Discussion Paper April 2019

D5 Economic Data Reporting
APRIL 2019

Discussion Paper:
Alaska Region Economic Data Reporting Programs
March 22, 20191
1
2
3

Executive Summary ................................................................................................................................................2
Introduction ........................................................................................................................................................... 14
Scientific and Analytical Standards ....................................................................................................................... 16
3.1 Requirements and Guidance for Economic Analyses .................................................................................... 16
3.2 Business data collection design and evaluation ............................................................................................. 19
3.2.1 Measurement objectives and data applications................................................................................... 20
3.2.2 Data quality principles and guidance................................................................................................... 22
4 Description and History of Economic Data Collection ........................................................................................... 27
4.1 Overview of national fisheries economic data collections .............................................................................. 27
4.1.1 Summary of the Northwest Groundfish Trawl Rationalization Economic Data Collection Program..... 31
4.2 Review of North Pacific economic data collections ........................................................................................ 31
4.2.1 Non-EDR data sources of fisheries economic data ............................................................................. 31
4.2.2 Overview of current EDR program framework..................................................................................... 32
4.2.3 Current EDR Data Collections............................................................................................................. 35
4.2.3.1 Crab rationalization program EDR ................................................................................................. 35
4.2.3.2 Amendment 80 economic data EDR .............................................................................................. 37
4.2.3.3 Amendment 91 Chinook salmon EDR ........................................................................................... 38
4.2.3.4 Gulf of Alaska trawl EDR ............................................................................................................... 41
4.2.3.5 Summary overview of EDR variables by EDR form ....................................................................... 42
4.3 Historical overview of EDR development process ......................................................................................... 48
5 EDR Program Operations, Costs, and Limitations ................................................................................................ 59
5.1 Summary of EDR program operations ........................................................................................................... 59
5.1.1 Data collection to-date ........................................................................................................................ 59
5.1.1.1 Summary of EDR forms submitted and reporting compliance ....................................................... 59
5.1.1.2 Data verification/audit administration ............................................................................................. 60
5.1.1.3 Program expenditures and cost recovery ...................................................................................... 63
5.1.1.4 Estimated costs to industry of preparing and submitting EDRs ..................................................... 66
5.2 Limitations of EDR data ................................................................................................................................. 69
5.2.1 Data quality limitations in current EDR data collection ........................................................................ 70
5.2.1.1 Crab EDR ...................................................................................................................................... 70
5.2.1.2 Amendment 80 EDR ...................................................................................................................... 70
5.2.1.3 Amendment 91 EDR ...................................................................................................................... 70
5.2.1.4 GOA Trawl EDR ............................................................................................................................ 71
5.2.1.5 Usability ......................................................................................................................................... 72
5.3 Applications of EDR data in analyses ............................................................................................................ 74
5.3.1 EDR Data Annual Reporting ............................................................................................................... 74
5.3.2 Council program reviews ..................................................................................................................... 74
5.3.3 Use of EDR Data in Analyses ............................................................................................................. 75
5.3.4 Analyst Feedback................................................................................................................................ 76
6 EDR Program Assessment and Recommendations ............................................................................................. 78
6.1 Short(er) term, practical recommendations to: ............................................................................................... 78
6.2 Long(er) term, recommendations to improve economic data collection processes: ....................................... 78
7 References............................................................................................................................................................ 79
Appendix A ................................................................................................................................................................... 83
Appendix B ................................................................................................................................................................... 89

1

Prepared by Brian Garber-Yonts (Alaska Fisheries Science Center (AFSC), Economics and Social Science Research Program
(ESSRP)), Stephen Kasperski (AFSC ESSRP), Sally Bibb (NMFS Alaska Region, Sustainable Fisheries Division (AKR), and Scott
Miller (AKR).

Accessibility of this Document: Effort has been made to make this document accessible to individuals with disabilities
and compliant with Section 508 of the Rehabilitation Act. The complexity of this document may make access difficult
for some. If you encounter information that you cannot access or use, please call us at 907-271-2809 so that we may
assist you.

D5 Economic Data Reporting
APRIL 2019

1

Executive Summary

This discussion paper provides information and recommendations about the four Economic Data
Reporting (EDR) programs that the North Pacific Fishery Management Council (Council) and the
National Marine Fisheries Service (NMFS) have implemented in the federally managed groundfish and
crab fisheries off Alaska. The EDRs gather various levels of ownership, revenue, cost, vessel operations,
and employment information from vessel owners, vessel operators, processors, permit holders, and
leaseholders who participate in several of the catch share programs in the North Pacific fisheries. In
general, the purpose of the EDR requirements is to gather information to improve the Council’s ability to
analyze the economic effects of catch share or rationalization programs, to understand the economic
performance of participants in these programs, and to help estimate impacts of future issues, problems, or
proposed revisions to the programs covered by the EDRs.
The following four EDRs are addressed in this discussion paper:
●
●
●
●

BSAI Crab EDR, implemented in 2005 (Crab EDR);
Trawl Catcher/Processor (CP) EDR implemented in 2007 for Amendment 80, and in 2015 for
CPs operating in the GOA groundfish fisheries (A80 EDR);
BS Chinook salmon bycatch management program EDR for participants in the BS pollock
fishery, implemented in 2012 (A91 EDR); and
GOA trawl EDRs for trawl catcher vessels operating in the GOA and processors taking deliveries
from these vessels, implemented in 2015 (GOA Trawl EDR).

The Council discussed the EDRs in several meetings during 2018. Public testimony at the February and
April 2018 Council meetings noted that the EDR programs had been in effect for some time and
testimony focused on whether the EDR requirements for the GOA trawl catcher vessels and processors
had met the Council’s purpose and need to collect baseline information to assess the impacts of a
potential future GOA catch share program. Also at the April 2018 meeting, the Council reviewed a
discussion paper prepared by NMFS that provided information related to NMFS’s request that the
Council review all of its regulations to identify any that were outdated, unnecessary, ineffective or could
be further streamlined (NMFS, 2018) which included a reference to the Council’s February 2018
discussion of the EDR requirements as a possible area of regulations for future Council review. Later in
the April 2018 meeting, in response to this public comment and further discussion among Council
members, the Council requested that NMFS prepare a discussion paper that describes the EDR
requirements for all programs, explains how the data are used, and provides estimates of the costs of
complying with the EDR requirements. The Council’s motion stated that the Council could then use the
information in the discussion paper to determine if revisions to EDR requirements are needed and, if so,
the priority and process for analysis of proposed revisions. This discussion paper provides the information
requested by the Council in April 2018.

Requirements and Guidance for Economic Analyses
A variety of Federal laws and Executive Orders require the preparation of a written analysis of the
economic impacts of proposed fishery conservation and management actions developed by the Council.
Foremost among these are the Magnuson Stevens Fishery Conservation and Management Act (MSA), the
National Environmental Policy Act (NEPA), the Regulatory Flexibility Act (RFA), Executive Order
(E.O. 12866), and, more recently, E.O. 13771.
The MSA requires that the Councils prepare fishery management plans for each fishery under its
authority that requires conservation and management (section 302(h)(1)), with Section 303 of the MSA
specifying the contents of the FMPs. Many of these content requirements are related to economic aspects
of the fisheries, including requirements for information about the participants, gear types, operational

