0726_ SS_Part A_12_3_2018

0726_ SS_Part A_12_3_2018.docx

Socioeconmics of Guided Wildlife Viewing Operations in Monterey Bay National Marine Sanctuary MBNMS)

OMB: 0648-0726

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SUPPORTING STATEMENT


SOCIOECONOMICS OF GUIDED WILDLIFE VIEWING OPERATIONS IN THE MONTEREY BAY NATIONAL MARINE SANCTUARY


OMB CONTROL No. 0648-0726


A. JUSTFICATION


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


This request is for a new information collection to benefit natural resource managers in Monterey Bay National Marine Sanctuary (MBNMS). The National Ocean Service (NOS) proposes to collect information from wildlife watching operations to ascertain the market value of marine wildlife via the ocean recreational industry in the Monterey Bay region.


Up-to-date socioeconomic data is needed to support the conservation and management goals of MBNMS to strengthen and improve conservation of marine wildlife, including whales, pinnipeds, sea otters, and seabirds within the jurisdiction of the sanctuary and to satisfy legal mandates under the National Marine Sanctuaries Act (16 U.S.C. 1431 et seq), Endangered Species Act (16 U.S.C. 1531 et seq), Marine Mammal Protection Act (16 U.S.C. 1361 et seq), National Environmental Policy Act (42 U.S.C. 4321), Executive Order 12866 (EO 12866), and other pertinent statutes.


MBNMS updated its Management Plan in 2008 and initiated a Management Plan Review process in 2015, and has identified a lack of baseline socioeconomic information on ocean recreation businesses. The information is not available to assess the possible economic benefits of marine wildlife protection to the local economy, or the potential impact on ocean recreation businesses. The type of data targeted for this collection; that is, information on costs and earnings from the marine wildlife watching industry, are only currently available for recreational and commercial fishing. Thus, current economic information on the importance of marine wildlife to the local tourism industry is required. The primary focus for this survey will be to gather data on the non-consumptive, market and market and non-market economic value of marine wildlife. This will require two separate surveys. First, and the focus of this request, is the survey of “for hire” operations that take people out for wildlife observation. Specifically, researchers will collect data to determine the amount of wildlife viewing effort (measured in person-days) from wildlife watching operations in the Monterey Bay region. The second survey, not included in this request, will be the survey of passengers aboard the “for hire” vessels for their spending on wildlife observation and their non-market economic values and how those values change with changes in attributes of the wildlife watching experience (e.g. number and diversity of whales, other marine mammals, and seabirds). Approval for this second survey is delayed since this survey has not yet been designed. It will be submitted for review/approval at a future time and may require focus groups and pre-tests to aid in the design.


Secondarily, during the process of the Management Plan Review process, MBNMS may consider new approaches to reduce wildlife disturbance occurring because of close public interaction with the marine wildlife in the Monterey Bay region. Collaborating with the wildlife viewing industry, MBNMS will work with the Sanctuary Advisory Council to explore options for reducing disturbance to whales, pinnipeds, sea otters and seabirds, while minimizing the economic impact on industry. Ocean recreation businesses include whale watching, seabird charters, kayaking, SCUBA diving, and paddle-boarding. A non-regulatory approach to reducing disturbance to marine wildlife could include increased education, outreach and interpretive enforcement programming provided to work more directly with wildlife viewing businesses and the general public. A regulatory approach could include establishing an “approach distance” for encounters with whales, which could require a new prohibition for spectators to remain a defined stand-off distance from particular whales species. Large whales such as humpbacks, grays and blues, as well as orcas, tend to attract spectators who may approach whales during feeding, resting and/or transiting. The latter approach may be explored for implementation on a voluntary basis or for future regulatory action by MBNMS. MBNMS management plan update process will identify alternatives that offer the most logical approach for protecting marine wildlife, while fostering robust, sustainable ocean recreation businesses in the region.


