0716 ss 053118 Part A_083118

SUPPORTING STATEMENT

U.S. CARIBBEAN COMMERCIAL FISHERMEN CENSUS

OMB CONTROL NO. 0648-0716

A. JUSTIFICATION

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

This request is for revision and extension of an information collection to enhance the management of fishery resources in the Commonwealth of Puerto Rico. In the last iteration, there were funds only for the U.S. Virgin Islands; this time, the focus will be on Puerto Rico.

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. This will be a collaborative effort with the local fishery agency, namely Puerto Rico’s Department of Natural and Environmental Resources (PR DNER) who has 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.

PR DNER estimates that there are 2,000 fishermen of which 1,236 report landings statistics (i.e., “active” fishermen) so the plan is to interview the entire population of ‘active’ fishermen plus a stratified sample of the 764 fishermen who are not reporting landings statistics. We anticipate sampling about 73% of the non-reporting (fishery statistics) population. In total, we anticipate sampling 1,500 Puerto Rican fishermen (1051+449 fishermen using an 85% response rate for the ‘active’ fishermen population and 80% response rate for the non-reporting population – these estimates are based on the U.S.Virgin Islands response rates).

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.

The survey collects 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 Puerto Rican survey was written in English and Spanish to minimize the burden on local respondents.

The ‘demographic background’ section elicits miscellaneous demographic information such as fisherman’s age, 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.

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) and PR DNER 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.

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 Monday, March 19, 2018. No public comments were received.

In addition, we consulted with CFMC and PR DNER 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. They noted that the proposed data collection in Puerto Rico is sorely needed because the last census in Puerto Rico took place in 2008 ¹ and also because of the adverse impacts of the recent hurricanes (Irma and Maria). Mr. Daniel Matos of PR DNER stressed the importance updating baseline census information because it would provide insight into fishermen’s coping strategies and would help assess the impact of disaster relief funds.

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.

This information is covered by the Privacy Act System of Records COMMERCE/NOAA-11, Contact Information for Members of the Public Requesting or Providing Information Related to NOAA’s Mission.

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 1,500 and the time per response will be about 1/2 hour. Hence, we are requesting 750 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; only labor cost.

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

We anticipate that the expenditures for this data collection and analysis will be around $100,000. 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 $140,000.

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

We will be conducting this survey in Puerto Rico, but the numeric estimate of the fisher population is basically the same as for US Virgin Islands (USVI) population. The number of responses has been adjusted to reflect the current USVI fisher population.

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

We anticipate completing the data collection in Puerto Rico by September 2019 depending on funding. We also expect to complete the analysis and publish a technical report of the Puerto Rico data by May 2020. The technical report 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.

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