Economic Data Reporting – Discussion Paper, April 2019

2

D5 Economic Data Reporting
APRIL 2019
modes, harvest levels, revenue, and the cost likely to be incurred in management. The MSA also requires
that any FMP or FMP amendment must be consistent with ten national standards (section 301(a)). Each of
the national standards has some relation to economic aspects of the fisheries. However, the most direct
references to economic impacts are in National Standard 1(NS1) which relates to achieving optimum
yield, National Standard 4 (NS4) which mandates the fair and equitable allocation of fishing privileges,
National Standard 5 (NS5) which requires consideration of efficiency and prohibits economic allocation
as the sole purpose of an action, National Standard 7 (NS7) which requires minimization of costs, and
National Standard 8 (NS8) which requires consideration of the importance of fishery resources to fishing
communities and specifically references using the best available economic and social data.
Determinations about the consistency of a proposed action with the National Standards relies, in large
part, on the economic analysis prepared for a proposed action. In addition to the general requirements of
the MSA, section 303(b)(6) contains a specific list of factors that the Council and Secretary of Commerce
must take into account when establishing a limited access system for a fishery. Most of these factors are
related in some way to economic considerations.
NEPA requires Federal agencies to consider the interactions of natural and human environments, and the
impacts on both systems of any changes due to governmental activities or policies. In addition, NOAA’s
NEPA implementation guidelines require that the environmental impact statement (required under NEPA
Sec. 102(2)(C)(i)) include biological, ecological, economic, and social consequences. Social science data
and the models they support are needed to conduct the required analyses and to predict the behavioral
response of fishermen and others that affect the biological, ecological, economic, and social consequences
(AFSC 2019).
The Regulatory Flexibility Act (RFA), requires agencies to consider the impact of their regulatory
proposals on small entities, to analyze effective alternatives that minimize small entity impacts, and to
make their analyses available for public comment (SBA, 2010). Small entities are identified based on
either an income or employment threshold. The RFA requires analysis of the costs and burden of
information collection requirements on industry participants.
E.O. 12866 (58 FR 51735, October 4, 1993) is the primary Presidential Executive Order that requires the
preparation of economic analyses of regulations implementing fishery conservation and management
actions. Council and NMFS staff comply with E.O. 12866 by preparing a Regulatory Impact Review
(RIR) for each conservation or management action that will be implemented through Federal regulations.
NMFS issued guidelines for the preparation of economic analyses to meet the requirements of E.O. 12866
and the RFA, two of the most direct mandates for the preparation of economic analyses. “Guidelines for
Economic Reviews of National Marine Fisheries Service Regulatory Actions” (NMFS, 2007) addresses
the procedural and analytical requirements of E.O. 12866 and the RFA. The guidelines state that
“[A]lthough a benefit-cost analytical framework is prominent in meeting the intent of E.O. 12866, it also
requires broad consideration of the distributive effects and economic burden that may be imposed on
individuals, businesses of differing sizes, as well as small communities and governmental entities…
Meeting the broad analytical requirements of E.O. 12866 requires consideration of both benefits and costs
of regulatory alternatives from a National perspective, as well as from that of the private individual or
firm.” In addition, the RIR must provide the information necessary to evaluate the change in net benefits
to the Nation from each of the alternatives, and not just for the preferred alternative or proposed action.
NMFS’s guidelines do not prescribe particular economic analysis methods, a required level of analysis, or
specific data collection elements, but state that the analysis “should include a good qualitative discussion
of the economic effects of the selected alternatives. “Quantification of these effects is desirable, but the
analyst needs to weigh such quantification against the significance of the issue and available studies and
resources.” The appropriate analysis depends “on circumstances to be analyzed, available data, the
accumulated knowledge of the fishery and other potentially affected entities, and on the nature of the

Economic Data Reporting – Discussion Paper, April 2019

3

D5 Economic Data Reporting
APRIL 2019
regulation option.” However, the guidelines also state that “a quantitative analysis should be substituted
for a qualitative analysis whenever feasible (i.e., when adequate data, resources, and defensible analytical
models are available).”
More recently, E.O. 13771 was issued on January 30, 2017. This E.O. is intended to manage the costs of
government regulation on private industry and is the source for the policy that two deregulatory actions
are needed for every regulatory action that is significant under E.O. 12866 and that imposes costs on
industry. To comply with this E.O., NMFS prepares a worksheet for each proposed rule that identifies
whether the proposed action is reducing costs or imposing costs and, if known, the amount of the cost or
cost savings. NMFS relies on the RIR to provide the necessary information about the costs of a proposed
rule.

Data collection design and data quality guidance
Many of the processes involved in developing and implementing a larger and more complex data system,
such as eLandings, are required for operation of the EDR program. The North Pacific fishery information
system in regards to the human environment can be broadly divided between administrative record
systems designed for primary uses in in-season fishery management and statistical surveys that are
defined by the Office of Management and Budget (OMB) as those employing statistical methods, i.e., “a.
collecting data using any survey methods; b. doing any kind of estimation, imputation, or weighting; or c.
pretesting or field testing for a survey, including cognitive interviews or focus groups from a total of 10
or more people.” Examples of administrative record systems include fishery permit registries, ADF&G
fish tickets and Commercial Operators Annual Report, AKR’s catch accounting system, and other data
collections associated with record keeping and reporting requirements under federal or state fishery
regulations, while statistical surveys include surveys of recreational anglers to assess their catch, effort,
and value derived from fishing, social surveys of participant demographics, distribution, and preferences,
and the EDR forms.
The distinction between the EDR program and administrative data systems is important for several
reasons. Administrative data are used routinely by agency staff to execute specific regulatory procedures,
in many cases producing direct effects on specific regulated entities. Because these elements in the EDR
Program closely resemble features of NMFS and ADFG administrative reporting forms, however, EDR
submitters may confuse the distinct purpose and permissible uses of EDR data collections from those
associated with administrative reporting requirements, and convey expectations for data quality
requirements appropriate to the latter that may be excessive for the intended uses of EDR data. For
example, while a vessel may not be able to precisely calculate the vessel maintenance cost associated with
a specific fishery, monitoring the changes in overall fleet costs over time can provide insight into how a
catch share program impacts the costs of participants.
Consistent with principles stated in PRA review guidelines, NOAA Information Quality (IQ) guidelines
acknowledge that “accuracy” is not an absolute metric, but must be assessed on the basis of whether
information is “within an acceptable degree of imprecision or error appropriate to the particular kind of
information at issue and otherwise meets commonly accepted scientific, financial, and statistical
standards, as applicable;… original and supporting data that are within an acceptable degree of
imprecision, or an analytic result that is within an acceptable degree of imprecision or error, are by
definition within the agency standard and are therefore considered correct.”
National Standard 2 (NS2) develops additional data quality guidance beyond NOAA IQ Guidelines that is
particularly applicable to evaluation of EDR data and information considered in developing and
evaluating EDR data collections. The criteria established in NS2 are intended to be used when evaluating
best scientific information are relevance, inclusiveness, objectivity, transparency and openness,
timeliness, verification and validation, and peer review, as appropriate.

Economic Data Reporting – Discussion Paper, April 2019

4

D5 Economic Data Reporting
APRIL 2019
Overview of current EDR program framework
Each of the EDRs was developed through the Council’s FMP and regulatory development and review
process, beginning with the specification of purpose and needs for the data collection and the
development, analysis, and selection of a preferred alternative. In reaching final action on preferred
alternatives for each new or revised EDR, the Council has specified submission requirements,
administrative procedures, and enforcement mechanisms for the data collections, and in all cases included
detailed descriptions of the information content of EDR forms in their regulatory recommendations to
NMFS.
In EDR development and ongoing oversight, the Council has relied on committees and/or workgroups of
varying industry, agency, and/or scientific composition and purpose, and has varied in its responsiveness
to AP and SSC review recommendations. Notwithstanding differences in EDR form content and specific
elements of implementing rules (e.g., target populations) between the four EDRs, the general structure of
the EDR program is largely consistent with that of the original Crab EDR as developed by the Council
and implemented by NMFS. Each of the four EDRs employs mandatory annual censuses of the target
populations of designated reporting entities participating in the associated fishery management programs,
and all include provisions for third-party data verification audits in the implementing rules.
Within the recommended framework developed by the Council, the EDR program is managed jointly by
AKRO and AFSC (primarily by the Economic and Social Sciences Research Program (ESSRP)), with
Pacific States Marine Fisheries Commission (PSMFC) acting as NMFS’ Data Collection Agent (DCA).
PSMFC provides primary administrative support for collection and database management for all four
EDR collections. AFSC and PSMFC collaborate on development and maintenance of workplans for
implementation of new or revised EDRs, including development of Scope of Work documents and RFP
procedures for soliciting and selecting bids for required IT application development and Data Verification
Audit work subcontracted by PSMFC, AFSC monitors implementation and oversees quality control of
PSMFCs administrative process and communication with submitters.
Current Crab rationalization program EDR
The Crab EDR is comprised of three EDR forms developed for the respective sectors: the Crab CV EDR,
Crab Processor EDR, and the Crab C/P EDR. The CV and processor forms collect distinct sets of data
elements, with the CP form comprised of a combination of all data elements collected in the catcher
vessel form and applicable elements from the processor form. Crab CV and CP forms report ex-vessel
sales and quota lease costs by fishery and quota type; fuel gallons, provisions costs, bait costs, and total
labor payments to crew and captains by fishery, annual total fuel cost and gallons and annual total direct
labor payments to crew (inclusive of crab settlements); commercial crew license or CFEC permit number
for all crab crew members; and indicators of benefits provisions to captain and crew and tendering use of
the vessel. Crab processor and C/P forms collect valuation metrics for plant/vessel; crab product sales by
species, product and process code, and box size, custom processing services provided and fee revenue,
raw crab purchases and processing quota lease costs by fishery and quota type; custom processing
services purchased and cost, processing labor gross wages and paid hours by fishery; processing
employee count by location of residence; and non-processing employment and total annual gross wages
and salaries.
Amendment 80 economic data EDR
The A80 EDR form has been submitted annually by A80 QS holders since 2008, collecting quantitative
data for a comprehensive set variables. The form collects vessel characteristics and registry details, survey
value, fuel consumption rate and annual total gallons consumed by operating activity, freezer storage and
throughput capacity, and processing line throughput capacity by species and product. Annual revenue is

