FIS), which assesses, specifies, and describes the likely effects of the conservation and management measures on participants in the fisheries being managed, fishing communities dependent on these fisheries, and participants in fisheries in adjacent areas.

Under the RFA, the Small Business Administration needs a determination of whether a proposed rule has a significant impact on a substantial number of small entities that are to be directly regulated. For RFA purposes, one of the criteria to determine significant economic impact involves an assessment of the change in short-term accounting profits for small entities. The NEPA requires a determination of whether Federal actions significantly affect the human environment. This requires a number of socio-economic analyses including the impact on entities that are directly regulated and those that are indirectly affected. In addition, EO 12866 mandates an economic analysis of the benefits and costs to society of each regulatory alternative considered by the fishery management councils, and a determination of whether the rule is significant.

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.

One-time, voluntary surveys will be used to collect socio-economic information in Puerto Rico and in the USVI. This will be a collaborative effort with local fisheries agencies, namely Puerto Rico’s Department of Natural and Environmental Resources (PR DNER) and USVI’s Department of Planning and Natural Resources (USVI DPNR), who have conducted these censuses in the past.

The interviews will be mainly conducted in person; however, some interviews maybe conducted over the telephone as needed to minimize any burden on the fishermen. We anticipate that the contractor (to be determined) will be hiring local port agents and local university students to assist conducting the interviews, creating the database, and analyzing the data. The current lists of the registered fishermen with their contact information will be provided by PR DNER and USVI DPNR.

PR DNER reports that there are 3,400 licensed fishermen of which 1,000 report landings statistics (i.e., “active” fishermen) so the plan to conduct a stratified sample of the 2,400 remaining licensed fishermen who are not reporting landings statistics. We anticipate sampling about 15% of this population (i.e., 332 fishermen). In total, we anticipate sampling 1,182 Puerto Rican fishermen. USVI DPNR reports that there are 389 licensed fishermen (191 in St. Thomas, & St. John and 198 in St. Croix). We intend to survey the entire population in USVI.

The information collected (in combination with existing trip ticket data) will be of practical utility since NMFS needs it for descriptive and analytical purposes. The data will be used to describe the human and economic environment of the local fisheries and to conduct socio-economic analyses of regulatory proposals. This information is required for the development of

U.S. Caribbean fishery management plans and amendments. The proposed survey will collect socio-economic data which otherwise would be unavailable.

Two survey instruments were developed for the proposed data collection. One instrument is to be used in Puerto Rico and the second in the USVI. The reasons for the two survey instruments lie in the slightly different gear usage across islands and the desire to maintain previous data collection baselines. Earlier USVI commercial fishermen censuses collected detailed gear information such as dimensions and usage whereas the Puerto Rican commercial fishermen censuses collected gear counts. In addition, the Puerto Rican survey is written in Spanish to minimize the burden on local respondents.

The survey forms collect information on the following: 1) demographic background, 2) fishing and marketing practices, 3) capital description and investment in vessels, gear, and fishing equipment, and 4) miscellaneous attitudinal questions.

The ‘demographic background’ section elicits information about fisherman’s age, marital status, race, number of dependents, and formal education achievement.

The ‘fishing and marketing practices’ section probes about the fisherman’s role in the fishing vessel (captain vs. crew), fishing experience, participation level (e.g., full-time vs. part-time), main gear types used, main species targeted, time spent on fishing and fishing related activities (e.g., fixing gear, marketing), crew size, participation in fishing cooperatives, main launching sites, and type of fishing license held. It also asks about the main markets, icing practices, and type of fish processing conducted (e.g., gutting, scaling

The ‘capital description and investment in vessels, gear, and fishing equipment’ section inquires about vessel ownership, vessel characteristics (e.g., length, age, type of hull, number of engines and horsepower), electronics and fishing equipment owned (e.g., GPS, fish finders, winches), counts and description of various gear types (e.g., nets, hook and line, pots and traps) and approximate value of the capital invested in the fishing operation.

The ‘miscellaneous attitudinal questions’ section gathers information on their perceptions about the state of the resource and coral reefs, easiness to find employment outside fishing, household financial well-being and main socio-economic affecting the fishery.