Collection of this data will provide estimates of the potential economic benefits of the diversity of marine wildlife in this region. Additionally, should MBNMS choose to move forward with a regulatory approach to establish an approach distance between wildlife and operators, the information and tools developed from this data collection would be required before conducting a socioeconomic impact analyses under the National Environmental Policy Act (NEPA), Executive Order 12866 (Regulatory Impact Review) and an Initial and Final Regulatory Flexibility Analyses (impacts on small businesses).


Collection of the data on the ‘for hire” operations, applied for here, will provide the basis of estimating the amount of use for extrapolating the future survey of passengers from sample to population. It will also provide information that will help analyze and impacts of MBNMS regulations under the Regulatory Flexibility Act (impact on small entities, here primarily small business operations).


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.



General Overview

The purpose of this information collection is to obtain the information necessary to calculate estimates and build tools that can be used by natural resource managers at the MBNMS to evaluate the value of whales, pinnipeds, sea otters, and seabirds within the sanctuary, as well as estimating potential impacts of alternative management options on the local tourism industry. Socioeconomic data will be gathered from commercial whale and marine wildlife observation operations and will be used to develop social and demographic profiles of business owners/operators. Cost and earnings data will be gathered to develop estimates of the value of these businesses to the local economy. Spatial data documenting, where commercial, non-consumptive marine wildlife viewing activities occur in the region, will be used to assess the cost or benefit of alternative management scenarios to the whale and marine wildlife watching industry.


The unit of measurement is the operation. The interviewer doesn’t select the appropriate person to interview. Instead, the business owner selects the appropriate person (i.e. most knowledgeable) for each type of information. This is a records based data collection where we send out a team to the business establishment and obtain the majority of information from their records. The only information that is tied to a particular person in the operation is the demographics. Demographic information applies to the business owner. This is done so we can meet the requirements of the Regulatory Flexibility Act (impacts on small entities—primarily small businesses) in analyzing the socioeconomic impacts of regulations.


Who will use this information?

Data gathered during this collection will be used by MBNMS and, more generally, the Office of the National Marine Sanctuaries. The surveys will be conducted by staff and graduate students at the Bren School of Environmental Science and Management at the University of California at Santa Barbara. MBNMS will use this data to inform their upcoming management plan update.


How frequently will this information be used?

This one-time collection will last one to two months. It is anticipated that the data gathered from this collection will be used on an as-needed basis. Some of the elements of this submission may be replicated to support socioeconomic monitoring in future years.


For what purpose will the information be used?

Data gathered during this collection will be used by MBNMS and, more generally, the Office of the National Marine Sanctuaries, to support a stakeholder outreach process conducted in and by Monterey Bay National Marine Sanctuary. Completing this information collection will give MBNMS stakeholders fair representation in the design of management strategies by providing information to support the assessment of socioeconomic impacts of management alternatives. The data may potentially be used for conduct of socioeconomic impact analyses under the National Environmental Policy Act (NEPA), Executive Order 12866 (Regulatory Impact Review) and an Initial and Final Regulatory Flexibility Analyses (impacts on small businesses). Finally, the information collected also has potential to be used by resource managers for outreach and education purposes.


Summary of Survey Questions and Mapping Activity

The questions that are included in this collection have not changed from what was submitted under 0648-0726, which will expire 1/31/2019. In addition, they are similar to those submitted under OMB Control Number 0648-0408, Expiration Date: 6/30/2003, for the Channel Islands National Marine Sanctuary. The questions have been slightly modified to meet the data requirement for the present management purpose. This request is to extend the approval of this survey, since implementation was delayed under the original approval. The survey items can be categorized into two primary components: general information and economic information. Below is a discussion of type of information that is being collected and its importance for the study.


General Information


Respondent ID Number

A respondent identification number will be assigned to each operator for data collection purposes.


1. Which of the following includes your age?

2. Are you Hispanic or Latino?

3. What is your race? (Mark one or more)

These three demographic questions will be used to develop profiles of the wildlife viewing tour operators in the Monterey Bay region. The race and ethnicity questions are written per guidelines issued by OMB. The demographics are specifically for the owner of the business to support socioeconomic impacts of regulations on small entities (primarily small businesses) under the Regulatory Flexibility Act.