Economic Data Reporting – Discussion Paper, April 2019

5

D5 Economic Data Reporting
APRIL 2019
reported from fishery product sales, quota leases, and other vessel operations income. Annual total capital
expenditures are reported for fishing gear, processing equipment, other equipment, and other vessel
capital; and annual non-labor vessel operating expenses are reported for fuel, lubrication, provisions,
repair and maintenance, vessel/equipment lease costs, fishing gear purchases, leases and repair costs,
freight and storage costs for product sales, other freight and storage, materials, observer fees and
reporting/monitoring costs, cooperative fees, general administrative/management overhead, vessel
insurance, fisheries landing taxes, total cost and volume of raw fish purchases, and QS lease quantity and
costs by A80 species. Gross labor costs are reported for deck crew, processing crew, and all other onboard crew, and average crew size and annual employment grouped by deck, processing, and all other onboard crew, and the use of share-based compensation for processing non-processing crew is indicated.
Beginning in 2016, the revised Annual Trawl CP EDR added collection of individual commercial crew
license or CFEC gear operator permit numbers for all individual crew members that worked on the vessel
during the calendar year.
Amendment 91 Chinook salmon EDR
The Amendment 91 EDR is comprised of three separate forms: the Compensated Transfer Report, the
Vessel Fuel Survey, and the Vessel Master Survey.
The Compensated Transfer Report (CTR) is intended to collect transaction-level data on all bipartite
transfers of Chinook PSQ allocation units during the pollock season in which monetary payment is
included the transaction (i.e., “in-kind only” transactions are exempted). The form is to be completed by
all entities participating as lessor or lessee in one or more "compensated transfers" of Chinook PSC;
however, no such transactions have been reported, and all CTR form submissions to date have been
“certification-only” submissions.
The Vessel fuel survey is required for all AFA vessels that harvested BSAI pollock during the previous
year, and collects four data elements, including: average hourly rate of fuel consumption for the vessel
while operating in the BSAI pollock fishery, reported separately for fishing and transiting; and total
annual amount (in gallons) of fuel loaded to the vessel during the year, and total fuel cost.
The vessel master survey is comprised of a series of qualitative response questions regarding fishing and
bycatch conditions observed by vessel masters during the BSAI pollock fishery, and factors in effect that
motivated Chinook bycatch avoidance.
The structure of the A91 EDR is distinct from the other three EDRs in that it is modular, with AFA vessel
owners as the primary submitter group, from which all three of the forms are required. The CTR form is
also required from PSC entities, for whom it is the only EDR requirement.

Gulf of Alaska trawl EDR
The Trawl CV EDR form is required for all trawl CVs that harvested groundfish in the GOA during the
previous year. The GOA Trawl CV EDR form collects the estimated market value and replacement value
of vessel; fishing gear costs; lease, installation and repair of (a) salmon and halibut excluder gear, and
(b) trawl gear; annual total fuel and lubrication cost and gallons; total labor payments to (a) crew and
(b) captain, and number of crew, for GOA groundfish only; and commercial crew license number or
CFEC gear operator permit number, by individual crew member that worked on vessel during GOA
groundfish trawl fishing.
The Annual Shoreside Processor EDR form is required from all shore-based processors that receive and
process groundfish from GOA trawl fisheries. These forms collect the estimated market value; Borough
assessed value or replacement value; municipal water utility consumption, gallons and cost, by month for

Economic Data Reporting – Discussion Paper, April 2019

6

D5 Economic Data Reporting
APRIL 2019
Kodiak plants only; municipal electrical utility consumption, kilowatt-hours and cost, by month for
Kodiak plants only; processing labor gross wages and hours for groundfish processing only, by month
and housing-status (housed, non-housed); number of processing employees, by month, groundfish only;
and total annual non-processing employment, number employed, total wages and salaries.
Summary overview of EDR variables by EDR form
An examination of all data elements collected in the EDR program as a whole (with the exception of the
A91 Vessel Master Survey) indicates a number in inconsistencies, at different scales, across EDR forms.
The most obvious disparity is the relative comprehensiveness of the content reported in the A80 EDR
form, which efficiently collects measures of the physical capital stock of the vessel, and collects revenue
and costs using a framework that is fairly consistent with standard financial accounting categories. In
contrast, crab CV and CP EDR forms collect fewer categories of operating costs but require stratification
by individual crab fishery. At a finer scale, there are notable inconsistencies across EDR forms in the
specification of individual data items, as in the GOA CV reporting of trawl gear and excluder devices
combines capitalized expenditures (paid over multiple years) with annual expenses, compared to separate
treatment of fishing gear capitalized and expense costs in the Trawl CP form. Also, notably, the GOA CV
form includes three alternate scales of reporting: values aggregated to total annual value, GOA trawl
value, and GOA groundfish value.

Historical overview of EDR development process
A review of the documentary history of the Council and NMFS efforts to develop economic data
collections spans 20 years of Council minutes and federal register notices. The timeline is drawn largely
from Council minutes and follows the course of significant actions and events in the development of each
of the respective EDR collections, initially through the Council process, followed by rule-making and
OMB review processes, to administration of annual EDR submissions and production of data.
The original draft Crab EDR forms developed by the Council-appointed data collection committee were
adaptations of a previously fielded voluntary survey in the pollock fishery in 2000 and were intended to
support the production of the same set of standard economic and financial performance metrics that
pollock industry and AFSC economists had spent two years developing. As such, the committee retained
an equivalent scope of variables in the Crab EDRs but increased the level of disaggregation. However, in
order to address community effects of rationalization, the crab forms added disaggregation by location of
purchase for most of the cost variables. The result of the additional layers of stratification resulted in
surveys of daunting complexity; however, industry representatives on the data committee were
nonetheless confident that they could be completed and pretesting of the forms with a small number of
volunteer vessel owners and accountants was reasonably successful.
The design of the A80 EDR also started by adapting the voluntary pollock CP survey and relied on the
same conceptual framework of measures and metrics. The Council’s purpose and need for the A80 EDR
was more narrowly focused on assessing economic performance within the A80 sector, and in particular,
the effectiveness of efficiency gains achieved by the program in mitigating operational costs of bycatch
avoidance measures. As such, rather than increasing the complexity of the pollock survey by adding
additional stratification, the A80 survey simplified the original by eliminating by-fishery disaggregation
and limited required reporting to annual aggregate values for most variables. As a result, the reporting
burden and cost are much lower, the accuracy of the data reported is sufficient for use in most
applications, and the analytical framework originally conceived in the design of the EDR has been
effectively applied in the A80 5-Year Review and is used as the basis for annual updates of the A80
chapter of the Groundfish Economic SAFE. However, in simplifying the A80 EDR from the more
disaggregated detail used in the pollock survey, significant data quality may have been sacrificed, but this
has not proven to be a critical limitation for the Council’s purpose thus far.