Survey differences:

Questions 9, 8, and 30 have slightly different answer options because of past censuses and to better reflect the local setting. For example, q18 has juey (land crab) as an option which is not present in the VI survey (again, this is because land crabs were never asked in the VI and because land crabs are considered a fishery in PR. The opposite in true for whelk in the VI)

Q35 is different in the VI and PR surveys because VI usually asked more detailed information (e.g. size of gear) whereas PR simply asked for counts.

Q35 in the PR survey asks for count and value of the various gears in a single table, whereas:

Q35 in the VI survey asks for info on the net fishery; 

Q36 in the VI survey asks for info on the trap/pot fishery, 

Q37 in the VI survey asks for info on the hook and line fishery and 

Q38 in the VI survey asks for info on the scuba/skin diver fishery.

Questions 36-41 in the PR survey ask the same questions as Qs 39-43 in the VI survey (e.g., resource and economic conditions.

The data collected in the above sections will be used to characterize the population of fishermen which is necessary for the description of the human and economic environment in fishery management plans and amendments. Data from the ‘capital description and investment’ and ‘miscellaneous attitudinal questions’ sections will also provide valuable data to explore issues of fishing engagement and dependence.

The information collected will be disseminated to the public and used to support publicly disseminated information. NOAA 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 to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subject 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 socio-economic data needed will be primarily collected using in-person interviews (and/or telephone interviews in cases where it is easier for respondents) because they are more versatile and less burdensome than mail surveys. We do not anticipate using online questionnaires because of the limited access to internet in some parts of the U.S. Caribbean. In addition, in-person interviews may be preferable because many of the answers do not lend themselves to simple ‘yes/no’ answers and because of the presence of a few open-ended questions, which are burdensome to complete in written form (inadvertently leading to higher non-response rates). Moreover, in-person surveys allow the interviewer to explore the logic and/or reasoning behind the ranking of certain answers.

We do not anticipate that the contractor (to be determined) will be using laptops or other electronic devices to record answers since a few of the questions will be open ended. Typing verbatim could extend the length of the interview, which would further burden the interviewees and result in incomplete surveys.

The data collected will not be available to the public over the internet given its confidential nature. However, a report summarizing the salient, aggregated results will be available online once the data collection and analysis is completed. Also, some of the key results will appear in upcoming human and economic environment descriptions of U.S. Caribbean fishery management plans and amendments.

4. Describe efforts to identify duplication.

We contacted the Caribbean Fishery Management Council (CFMC), PR DNER and USVI DPNR to inform them about our intention to collect socio-economic data and to inquire about other on-going or prospective data collections in the area. These agencies noted that they were not planning nor they were aware about any current or planned data collections that targeted commercial fishermen. The last data commercial collection in the region was a costs and earnings study. Also, as noted earlier, the last commercial census in Puerto Rico was conducted in 2008 and the last one in USVI took place in 2010.

USVI DPNR noted that they were aware of survey that planned to target private anglers on boats (as opposed to fishing from the shore). However, this data collection had been postponed for a couple of years and they weren’t sure when it was going to commence. This planned recreational data collection has yet to be submitted for OMB review.

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

Most commercial fishing operations in the U.S. Caribbean are owner or family-operated small businesses. We have taken several steps to minimize the burden on these small businesses. First, we designed the survey instrument so that only the minimum data requirements for present and future management needs are collected. Surveys will be available in English and Spanish to reduce any burden to non-English speaking fishermen. Second, responses to the in-person survey will be voluntary. Fishermen, who do not wish to participate in the interviews, can choose not to partake. Third, the interviews will be conducted at times and places that are convenient to fishermen. This will minimize any potential disruption to their fishing practices. Last, the wording of the past local surveys (i.e., commercial fishermen censuses) is maintained to account for regional differences particularly when discussing gear types.

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

If the proposed information were not collected (or collected less frequently), then NOAA and the CFMC would not be able to adequately satisfy the legal requirements put forth by the MSA, NEPA, and EO 12898. These mandates require regional fishery management councils to establish conservation and management measures, which take into account the importance of fishery resources to fishing communities in order to provide sustained fishing community participation and to minimize, to the extent possible, adverse economic impacts on such communities. Furthermore, these requirements also mandate that regional fishery management councils to establish conservation and management measures using the best available information.