4. How many family members do you support (including yourself)?

In combination with economic information gathered, this question will provide information on the degree to which operators (business owners) are dependent upon whale watching as their primary source of income for supporting their household and their vulnerability if this income were to decline.


5. What is your primary port/marina/location?

6. Do you have a secondary port/marina/location from where you operate part of the year?

6a. If YES, which one? __________________________________________________

Questions 5 and 6 ask about the primary and secondary ports and/or marinas that the wildlife viewing operation utilize. This information is important for assessing the region of operation as well as travel distance and resulting expenses.


7. How many years have you been an ocean recreation business operator?

This information will help determine how established and dependent the operation is in the local whale watching and marine wildlife viewing industry and may explain differences in attitudes and perceptions of management strategies and regulations.


8. How many years have you been an ocean recreation business operator in the Monterey Bay region?

Question 8 is similar to the prior question in terms of purpose, but collects information regarding the Monterey Bay region, specifically.


9. Do you visit state marine protected areas (reserves/conservation areas) specifically during your tours? (Interviewer—Please show map to identify specific quadrants)

9a. Why?

9b. How often?

9c. If YES, how many years have you taken guided wildlife tours to Monterey Bay National Marine Sanctuary?

This information is important for understanding visitation rates to, as well as the importance of, the state marine protected areas and sanctuaries to business operations. Also asked is why and how often they visit the state MPAs. This qualitative information is important to ascertain their reasons for visiting the state MPAs, which will be of use to sanctuary managers.


Question 10 is for whale watching operators only:

10. Do you currently have a naturalist on board during whale watching trips?

10a. If NO, would you be interested in having one on board if you had more information about the role they play with whale watching operators?

In the Monterey Bay region, naturalists will often come aboard for whale watching trips to talk with customers and collect data on the location and species of whales seen per trip. Question 10 asks if operators participate in this naturalist program, meaning that they allow naturalists on board during whale watching trips. This question will help researchers and sanctuary workers better understand the participation rate of operators in the naturalist program, as well as interest among operators for program expansion.


11. Are customers targeting particular wildlife species when they go on a guided tour?

11a. If YES, please list:

This information will allow researchers to roughly ascertain the species of viewing preference among whale/marine wildlife watching customers in the region.


12. Are you aware that wildlife in the region are sometimes harassed unintentionally?

12a. If YES, how concerned are you that harassment to wildlife (whales, pinnipeds, sea otters, and seabirds) may currently be having a negative impact on your business, with 1 being not concerned and 5 being extremely concerned?

This question series queries the operation on the issue of wildlife disturbance in the region. Gauging awareness of the issue would help local resource managers plan future education and outreach efforts among guided tours. Question 12a gathers information on the level of concern among wildlife viewing operations about the impact of wildlife harassment on their businesses. This question will help managers to understand how interested stakeholders from this group are about wildlife conservation issues relative to wildlife disturbance.


13. In your opinion, on a scale of 1 to 5, how has the quality of guided wildlife tours changed in the last 10 years?

13a. If you believe that the quality of guided tours has changed, could you tell me why you think this is true (e.g. change in the abundance of whales, overcrowding from other operators, new regulations, etc.).

This series of questions, Questions 13 and 13a, asks the operations to indicate if the quality of wildlife viewing has changed in the last 10 years. This information will be helpful in gauging the status of the industry from an “insider’s” point of view. Question 13a elicits detailed feedback on what factors affected a change in quality. Together, this information will allow researchers to understand what factors are believed to be most associated with changes in quality in the industry.


Economic Information


This section addresses costs and earnings of the wildlife viewing businesses. This section was designed to conform to other studies being conducted on the economics of recreational for-hire and guided tour operations, but modified to account for the differences for whale watching and marine wildlife observation businesses.


14. What approximate percentage of the TOTAL business income is derived from guided wildlife viewing operations?

Question 14 will provide information about how much of a respondent’s business income is dependent solely on wildlife viewing services, as opposed to other goods or services offered as a part of their business (e.g., the operation may offer fishing tours as well). This information will allow researchers to assess the degree of dependency of these businesses on wildlife viewing ventures.