Economic Data Reporting – Discussion Paper, April 2019

7

D5 Economic Data Reporting
APRIL 2019
The outcome of the original Crab EDR was markedly different. The two-step approach used in the
pollock survey, reporting annual aggregate values in the first step, followed by disaggregating fisherylevel values in the second step, may have prevented some of the ensuing problems. This would likely
have been straightforward and unchallenged on the basis of accuracy or burden. The complexity of the
crab EDRs, however, resulted in excessive burden and heightened doubts about the quality of the data.
Annual-level data would also have been made available to Council staff much sooner and synthesized
into information of utility to the Council much sooner, with a clearer path to rebalancing the burden and
data quality in revising the EDR design.
Beginning in February 2008, the Council initiates a metadata review process recommended by PNCIAC,
specifying a series of public meetings for staff to present EDR metadata, receive comments and
recommendations provided by PNCIAC and the public and then to be incorporated “as appropriate” into a
revised draft metadata document, and final comments and recommendations resulting from the review to
be provided to the Council by PNCIAC. The result of that process was the introduction of an A/B/C data
quality grade, summarizing the comments and recommendations AFSC received from PNCIAC and crab
industry members as a summary indicator of data quality in the EDR metadata.
The Council took final action at the December 2009 meeting on its preferred alternative for the A91
Chinook salmon EDR, which pursued a narrow data collection and analytical objective focused on
assessing the effectiveness of specific bycatch avoidance incentives measures under Amendment 91. The
preferred alternative limited cost data collection to two items relevant to bycatch avoidance choice
behavior (fuel and Chinook salmon PSC). The alternatives considered for analysis did not include
additional data collection items and analytical methods recommended by AFSC to more fully capture the
direct and opportunity costs of bycatch avoidance and other factors forming the economic context of
bycatch avoidance choices.
The discussion paper reviewing economic data collection objectives and associated data needs was
presented at the February 2010 meeting. The paper covered some of the same history discussed here and
offers additional insights on the process. The paper made several recommendations, three of which appear
to have been influential in subsequent Council actions: data collections should be: (1) implemented
independent of major management actions; (2) limited to data that inform management decisions, are not
duplicative, and can be accurately and cost effectively collected; and (3) should be developed deliberately
and incrementally. The Council tasked staff to begin an analysis of the Crab EDR, resulting in the
developing Amendment 42, in which the Council altered its purpose and need but is unclear to what
degree this purpose and need modified or superseded what had previously been conveyed as the
fundamental purpose of economic data collection in the purpose and need statements and analyses for the
Council’s previous action. Previously, the purpose of economic data collection had been described in
analyses as collecting data to permit economic analysis, using specific metrics recognized by economists
and policy makers as indicators of economic performance.
Relatively soon after the Council adopted their preferred alternative for Amendment 42 amending the
crab EDR program, the Council approved a motion tasking a discussion paper developing proposed
elements and options on a baseline economic data reporting program for Western and Central GOA trawl
industries, including harvesters, processors, and catcher processors. In June 2013, the Council reviewed
the draft RIR/IRFA for GOA Trawl Data Collection and adopted a modified Alternative 2 as the
preliminary preferred alternative. (PPA). On final review in October, the Council adopted the preferred
alternative, developing the GOA Trawl EDR, revising the A80 EDR form, requiring a third-party data
collection agent and blind data protocol for CV and shoreside processor data, and data verification
consistent with Crab EDR audit protocols. OMB approved the PRA clearance for the GOA trawl EDR in
December 2014, with a June 2016 deadline for the first year’s EDR submission. The Council postponed
further action on GOA Trawl Bycatch Management in its December 2016 meeting, but the GOA Trawl
EDR reporting requirements remain unchanged.
Economic Data Reporting – Discussion Paper, April 2019

8

D5 Economic Data Reporting
APRIL 2019

EDR Program Operations, Costs, and Limitations
Summary of EDR program operations
Data Collection to date
Summary of EDR forms submitted and reporting compliance
In the three years in which all four EDRs have been collected (2015-2017), an average of 376 forms are
returned annually, with the Crab EDR representing 90 forms, A80 accounting for 19 forms, GOA trawl
CVs averaged 68 forms while there were 10 shoreside processor forms returned, and the A91 EDR
averaged 63 fuel survey forms and 118 vessel master surveys. Compliance with EDR submission
requirements is effectively 100%. Gross non-compliance with EDR submission requirements has been
limited to a small number of cases that involved bankruptcy and/or more extensive violations of federal
fishery regulations.
Data verification/audit administration
EDR data verification is required under EDR rules in 50 CFR 679 and 680. The rules state that “the DCA
shall...” (680.6), or “NMFS, the DCA, or the DDCA will…” (679 subsections 65, 94, and 110) “conduct
verification of information with [a person required to submit the applicable EDR or a designated
representative]”. In the subsections that follow this shall direction to the DCA, the rules require the EDR
submitter to respond to inquiries from the DCA within 20 days, require the submitter to provide
supporting records to the DCA as requested, and authorize the DCA auditor to review the records for the
purpose of substantiating values reported in the EDR.
EDR data verification currently employs a series of validation procedures, including 1) primary,
automated data validation procedures programmed and maintained by AKFIN on the EDR database, 2)
secondary validation employing statistical procedures and visual inspection to identify data anomalies and
statistical outliers, and 3) editing and imputation for data errors identified by data users that were not
detected and corrected in primary and secondary validation.
Two issues that have emerged from the practical experience of AFSC and PSMFC in working with CPA
firms under contract are especially worth noting: 1) in all audits reviews conducted since 2006, there has
not been a single finding of intentional misreporting, or of any bias in the direction of reporting errors
identified by auditors; and 2) verifying the quality of results produced by auditors requires considerable
effort by AFSC and PSMFC. On the latter point, contracting for the services of CPA firms to conduct
data validation audits is not straightforward, and the tasks involved are unfamiliar to CPAs and require
one or two iterations to gain experience. However, CPA firms face staff turnovers and can’t be relied
upon to maintain staffing stability for EDR contracts, and PSMFC is required to issue RFPs to renew
ongoing service every three years at minimum.
Program expenditures and cost recovery
This section describes the financial cost of implementing the EDR Program and identifies those costs
have been recovered from the fishing industry by the National Marine Fisheries Service. The focus is on
the cost recovery amounts rather than the full cost to the NMFS, because NMFS did not calculate the inkind contribution of staff time on EDRs until required to do so for cost recovery purposes.
Three of the four EDRs have some portion funded through cost recovery. The one exception is the GOA
Trawl EDR, which is not part of a catch share fishery and is therefore not subject to cost recovery.
Therefore, only the PSMFC administrative costs for the GOA Trawl EDR are included for comparison.

