Responses to OMB comments

Response to Comments on West Coast Swordfish Fishery Cost and Earnings Survey

1. Do the confidentiality provisions under the MSA 402(b) apply to this survey? Please mention on the survey instrument and supporting statement A.

No, they do not apply, because the survey is voluntary. The instructions have been reworded accordingly.

2. In supporting statement A, please describe changes made to the survey instrument from 2010, including new questions that have been added.

We have added the requested description of changes to the survey instrument to supporting statement A.

3. Several questions seem particularly time consuming for respondents. Please justify questions Section 1, Q12 through Q16 and Section 6 Q9 through 13

This group of questions was asked on previous cost-and-earnings surveys; including them again will help provide continuity of information collection from past surveys through the present one. Based on previous survey experience, fishermen are keenly aware of the insured replacement value of their vessels and the remaining time on their loans, so these questions are not especially time consuming. We realize that some fishermen may need to refer to their tax documents to provide information such as remaining time on their loans or vessel depreciation and amortization; however, this information is important to characterizing the cost of participation in the fishery.

4. Would Section 1 Q32 include engine maintenance? If so, then why is it necessary to ask Q30?

We agree that Q30 and Q32 are redundant. We have replaced Q30 with a follow-up question to Q32 to clarify whether haul out fees are included with total vessel repairs and maintenance.

5. Are the berthing fees in Section 1 Q36 different than Q26? Please clarify.

No difference. The reason they are included in both questions is that berthing fees are sometimes included with Total County or Landing fees. We have added a clarification to Q26 that berthing fees should only be included here if separately charged (i.e. not included with amount referenced in Q36).

6. Would a mileage deduction be entered into Section 1 Q36 or Q37?

No. Generally the survey does not attempt to capture tax treatment of expenditures.

7. If a new vehicle was purchased, where would it be reported in Section 1?

We added a Q37a to enable reporting new vehicle purchases.

Where would the respondent indicate the proportion of time the vehicle was used for fishing-related business?

We assume vehicle expenses will reflect proportion of time the vehicle was used for fishing-related business and will clarify this in conducting the survey.

8. Section 1 Q6: Why is the age of the captain necessary to collect?

This is to provide statistical data to document a frequently-expressed concern about the aging fleet.

9. Section 1 Q18 and Section 6 Q16: Should the form indicate whether health insurance is covered by a spouse’s plan?

The survey focuses on vessel-level operating costs, not household-level costs. We believe questions about whether respondents are covered by their spouse’s health insurance plan lie beyond the scope of the survey, and hence should not be included.

10. Section 1 Q38: Do storage expenses include the refrigeration expenses in Q22(c)? Please clarify.

No. This question refers to off-vessel storage expenses, not refrigeration. We have modified the wording to reflect this.

11. Section 1 Q43 through Q52: For captains that own a spotter plane, is there a reason why they are not also asked applicable questions from Section 7?

We have revised this part of the survey to better accommodate captains that own a spotter plane, as explained in answer to 12.

12. Section 1 Q47: Is it intended for respondents to complete 47(a) only if they are responsible for paying fuel costs? Please clarify. Would respondents typically record fuel and oil costs separately? If not, please revise to allow for the reporting of combined costs.

To address this concern, we have revised Q45 to direct participants to complete Section 6 in case they own the plane, and have removed subsequent questions in Section 1 pertaining to plane ownership and operating expenses.

13. Section 2 Q6 through 7a, Section 4 Q4, and Section 5 Q4: For a fisherman that has purchased multiple drift nets and pingers (or longlines/buoy gear) over many years, how would the person determine the initial price and life expectancy?

We have revised the wording to indicate the questions only pertain to the most recently purchased net currently in use.

14. Section 6, Q2: Why is it necessary to ask for the pilot’s age?

Participant age distribution is a key question of interest regarding the West Coast Swordfish Fishery. Collecting information about participant age will enable providing statistical information about this important variable in our survey report.

15. Section 6 Q19a: Is it a matter of practice for pilots to record gallons of gas and oil used for tax purposes? Why is it necessary to ask this question in addition to Q19(b)? (Does the IO model use both variables?)

Based on responses to past surveys, we believe many participants routinely maintain records of gallons of gas and oil consumed, whether or not for tax purposes. Consumption volume information is of additional interest to expenditures on fuel or oil, even though both categories of information do not enter the IO model. Expenditures together with quantities of fuel and oil consumed reflect the price of these production inputs, which in turn affects the economic viability of fishing effort.

16. Section 6 Q19(f): Is the intent of the question to capture surface and commercial air travel?

No. The question pertains to transit of the plane to and from the fishing grounds. We have clarified this in the wording.