15. What approximate percentage of your TOTAL household income is derived from guided wildlife viewing operations?

Question 15 will be used, in combination with other information gathered, to determine the degree of dependency of the business owners on wildlife viewing tourism for their household support. This question, in combination with Question 4, will help researchers to understand the economic vulnerability of owners’ households should management options or other factors impact the industry. This will help us meet the needs of socioeconomic impact analysis of regulations under the Regulatory Flexibility Act, which applies to small entities (primarily small businesses).


16. How would you describe the wildlife viewing operation? (Mark one or more)

17. Number of boats/vessels at the operation:

Questions 16 and 17 ascertain the type and size of the operation. This information will be used to develop a profile of the business, which will inform cost and earnings calculations.

Question 18 is for whale watching operators only:

18. Number of whale watching participants per vessel in operation (capacity):

19. Number of participants per vessel in recreational cruise operation (capacity):

20. Number of kayakers per guided tour (capacity):

21. Number of divers/snorkelers per vessel in operation (capacity):

22. Number of wildlife observers (seabirds and other) per vessel in operation (capacity):

Questions 18-22 ask about the capacity of vessels in terms of the number of participants for each of the operator’s different vessels for each activity. This information will help assess supply capacity and will be used in cost/earnings calculations.


23. Number of employees at the operation:

a. Full time ____________ b. Part time____________ c. Seasonal____________

Question 23 will gather data on the number of employees at the operation. Employee numbers and status will help determine the size of the operation and costs.


24. Number of vessel trips/guided tours per day (primary purpose):

Whale watching ___________

Recreational cruise ___________

Fishing ___________

Kayaking ___________

Diving/snorkeling ___________

Seabird viewing ___________

Question 24 gathers information on the number of trips per day and will help researchers understand the magnitude of participants/customers in the area, as well as the percentage of business that is dedicated to wildlife viewing, as opposed to other services.


25. Please provide your best estimate for annual operating expenses (i.e., docking fees, permits/licenses, maintenance and repair, and office expenses) last year.

Information gathered from Question 25 will be used with revenues to assess the profitability of the operation that can be used to assess the impacts of management options or other factors on individual businesses and the industry as a whole.


26. Please provide your best estimate for trip related expenses (i.e. food/supplies, bait, captain and crew wages, equipment costs) last year.

Question 26 asks about additional annual expenses from the previous year. This information will help researchers to calculate the operation’s total operating costs.


27. Please provide your best estimate of your total business revenues last year.

Question 27 asks about the operation’s total revenue from last year. Revenue information is essential for understanding profits and the size of the local industry.


28. Please provide your best estimate of your total revenues and/or percent of total revenue last year in Monterey Bay National Marine Sanctuary. $ ______________ % _____

Question 28 focuses on total whale watching and marine wildlife observation operation revenues for the past year in MBNMS.


Questions 29 – 31 pertain to whale watching operators only:

29. What is the minimum number of whales that need to be seen in order to make the trip worthwhile financially?

30. What is the minimum number of customers/attendants that need to be booked in order to make the trip worthwhile financially?

31. If you do not see any whales on the trip, do you reimburse customers?

31a. If YES, how do you reimburse customers?

Questions 29 – 31 gather information on the threshold of probable success before a vessel operator agrees to go out, as well as the impact of unsuccessful trips, meaning trips made when no whales are spotted. The latter information is useful in determining how much loss is associated if whales are not encountered during a whale watching trip.


32. Use by activity and month:


Question 32 collects information on the person-days by activity type for the business over a twelve-month period. A person-day is one person doing an activity for a whole day or any part of the day. This measurement corresponds generally to what the operations record in their logbooks as the number of passengers taken to a specific location on a specific day. There is some potential for double-counting across activities, so totals across activities is asked and it is not required that the sum by activity equal the total. This type of information has been collected previously by ONMS to ascertain the spatialized recreational value of marine protected areas in the CINMS and the Florida Keys National Marine Sanctuary.1


33. Mapping Exercise: Map the Distribution of Each Activity

Respondents will be advised to provide information on their anticipated spatial use of the Monterey Bay. This anticipated spatial use may be the same as their current use or it may be different. Respondents will be given a 100 penny budget, meaning one penny equals one percent of passenger activity. The respondent will allocate his or her budget across all map cells. Codes will be recorded on the coding sheet. The map cells will be referenced by column and row: For example, C1R1 1% means 1% of activity is in cell Column 1 Row 1. The percent of each activity must add up to 100.