Economic Data Reporting – Discussion Paper, April 2019

9

D5 Economic Data Reporting
APRIL 2019
The other exception is the AFA pollock fleet, for which NMFS only collects cost recovery fees from the
in-shore (catcher vessel) sector.
The costs have been quite variable in the Crab EDR Program, which averaged $286,013 over all years,
and fluctuates largely due to changes in the cost of audits and the costs associated with database
administration, support, and changes to the EDR forms. Costs have remained relatively stable in the A80
EDR, averaging $90,733/year for the first three years of cost recovery (2016-2018). For the inshore sector
of the A91 EDR, the only sector from which EDR Program costs are now recovered, costs have averaged
$57,260 per year since costs have been recovered since 2016. The PSMFC administrative costs of
implementing the GOA Trawl EDR, have averaged $70,159 per year over the four years of the data
collection, with costs varying largely due to changes in the need for audits.
While these costs are not insignificant, they represent a small fraction of the ex-vessel value generated by
these fisheries, with EDR-related costs averaging 0.15% of the ex-vessel value for the Crab EDR, 0.09%
for the A80 EDR, 0.04% for the A91 EDR, and 0.10% for the GOA Trawl EDR. Ex-vessel values for the
Crab EDR, A80 EDR, and A91 EDR come from the annual cost recovery reports, while the values for
GOA Trawl represent their GOA Trawl related ex-vessel revenue for all vessels required to submit a
GOA Trawl EDR and were calculated directly by AKFIN.
Estimated costs to industry of preparing and submitting EDRs
Under the PRA, NMFS is required to obtain approval for new information collection requirements
implemented through Federal regulations and for voluntary requests for information. For each of the four
EDRs, NMFS provides estimates of the estimated number of respondents for each form or component
each year, the estimated hours it takes to submit the required information, the estimated cost per hour for
preparing and submitting each response, the estimated total cost per respondent, and the estimated total
cost for all respondents. The estimated total cost of submitting the required EDR information for each of
the four EDR programs approximately $312,000 per year for respondents to provide the information
required for the crab EDR; approximately $19,000 per year for the Amendment 80 and GOA trawl
catcher/processor EDR, approximately $48,000 per year for the GOA trawl catcher vessel and processors
EDR, and approximately $60,000 per year for the BS Chinook salmon bycatch EDR. These are the cost
estimates for submitting the required information and are in addition to the EDR administrative costs
described above, some of which are recovered from the industry through cost recovery.
One factor in the fairly wide range of costs to submitters across programs are the different estimates of
costs per hour among the EDR programs. The $37 per hour estimate is an average per hour cost estimate
used for many different forms in most of NMFS’ information collections and is applied in the A80 and
GOA Trawl EDRs, but an estimate of $165 per hour for the crab EDR and $75 per hour for the A91 EDR
are based on comments received on past EDR renewals with explanations of the type of expertise needed
to complete these particular EDRs and the associated costs per hour for people with this expertise. As
stated earlier, NMFS presents its burden hour and cost per hour estimates for public comment and
generally updates and revises them if it receives information that supports doing so.
Limitations of EDR data
Limitations of the EDR Program span a range of issues, and include limitations on the quality and utility
of the data collected in the respective EDR forms that arise from the conceptual design of the data
collections, to challenges in making the data that has been collected more readily accessible to analysts,
more salient to the analytical applications intended by the Council, and more informative to the public.
Some variables, including vessel activity days and processing line throughput capacity on the A80 EDR
form are somewhat duplicative of data reported elsewhere, or may not be the best source for these data.

Economic Data Reporting – Discussion Paper, April 2019

10

D5 Economic Data Reporting
APRIL 2019
Assessing the utility and useability of EDR data requires a consideration of the context in which the data
are (or aren’t) being used. To varying degrees, the EDRs were designed by the Council to support
assessment of particular effects of management measures, as in the case of the A91 EDR. The useability
of the EDR data collections in regard to specific applications intended by the Council is separate from the
broader consideration of utility and useability of the data collections to support more general analyses, for
example, in ongoing assessment of the status of the Council’s social and economic objectives described in
the FMPs, or to providing a common set of economic performance metrics that are generally applicable to
industry sectors.
An important limitation on the use of EDR data for specific applications is the frequency with which the
particular management issues are taken up for consideration by the Council. For example, the Council’s
intent in initiating the GOA Trawl CV and processor EDRs was to establish a baseline of economic data
for use in analyzing the effects of a change to catch-share management. Notwithstanding the suspension
of GOA rationalization, the intent of the Council was to use the EDR to accumulate a set of baseline
measurements, against which later measurements collected after a management change could be
compared.
The broader issue of useability of EDR data is primarily limited by the fragmentary nature of the various
data collection forms. There are only a small subset of variables that are somewhat consistently collected
across the EDRs, e.g., harvesting and processing labor costs, crew identifiers, and fuel costs. Most of the
rest of the variables collected are unique to a particular EDR form. Apart from the more fundamental
limitations of not having general purpose EDRs that are administered consistently at the sector-level, the
fragmentary nature of the distinct sets of variables collected in the current EDRs, and the distinctions
between EDRs in the way a given variable is measured, e.g., fuel cost, substantially limits the utility of
the data, particularly in the context of Council analyses.
The ability of analysts to produce informative analysis requires familiarity with the base of readily
available data. Although EDR data are available to analysts through AKFIN, the fragmentary information
that EDRs provide limit the potential for analysts to become sufficiently familiar with the data to enable
general usefulness.

Applications of EDR data in analyses
Despite numerous limitations, the EDRs together provide considerable valuable insights into the
economic behavior of the fishing industry. While this understanding has had a number of specific
valuable applications, the EDRs have given analysts who use the data a deeper understanding of the
diversity within and across fleets. For example, from the Chinook salmon EDR skipper survey, it is clear
that the pollock fishery is balancing a complex range of management challenges. Having a census of all
skippers reveals that different fishers have very different experiences in any given year, and that features
such as the extent of sea ice vary considerably and impact fishing choices and the difficulty of avoiding
Chinook salmon bycatch. In addition, all of the EDRs provide insights into the differences across the
vessels in the fleets they represent. This illustrates that some vessels may be much more flexible at
moving in response to changing target and bycatch encounter rates.
EDR Data Annual Reporting
To assess the performance of the Amendment 80 fleet under the rationalization program and subsequent
changes in fishery management Economists and analysts at the AFSC use the Amendment 80 EDR data
collection to prepare an annual summary report that is included as a chapter to the annual publication the
Economic Status of the Groundfish Fisheries off Alaska. The reported statistics provide a general
overview of fishery performance over time and are not intended as a rigorous statistical analysis of
specific hypotheses regarding economic efficiency or other performance metrics.

Economic Data Reporting – Discussion Paper, April 2019

11

D5 Economic Data Reporting
APRIL 2019
The annual summary of Crab EDR data is prepared as part of the Economic Status of the BSAI King and
Tanner Crab Fisheries off Alaska (Garber-Yonts and Lee, 2018). Statistics on harvesting and processing
activity; effort; revenue; labor employment and compensation; operational costs; and quota ownership,
usage and disposition among participants in the fisheries are provided.
Council program reviews
Both the 5-year and 10-year crab program reviews relied on EDR data to document fleet performance
with regard to quota usage and leasing, effort levels, vessel operating costs, gross and net earnings, crew
participation and crew earnings. This information is also used to document changes in crew employment
and compensation and state of residency of crew. Processing labor, employment, and wages are also
assessed using EDR data. The 10-year crab program review Social Impact Assessment (SIA) utilizes
EDR data along with other data sources to provide, within the bounds of data confidentiality constraints, a
quantitative participation description by community, including harvest trends by crab fishery, local
community fleet participation, catcher vessel crab harvest volume and value by community, community
processor participation, processor volume and value by community by share type, and quota share
distribution by community for Alaska, Washington, Oregon, and other U.S. states combined. The 10-year
Crab Rationalization Program review also summarizes the social impacts of crab rationalization by
community, including discussions of vessel participation, catcher vessel owner shareholdings, crew
participation, catcher vessel crew shareholdings, locally operating processors, support services, and local
governance and revenues.
In 2017, a program review was conducted for the Central GOA Rockfish Program. This program review
also included an SIA that made extensive use of EDR data by developing cross-walk tables for catcher
vessel ownership address community and community of residence of crew on those vessels, along with
payments to labor information, which gave a look at the “employment footprint of the fishery” in a way
that could not be done without EDR data.
The Amendment 80 program 5-year review was completed in 2014 (Northern Economics, 2014). The
review provides an overview of the EDR data collected and uses the data to summarize expenses and
revenues fleet wide. Operating expenses, including payments to labor, are documented and the EDR data
is used to develop a cash flow model.
Use of EDR Data in Analyses
EDR data have been used in several regulatory action analyses, such as for analyzing crew employment in
the 2014 Final Steller Sea Lion EIS, are currently being used in a regulatory impact review of allowing
Halibut Deck sorting in non-pollock groundfish trawl fisheries, have been utilized in projects related to
groundfish and crab stock assessments, particularly through parameterizing bioeconomic models. EDR
data have also been used in several journal articles and/or technical memos that evaluate fishery
productivity and efficiency changes and analyses of the economic contribution of Alaska fishing fleets to
different regional economies including Alaska.
Several recent Council action analyses have used EDR data. The 2016 GOA trawl bycatch management
analysis included an SIA that made extensive use of EDR data. In addition, EDR data was used in the
recently completed (3/8/19) analysis titled BSAI Final Review Draft Social Impact Assessment:
Catcher/Processor Mothership Restrictions in the Bering Sea and Aleutian Islands and the Gulf of Alaska
when taking Directed Non-CDQ Pacific Cod Deliveries from Trawl Catcher Vessels. However, in this
case inconsistent EDR data coverage across sectors limited the use of EDR data so that consistent
information is provided about each sector. This recent example highlights the limitations of the programspecific nature of the EDR Program and how fair treatment across sectors will result in analyses,