The absence of up-to-date socio-economic information would limit the Agency’s ability to describe the human and economic environment in fishery management plans and amendments, to estimate the socio-economic impacts of management proposals and to examine the performance of existing regulations. Hence, the advantages and disadvantages of regulatory proposals would continue to be debated without sound data. Current information would also minimize the likelihood of unforeseen impacts of existing regulations. In addition, the availability of current information would minimize the likelihood of unforeseen impacts of existing regulations and court challenges on the grounds of deficient analysis. Last, the collection of detailed socioeconomic data will allow fishery managers to make timely and better-informed decisions by having the best scientific information available.

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

There are no special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

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 recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

A Federal Register notice soliciting public comment on the proposed data collection was published on Tuesday, November 18, 2014 (79 FR 68665). No public comments were received.

In addition, we consulted with CFMC, PR DNER and USVI DPNR staff about the availability of socio-economic 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. Staff from these agencies indicated that their agencies lacked up-to-date, detailed socio-economic data on their commercial fisheries. They noted that the proposed data collections were timely because last census in Puerto Rico took place in 2008 and in the USVI in 2010. ^{1, 2} Moreover, they observed that new commercial fisheries data would help them better manage their local fisheries.

The above agencies also offered several suggestions to improve the wording of the questions and proposed minor changes to the data elements (i.e., variables) to be collected. In addition, staff from the CFMC, PR DNER and USVI DPNR suggested placing the technical report online to make the findings widely available.

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.

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 instruments, respondents will be advised that any information provided will be considered private and will be treated as confidential in accordance with NOAA Administrative Order 216-100, Confidential Fisheries Statistics and section 402(b) of the MSA (16 U.S.C. 1881, et seq.).

In addition, NMFS’ data confidentiality policy does not allow its employees to release confidential data, other than in aggregate form, as the MSA protects (in perpetuity) the confidentiality of those who submitted data. Whenever data are requested, the Agency will ensure that information identifying the pecuniary business activity of a particular individual is not identified. Only group averages or group totals will be presented in any reports, publications, or oral presentations of the study's results.

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.

The survey does not inquire about sexual behavior and attitudes, religious beliefs, or other similar matters of a personal and sensitive nature.

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

We estimated that the number of respondents will be 1,522 and the time per response will be about 1/2 hour. Hence, we are requesting 761 burden hours. The half hour per response burden includes the time for reading the instructions, reviewing the questions, and completing the survey instrument. This estimate is based on the type of questions asked, length of the survey instrument, and the agency’s experience conducting similar surveys.

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 will be no financial cost to the public to participate in this study.

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

We anticipate that the expenditures for this data collection and analysis will be around $200,000. This estimate covers the outlays for the following activities: training of interviewers, printing of forms, travel, data collection, data entry and quality control, and report writing. In addition to the above contractor expenses, federal costs include NMFS staff time. The NMFS staff will be responsible for developing and administering the contract, monitoring performance and reviewing the final report. We estimate that the cost NFMS supervision will be approximately $20,000/year. Thus, the total annualized (for 2 years) cost to the federal government would be $240,000.

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

This is a new survey.

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

We anticipate completing the data collection in Puerto Rico and in the USVI by the end of 2016 and 2017, respectively. We expect to complete the analysis and publish a technical report of the Puerto Rico data by May 2017. We also expect to complete the analysis and publish a technical report of the U.S. Virgin Islands data by May 2018. Both of these technical reports will be available online.

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.

The OMB control number and expiration date will be displayed.

18. Explain each exception to the certification statement.

There are no exceptions to the certification statement.

1 Matos-Caraballo, D. and J.J. Agar, 2011. Census of Active Fishermen in Puerto Rico (2008). Marine Fisheries Review, 73(1):13-27.

2 Kojis, D., and N.J. Quinn, Census of the Marine Commercial Fishers of the U.S. Virgin Islands, 2011. Report to the Southeast Fisheries Science Center, NMFS, Miami, Florida.

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