34.  Does this map reflect where you presently operate?  Y/N

34a. If NO, please explain why future operations may be different than where you have historically operated.


Question 33 is needed to obtain a detailed spatial resolution of “expected person-days”. The purpose of this information is to assess the potential impacts of alternative management scenarios on the wildlife viewing industry. This evaluation is by its nature forward looking, thus past spatial distribution of effort may not be a good representation of future impact. Wildlife viewing tour operators will be asked to provide the percent distribution of where they expect to undertake their future effort (i.e., their anticipated spatial use area) by type of activity at spatial resolutions of 1-minute by 1-minute of one nautical square mile grid cells. It is important to note that a respondent’s future anticipated spatial use area might be similar or identical to their current or past use area. Detailed maps will be provided with NOAA nautical chart layers with latitude and longitude lines, as well as key reference points such as benthic structure and depth contours. The person-day totals provided in Question 32 will provide the information to weight percentage distributions across operations when extrapolating to population totals by spatial unit. A copy of the map that will be used for data collection is included with this package. This type of information has been collected previously by ONMS to ascertain the influence of a marine protected area designation on the economic condition of commercial fishermen and recreational boat operators in CINMS and the Florida Keys National Marine Sanctuary.2 Additionally, similar data have been collected for the Flower Garden Banks National Marine Sanctuary in the Gulf of Mexico, although data from this report have not been published to date.


Questions 34 and 34a clarify if the distribution is for current or future movements.


35. Currently, there are no regulations in MBNMS that require an "approach distance" to whales and other wildlife. However, there are official NOAA Fisheries guidelines that recommend wildlife viewing vessels maintain a minimum distance of 100 yards/meters from whales and wildlife. Does your operation have any kind of established policy regarding a minimum distance your vessels maintain from whales and wildlife? _____ YES  ______ NO

35a. If YES, what is your company's approach distance policy?


36. If a regulation were to be passed that would require an approach distance to whales and other wildlife, how strongly would this regulation affect your business?


37. Please give a brief explanation of how you think your business would be affected if a regulation were to be passed that would require an approach distance to whales and other wildlife.


38. If a regulation were to be passed that would require an approach distance to whales and other wildlife, which of these options do you think would be most affected regarding your business?


Questions 35-38 provide important information for MBNMS should we choose to move forward with a regulatory approach to establish an approach distance between wildlife and operators. It is beneficial to know if wildlife viewing tour operators already are adhering to official NOAA Fisheries guidelines or even a self-imposed approach distance policy. Collecting this information will give MBNMS stakeholders fair representation in the design of management strategies by providing information to support the assessment of socioeconomic impacts of management alternatives. The information collected also has potential to be used by resource managers for future outreach and education purposes.


Compliance with Information Quality Guidelines

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NOAA National Ocean Service, Office of National Marine Sanctuaries 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 subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554. All analyses and reports developed in this project will be peer reviewed before release to the public.


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.


No automated, electronic, mechanical, or other technological or other forms of information technology are being used. All surveys with whale and marine wildlife watching operators will be conducted face-to-face and will be recorded on paper forms.



4. Describe efforts to identify duplication.


The research team consulted with resource managers at the MBNMS to determine what types of socioeconomic data collection activities were planned or presently ongoing in the region related to whale and marine wildlife watching industries. To avoid survey fatigue and overburdening business owners with data collections, the team consulted with researchers who have projects underway or planned to determine if there was overlap of target populations. We identified no projects that included our target population of whale and marine wildlife watching operators for collections. The literature review did not reveal any more recent efforts completed or underway to collect similar information. Additionally, representatives of the ocean recreation industry were consulted to inquire about whether they were currently or recently involved in the same or similar type research. The response from both individuals was negative.