Economic Data Reporting – Discussion Paper, April 2019

12

D5 Economic Data Reporting
APRIL 2019
particularly those involving (re)allocations, which may exclude important economic information about the
sectors from EDR data if comparable data are not available across all sectors under consideration.
Analyst Feedback
Analysts from the Council staff, NMFS staff, and contractors who have used EDR data or analyzed the
associated fisheries provided useful feedback on the EDR collections. In cases where EDR data was not
used in analyses where it may have been helpful, analysts may not have full access to the data or feel that
they did not have the familiarity and/or technical skills to access the data without assistance. Further, it
has been reported by analysts that the technical aspects of using EDR data necessitates advanced planning
to obtain assistance with the data access and management tasks and the economic analysis skills needed to
use the EDR data. Analysts have also indicated in some cases the alternatives to be analyzed in a council
action are not always directly informed by the EDR data currently collected.
EDR Program Assessment and Recommendations
The discussion paper concludes with several short term and long-term recommendations for the Council’s
consideration. The two recommendations to reduce costs and burden in the short term are to revisit the
purpose of and need for third-party data verification audits and review duplication of reporting
requirements in the EDR Program with other existing reporting requirements.
The longer term, overarching, recommendation is for the Council develop a systematic approach to
identifying and prioritizing the Council’s needs for economic and social science information. While
NMFS has many actionable suggestions for ways to improve the EDR Program, this discussion paper
intentionally does not try to address any of these as it would presuppose that the Council’s purpose and
need for each of these data collections or assume that they have not changed since the programs were
most recently modified. The data collections could be modified to address known problems, scaled back
or expanded in the information collected, revised to be collected at a different frequency for all or some
variables, or the survey design could be modified to a sampling framework with a sufficiently large
sample population. The program could also be modified to reduce data collected from some EDR
Program fishery participants and instead increase the data collected from some groups that are not subject
to EDR requirements, such as quota shareholders. However, each of these changes would impact the
potential uses, utility, cost, and burden of the data collection and these tradeoffs are more appropriately
addressed by the Council with guidance from the NMFS.

Economic Data Reporting – Discussion Paper, April 2019

13

D5 Economic Data Reporting
APRIL 2019

2

Introduction

This discussion paper provides information and recommendations about the four Economic Data
Reporting (EDR) programs that the North Pacific Fishery Management Council (Council) and the
National Marine Fisheries Service (NMFS) have implemented in the federally managed groundfish and
crab fisheries off Alaska. The EDRs gather various levels of ownership, revenue, cost, vessel operations,
and employment information from vessel owners, vessel operators, processors, permit holders, and
leaseholders who participate in several of the catch share programs in the North Pacific fisheries. The
catch share programs that are subject to some form of EDR requirements are the Bering Sea and Aleutian
Islands (BSAI) Crab Rationalization Program, Amendment 80, the Gulf of Alaska (GOA) Rockfish
Program, and the Bering Sea (BS) pollock fisheries managed under the American Fisheries Act. In
addition, the Council and NMFS also implemented EDR requirements for the GOA trawl catcher vessels
and processors in fisheries not yet managed under a catch share program. For the sake of brevity, the
individual EDRs are referred to hereafter as the Crab EDR, A80 EDR, A91 EDR, and GOA Trawl EDR,
and are collectively termed the EDR Program.
The following four EDRs are addressed in this discussion paper:
•

BSAI Crab EDR, implemented in 2005 (Crab EDR);

•

Trawl Catcher/Processor (CP) EDR implemented in 2007 for Amendment 80, and in 2015 for
CPs operating in the GOA groundfish fisheries (A80 EDR);

•

BS Chinook salmon bycatch management program EDR for participants in the BS pollock
fishery, implemented in 2012 (A91 EDR); and

•

GOA trawl EDRs for trawl catcher vessels operating in the GOA and processors taking deliveries
from these vessels, implemented in 2015 (GOA Trawl EDR).

In general, the purpose of the EDR requirements are to gather information to improve the Council’s
ability to analyze the economic effects of the catch share or rationalization programs, to understand the
economic performance of participants in these programs, and to help estimate impacts of future issues,
problems, or proposed revisions to the programs covered by the EDRs. For example, the EDR
implemented for GOA trawl catcher vessels and processors not managed under a catch share program was
implemented to collect relevant baseline information that could be used to assess the impacts of a future
catch share program on affected harvesters, processors, and communities in the GOA (NPFMC, 2014 and
79 FR 71313; December 2, 2014). The BS Chinook salmon bycatch EDR was implemented to provide
additional data to assess the effectiveness of the Chinook salmon bycatch management measures in the
BS pollock fishery (77 FR 5389; February 3, 2012).
The Council discussed the EDRs in several meetings during 2018. Public testimony at the February 2018
Council meeting noted that the EDR programs had been in effect for some time, and industry was
spending time and money to complete the reports, in some cases reimbursing NMFS for the
administrative costs of the EDR programs through catch share cost recovery programs. The testifier
suggested that the Council review the EDR requirements to determine whether and how the data was
being used, whether it was being collected efficiently, and whether the data collection programs were
meeting the Council’s needs.
In April 2018, the Council reviewed a discussion paper prepared by NMFS that provided information
related to NMFS’s request that the Council review all its regulations to identify any that were outdated,
unnecessary, ineffective or could be further streamlined (NMFS, 2018). This discussion paper included
reference to the Council’s February 2018 discussion of the EDR requirements as a possible area of
regulations for future Council review. In addition, at the April 2018 meeting, the Council also heard
Economic Data Reporting – Discussion Paper, April 2019

14

D5 Economic Data Reporting
APRIL 2019
public testimony raising the question of whether the EDR requirements for the GOA trawl catcher vessels
and processors had met Council’s purpose and need to collect baseline information to assess the impacts
of a potential future catch share program in those fisheries.
Later in the April 2018 meeting, in response to this public comment and further discussion among
Council members, the Council requested that NMFS prepare a discussion paper that describes the EDR
requirements for all programs, explains how the data are used, and provides estimates of the costs of
complying with the EDR requirements. The Council’s motion stated that the Council could then use the
information in the discussion paper to determine if revisions to EDR requirements are needed and, if so,
the priority and process for analysis of proposed revisions. This discussion paper provides the information
requested by the Council in April 2018.
In addition to the Executive Summary and this Introduction, the discussion paper is organized into four
sections. Section 3 addresses scientific and analytical standards relevant to the EDRs which includes
information about the requirements for economic analysis of fishery conservation and management
actions and programs to provide the rationale and need to collect economic information about the
fisheries. It also provides a review of scientific literature and best practices regarding the elements of
survey design and data quality that are relevant to evaluation of the EDR programs. Section 4 contains a
description of and history of the North Pacific economic data collection programs. Section 5 contains
information about EDR program operations, costs, and limitations. Section 6 provides NMFS’
recommendations.