This question appears to potentially double count fuel costs from 19(b). Are costs to fishing grounds typically recorded separately by pilots from their operating costs while at the fishing grounds?

We believe this is the case, but have reworded the 19(b) and 19(f) to avoid double-counting.

17. Section 6 Q20: Do spotter planes look for multiple categories (i.e., tuna and sharks) simultaneously? If so, then please add a field for combined (unspecified) fish stocks.

Our understanding is that spotter planes are typically seeking a particular species depending on availability and target preference of the fisherman, rather than looking for multiple categories. For exceptions where multiple targeting is occurred, we will direct participants to respond in the “Other” line.

18. Section 6 Q20(c): Would respondents typically record as a business practice the number of days flown for different stocks of tuna? If not, then suggest modifying the question and record the tuna stock most frequently spotted.

Since the primary focus of the survey is on swordfish fishing activity, we have removed “(specify)” from Q20(c) so that it pertains to all categories of tuna.

19. Section 6 Q21: If a spotter plane pilot was paid a fixed fee, would he know the figures for catch?

Our understanding is that catch success is a key determinant of future employment opportunities. Hence pilots generally are aware of figures for catch.

If not, then please clarify on instrument.

20. Section 6 Q21: Please clarify that ‘revenue’ refers to the revenue received by the spotter plane pilot and not the fishing vessel.

Clarification added.

Would some pilots be paid based on the total catch?

Yes. More generally, some pilots are compensated on a fixed contractual price basis while others receive a share of catch revenues.

If so, then please add a field for revenue from combined (unspecified) catch.

We have reformatted the “Other” row (Q21(e)) and will use this row to capture exceptions such as fixed revenues or revenue share based on combined catch.

21. Section 7 Q7 and Q8: Why is it necessary to ask these two questions in addition to Q5?

We agree that there is redundancy and have removed Q5 to eliminate it.

22. Section 7 Q9: Is this universally applicable to the respondents? Why is it necessary to know this information for the IO model?

We believe the purchase cost to be of independent economic interest from the IO model, as this is an indicator of the value of participating in the industry as a processor. Further, changes in the value of a processing operation over time are an indicator of business success.

23. Section 7 Q15: Is it necessary to specify insurance costs for (a) through (e) for the purposes of the model, or can respondents report combined costs for insurance? Note vehicle insurance is reported under 18(b).

Itemizing categories of insurance costs will enable more accurately determining which insurance costs pertain to participants in the fishery, and will help to validate and characterize the total insurance cost of participation.

24. Section 7 Q18: How are the maintenance costs reported in this field distinct from Q18a

We have reworded the “Maintenance costs” question to clarify that these are other than vehicle maintenance costs.

25. Section 8 Q10: This open-ended question could potentially collect personal information that is sensitive in nature. Please revise. One option would be to remove ‘personal’ and leave ‘other’ without space for explanation (e.g., a checkbox).

We have revised this question response to use the recommended checkbox approach.

26. Section 9 Q2: It is not clear how an open-ended question on regulation will have practical utility. Are respondents being asked for views whether they prefer a completely unregulated fishery, or are there specific aspects that are of interest to the program?

This question is intended to provide the opportunity to offer candid subjective feedback on how regulation has affected participant operations in recent years. We expect the responses to reflect the differential impacts of regulation on different participant groups, and will summarize responses accordingly. Given a history of regulation in the West Coast Swordfish Fishery back to the early-1980s, we do not expect respondents to advocate for a completely unregulated fishery.

27. Section 9 Q3: How will the responses to this question be used? There is often competition among fishing sectors. Is there a potential that fishermen will be biased against those fishing with other gear types?

This question is intended to collect information of relevance to the Pacific Fishery Management Council’s Swordfish Management and Monitoring Plan, which is currently under development. We acknowledge that responses may reflect individual opinions about which gear types should be allowed.

28. Section 9 Q7: Is ‘activity’ referring to the number of participants, catch limits, or both? Please clarify.

The Pacific swordfish stock targeted by the West Coast Swordfish Fishery participants is not overfished nor subject to overfishing, and the fishery is not subject to Annual Catch Limits. The question pertains to the amount of catch and economic production, not catch limits. We believe survey participants will be aware of this, but will be prepared to clarify as necessary.

29. Section 9 Q8: Suggest a revision, “Are you concerned that climate change will affect the operation…” Rephrasing the questions and options in Q8 using ‘concern’ instead of ‘expect’ seems more appropriate for respondents that likely are unaware of specific projections and uncertainties regarding fish stocks in the scientific literature.

We have revised the question to avoid any implicit references to specific projections and uncertainties regarding fish stocks in the scientific literature and reworded it to more directly relate to fishermen’s actual experience on the water.