Researchers conducted a literature review to determine if and to what extent existing information might meet the needs of MBNMS.


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


All the business entities in this information collection request can be classified as small businesses. Our approach is not to send out questionnaires to be filled out by respondents. Rather, to increase efficiency and reduce the respondent’s burden, we will send out an information collection team to the home or office of the business owner/operator. The information collection team will work with the respondent to complete the information collection. When arranging information collection interviews, our approach is to discuss the types of information we will be asking for during the interview. This enables the respondent to prepare before the interview, gathering any important records or documents that might be needed by the team. For example, for the cost-and-earnings questions, financial records are needed. Similarly, for the spatial use information, access to trip logbooks is generally required.


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


Without this collection, a critical data gap will remain that could inhibit the ability for resource managers to conduct a thorough social impact assessment that will inform the Management Plan Review process.


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


All data collection will be consistent with OMB guidelines.

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 October 29, 2018 (83 FR 54317) for public comment. No comments received. Since this collection has not started, we do not have respondent comments on burden accuracy etc.


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


Procedures have been established to protect the proprietary information provided by respondents. All personal identification information will be removed from all databases sent to NOAA or distributed to the public. Each individual respondent will be assigned an identification number in the database so the data from different portions of the survey can be linked for analysis. Release of proprietary information is further protected by the Freedom of Information Act (5 USC 522 (b) (4)) concerning trade secrets or proprietary information, such as commercial business and financial records. All non-personal or non-proprietary information will be available for distribution.


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 such questions will be asked.


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


The affected public for this collection are the owners or managers of whale/marine wildlife watching businesses in the Monterey Bay Region. We estimate that there are 56 or fewer relevant businesses in the region. We expect that it will require an average of 2.5 hours of interview/record compilation time to complete each data collection per respondent. This time can be roughly divided into 1 hour for record compilation by the respondent in preparation for the interview, and then 1.5 hours of working with our interviewers to fill out and check the forms completed during the actual interview. We anticipate completing interviews with the entire population of commercial whale/marine wildlife watching operators in the study area. We anticipate full cooperation with the clear understanding that responses to the survey questions remain anonymous. The members of this business community are interested in understanding their contribution to the local economy and the value of wildlife to their operation. Thus, we are requesting a total of 140 burden hours for this collection.


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 cost to respondents beyond burden hours.


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


The cost to the Federal government for contract services, supplies, equipment, travel, etcetera, is approximately $28,000 for FY2015. There is no anticipated cost in these budget categories for FY2016. The total annual cost for Federal labor on the project is approximately $42,000 for FY2015 and $42,000 for FY2016. Averaging the totals of $70,000 ($28,000 + $42,000) and $42,000, the annualized total is $56,000.


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


There are no program changes or adjustments.


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


All reports will be peer reviewed per NOAA standards under the Information Quality Act and posted on the ONMS Socioeconomic Web site:


http://sanctuaries.noaa.gov/science/socioeconomic


A new page(s) will be set up on this website to provide the project report to the general public. All data and documentation will be put on CD-ROM and will be made available to the general public, subject to any masking of the data required to protect privacy.


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.

1 Leeworthy, V.R. and P Wiley. 2003. Socioeconomic Impact Analysis of Marine Reserve Alternatives for the Channel Islands National Marine Sanctuary. Silver Spring, MD: U.S. Department of Commerce, NOAA.; Jeffrey, C.F.G., V.R. Leeworthy, M.E. Monaco, G. Piniak, M. Fonseca (eds.). 2012. An Integrated Biogeographic Assessment of Reef Fish Populations and Fisheries in Dry Tortugas: Effects of No-take Reserves. NOAA Technical Memorandum NOS NCCOS 111. Prepared by the NCCOS Center for Coastal Monitoring and Assessment Biogeography Branch. Silver Spring, MD. 147 pp.

2 Leeworthy, V.R. and P Wiley. (2003); Jeffrey, et al. (2012).

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