Economic Data Reporting – Discussion Paper, April 2019

15

D5 Economic Data Reporting
APRIL 2019

3

Scientific and Analytical Standards

3.1

Requirements and Guidance for Economic Analyses

A variety of Federal laws and Executive Orders require the preparation of a written analysis of the
economic impacts of proposed fishery conservation and management actions developed by the Council.
Foremost among these are the Magnuson Stevens Fishery Conservation and Management Act (MSA), the
National Environmental Policy Act (NEPA), the Regulatory Flexibility Act (RFA), Executive Order
(E.O. 12866), and, more recently, E.O. 13771.
The MSA requires that the Councils prepare fishery management plans for each fishery under its
authority that requires conservation and management (section 302(h)(1)). Section 303 of the MSA
specifies the contents of the FMPs. Many of these content requirements are related to economic aspects of
the fisheries, including requirements for information about the participants, gear types, operational modes,
harvest levels, revenue, and the cost likely to be incurred in management. Each FMP or amendment to a
FMP must include a “fishery impact statement” which must, among other requirements, analyze the
“conservation, economic, and social impacts” of the plan or amendment (section 303(a)(9)).
The MSA also requires that any FMP or FMP amendment must be consistent with ten national standards
(section 301(a)). Each of the national standards has some relation to economic aspects of the fisheries.
However, the most direct references to economic impacts are in National Standard 1(NS1) which relates
to achieving optimum yield, National Standard 4 (NS4) which recommends the fair and equitable
allocation of fishing privileges, National Standard 5 (NS5) which requires consideration of efficiency and
prohibits economic allocation as the sole purpose of an action, National Standard 7 (NS7) which requires
minimization of costs, and National Standard 8 (NS8) which requires consideration of the importance of
fishery resources to fishing communities and specifically references using the best available economic
and social data. Determinations about the consistency of a proposed action with the National Standards
relies, in large part, on the economic analysis prepared for a proposed action. In addition to the general
requirements of the MSA, section 303(b)(6) contains a specific list of factors that the Council and
Secretary of Commerce must take into account when establishing a limited access system for a fishery.
Most of these factors are related in some way to economic considerations.
NEPA requires Federal agencies to consider the interactions of natural and human environments, and the
impacts on both systems of any changes due to governmental activities or policies. This consideration is
to be done with "a systematic, interdisciplinary approach which will ensure the integrated use of the
natural and social sciences ... in planning and in decision-making …." [NEPA Sec. 102(2)(A)] and,
further, to “identify and develop methods and procedures, ….., which will insure that presently
unquantified environmental amenities and values may be given appropriate consideration in decision
making along with economic and technical considerations” [NEPA Sec. 102(2)(B)]. In addition, NOAA’s
NEPA implementation guidelines require that the environmental impact statement (required under NEPA
Sec. 102(2)(C)(i)) include biological, ecological, economic, and social consequences. Social science data
and the models they support are needed to conduct the required analyses and to predict the behavioral
response of fishermen and others that affect the biological, ecological, economic, and social consequences
(AFSC 2019).
The Regulatory Flexibility Act (RFA), enacted in September 1980, requires agencies to consider the
impact of their regulatory proposals on small entities, to analyze effective alternatives that minimize small
entity impacts, and to make their analyses available for public comment (SBA, 2010). Small entities are
identified based on either an income or employment thresholds. The FRA requires analysis of the costs
and burden of information collection requirements on industry participants.

Economic Data Reporting – Discussion Paper, April 2019

16

D5 Economic Data Reporting
APRIL 2019
E.O. 12866 (58 FR 51735, October 4, 1993) is the primary Presidential Executive Order that requires the
preparation of economic analyses of regulations implementing fishery conservation and management
actions. Specifically, E.O. 12866 requires:
In deciding whether and how to regulate, agencies should assess all costs and benefits of
available regulatory alternatives, including the alternative of not regulating. Costs and benefits
shall be understood to include both quantifiable measures (to the fullest extent that these can be
usefully estimated) and qualitative measures of costs and benefits that are difficult to quantify,
but nevertheless essential to consider. Further, in choosing among alternative regulatory
approaches agencies should select those approaches that maximize net benefits (including
potential economic, environmental, public health and safety, and other advantages; distributive
impacts; and equity), unless a statute requires another regulatory approach.
Council and NMFS staff comply with E.O. 12866 by preparing a Regulatory Impact Review (RIR) for
each conservation or management action that will be implemented through Federal regulations.
More recently, E.O. 13771 was issued on January 30, 2017. This E.O. is intended to manage the costs of
government regulation on private industry and is the source for the policy that two deregulatory actions
are needed for every regulatory action that is significant under E.O. 12866 and that imposes costs on
industry. To comply with this E.O., NMFS prepares a worksheet for each proposed rule that identifies
whether the proposed action is reducing costs or imposing costs and, if known, the amount of the cost or
cost savings. NMFS relies on the RIR to provide the necessary information about the costs of a proposed
rule.
NMFS issued guidelines for the preparation of economic analyses to meet the requirements of E.O. 12866
and the RFA, two of the most direct mandates for the preparation of economic analyses. “Guidelines for
Economic Reviews of National Marine Fisheries Service Regulatory Actions” (NMFS, 2007) addresses
the procedural and analytical requirements of E.O. 12866 and the RFA. The guidelines state that
“[A]lthough a benefit-cost analytical framework is prominent in meeting the intent of E.O. 12866, it also
requires broad consideration of the distributive effects and economic burden that may be imposed on
individuals, businesses of differing sizes, as well as small communities and governmental entities…
Meeting the broad analytical requirements of E.O. 12866 requires consideration of both benefits and costs
of regulatory alternatives from a National perspective, as well as from that of the private individual or
firm.” In addition, the RIR must provide the information necessary to evaluate the change in net benefits
to the Nation from each of the alternatives, and not just for the preferred alternative or proposed action.
NMFS’s guidelines do not prescribe particular economic analysis methods, a required level of analysis, or
specific data collection elements, but state that the analysis “should include a good qualitative discussion
of the economic effects of the selected alternatives. “Quantification of these effects is desirable, but the
analyst needs to weigh such quantification against the significance of the issue and available studies and
resources.” The appropriate analysis depends “on circumstances to be analyzed, available data, the
accumulated knowledge of the fishery and other potentially affected entities, and on the nature of the
regulation option.” However, the guidelines also state that “a quantitative analysis should be substituted
for a qualitative analysis whenever feasible (i.e., when adequate data, resources, and defensible analytical
models are available).”
The NMFS guidelines recommend that, where possible, analysts evaluate factors such as “potential
changes in prices, timing/quantity/quality/forms produced or consumed, fishing or observational trips,
etc., as a result of changing supply and demand conditions in the marketplace. This information can be
used to determine consumer surplus for various fishery products or activities and provides a partial
measure of net benefits from the fishery.” The guidelines also refer to the desirability of analyzing
changes “in revenues and operating costs for firms or individuals in the fishery, in response to changes in

Economic Data Reporting – Discussion Paper, April 2019

17

D5 Economic Data Reporting
APRIL 2019
market, biological conditions, and fishery management regulations. Analysis of firm-level changes
provides an indication of how producer surplus may change and, for small entities, the impact of
regulatory actions. This firm-level analysis characterizes changes in harvesting costs and outputs in the
fishery and may also be used to assess changes in potential industry output levels and fishing season
length. Similar analyses can also be developed for the recreational sector and for non-consumptive users
of the resource.”
The NMFS guidelines also advise the analyst to evaluate “how the regulation is expected to affect fishing
fleets, and the fishery dependent communities they support. Fleet size and composition may change in
response to market prices, biological conditions, and/or the regulatory environment. Consideration of
price and operating cost changes will permit an evaluation of how aggregate fleet size and composition
may change…Projected changes in size, composition, and geographic distribution of fishing fleets may
permit extrapolation of fleet level impacts to the communities (or regions) from which the fleets operate.
Participation rates within recreational fishing modes, and for non-consumptive user groups, should be
addressed in a similar manner, where relevant.”
The laws, E.O.s, and agency guidelines strongly support the collection of high quality economic data and
the most robust quantitative analysis possible given the data and analytical methods available and the
scope and complexity of the particular issue. However, these laws, E.O.s, and agency guidance do not
require the collection of specific economic data or the application of specific quantitative methods to
implement fishery conservation and management actions, including catch share and limited access
programs. These programs may be implemented, managed, and evaluated using the best scientific data
available and with both qualitative and quantitative analytical methods, as determined appropriate by the
Council and NMFS, and consistent with the requirements of the applicable laws and E.O.s.
Given that the guidelines for social and economic analyses outlined above are generally contingent on
available data, the discretion exercised by NMFS and the Council regarding the scope and quality of
economic data collections implemented through FMPs and federal fishery regulations determines the
scope of analyses. To an extent, this is analogous to MSA provisions that apply to the Council’s process
for specifying MSY and status determination criteria (SDCs), which allow FMPs to be implemented
despite incomplete scientific information and data-poor stocks. MSA and the National Standards place
responsibility on the Council for weighing the adequacy of available proxy measures of NS1 reference
points against the potential management value of improved proxies.
In contrast to the mandate under MSA to achieve MSY for fishery resources, the social and economic
mandates and guidelines discussed above are multivariate and qualitative, and lack an analytical
framework equivalent to that articulated in NS1.With limited exceptions, which include EDR data, the
best economic data that are consistently collected and produced for commercial fisheries of the North
Pacific are ex-vessel and first-wholesale volume and gross revenue data. These data provide the basis for
proxy measures of economic status and performance roughly equivalent to NS1 proxy measures available
in the absence of fishery-independent stock surveys.
A review of the Council record indicates numerous statements of intent to develop broad, comprehensive
economic data collection across all fisheries managed under its FMPs, with the clear support of both the
Advisory Panel (AP) as well as the Scientific and Statistical Committee (SSC). The lack of progress
toward this goal, and the limited success of the EDR program, are to some degree attributable to the lack
of a framework comparable to that articulated under NS1 for effectively applying economic and social
science information to management decisions.

Economic Data Reporting – Discussion Paper, April 2019

18

D5 Economic Data Reporting
APRIL 2019
3.2

Business data collection design and evaluation

The EDR program is small relative to other data collection systems operating within North Pacific fishery
management, such as eLandings or the North Pacific Observer Program. Although smaller in scale, many
of the functions and processes involved in developing and implementing a more complex data system,
such as eLandings, are required for operation of the EDR program. The range of methodological concerns
encountered in operation of a data collection system is extensive (see Snijkers et al. (2013)), and a
comprehensive review of survey methodology and statistical data production is beyond the scope of this
discussion paper. The following section highlights some key principles that are essential background for a
review of the EDR program, in particular concepts related to business data collection design and relevant
data quality assurance and quality control (QA/QC) methods.
To organize the discussion, it is helpful to consider a conceptual process model to help clarify the discrete
functions and tasks involved in developing and operating the EDR program, from identification of goals
and objectives, to evaluation of outcomes. The Generic Statistical Business Process Model (GSBPM;
Figure 1) is used by government statistical agencies (e.g., U.S. Census Bureau) to conceptually organize
and describe the processes involved in the design and operation of systematic statistical data collection
and dissemination process.2 Section 4 below provides an overview of the 20-year history of Council
efforts to develop economic data and information that have culminated in the current EDR program. Over
the course of that period, the Council has engaged in at least seven iterations of the process depicted in
Figure 1 (not all of which proceeded past the initial phases). As the Council considers evaluating some or
all of the current EDR programs, it may be useful to consider how the process model framed by Figure 1
has been realized in each iteration of Council EDR development, and the role that respective entities have
in the distinct phases and sub-processes.

2

The Generic Statistical Business Process Model (Snijkers et al. 2013; Vale 2009) is a product of international
collaboration within professional societies associated with national statistical agencies (e.g., the American Statistical
Association and US Census Bureau, respectively, noting that European counterparts have led development of
GSBPM), and represents the convergence of two broader communities of practice in quality management:
organizational quality management (see, e.g., (IOS, 2000)), and data quality assurance and quality control (DQA/QC). That is, the GSBMP was developed as a tool for implementing principles of quality assessment and quality
improvement in the contexts of both organizational structure and function of a complex enterprise, and of the
operational structure of stages and sub-processes involved in the generalized process of designing and implementing
a statistical information system. Figure 1 represents the model in the most general level, applicable to data systems
of any scale from a single individual survey project to a system as complex as the broader North Pacific fishery
information system described above. As a generalized process model, the GSBPM implies a sequential series of
process phases, from specification of information needs, through design, implementation, and evaluation, and with
sequential sub-processes associated with each phase. Effort and information generally flow from left to right and top
to bottom, and, as a continuous improvement process, it is implicit that the outcome of the evaluation phase (9)
reinitiates the process at the needs-assessment phase (1). However, the specific sequences depicted in Figure 1 are
not intended to be definitive. The outcome of any phase or sub-process (or external events and conditions) may
require the process to loop back to repeat a sequence beginning from an earlier sub-process or phase. If, for
example, sub-process 4.3 Run Collection produces sufficiently poor results (e.g., less than 1% response rate to a
voluntary survey), it may be necessary to skip ahead to the Evaluation phase, or where critical failure(s) can be
identified, loop back to improve and re-execute an earlier phase or sub-process. Also, some of the enumerated subprocesses may not be relevant in a given application.

Economic Data Reporting – Discussion Paper, April 2019

19

D5 Economic Data Reporting
APRIL 2019

Figure 1

3.2.1

Generic statistical business process model (Vale 2009)

Measurement objectives and data applications

With notable exceptions discussed in Section 4.23, the Council has been the principal actor in decisions at
the (1) Specify Needs and (2) Design phases of the EDR process, exercising its broad discretion under
MSA and National Standards Guidelines to identify analytical objectives and associated economic and
social data requirements. In each iteration of the EDR development process, the range, scope and level of
specificity of analytical objectives for each component of the program have varied, but the Council has
consistently expressed a general intent to improve its ability to monitor and evaluate the performance of
fishery management measures through improved understanding of the social and economic status of
affected stakeholder populations, and of the behavioral responses of stakeholders to such management
measures.4 The EDR program is unique in the North Pacific fishery information system in that each of the
EDR data collections were developed 1) primarily by the Council, and 2) exclusively for analytical
purposes associated with management program evaluation. That is, in contrast to the array of
administrative or resource assessment data systems developed by NMFS, ADFG, and the Council (or
under its oversight) the EDR program was developed by the Council solely for the purpose of providing
statistical data to be used by analysts and researchers for the purpose of high-level monitoring and
assessment of the social and economic effects, over time, of the associated catch share programs.
To clarify this distinction, The North Pacific fishery information system in regards to the human
environment can be broadly divided between administrative record systems designed for primary uses in
Section 4.2 below provides a more detailed discussion of the analytical objectives identified in the Council’s
purpose and need statements for each EDR data collection, and the engagement of the Council, AKR, AFSC and
other stakeholders in each phase depicted in Figure 1.
4
All of the EDRs have been developed in association with a pending catch share management action, and have been
limited in scope to requiring submission only by entities participating (or expected to participate) in the respective
catch share programs. In some cases, EDR design also excludes collection of data pertaining to submitters’ activities
not directly within the scope of the associated management program.
3

Economic Data Reporting – Discussion Paper, April 2019

20

D5 Economic Data Reporting
APRIL 2019
in-season fishery management and statistical surveys that are defined by the Office of Management and
Budget (OMB) as those employing statistical methods, i.e., “a. collecting data using any survey methods;
b. doing any kind of estimation, imputation, or weighting; or c. pretesting or field testing for a survey,
including cognitive interviews or focus groups from a total of 10 or more people.” The large majority of
fishery data collection systems fall within the former category designed for primary uses in in-season or
ongoing fishery management, such as fishery permit registries, ADF&G fish tickets and Commercial
Operators Annual Report, AKR’s catch accounting system, and other data collections associated with
record keeping and reporting requirements under federal or state fishery regulations.5 With few (if any)
exceptions, the primary purpose of such data collections is to facilitate NMFS and/or ADF&G execution
of administrative procedures with respect to regulated entities, either individually or categorically (i.e.,
over a designated class of individual entities).6 Examples of statistical surveys in the human environment
include surveys of recreational anglers to assess their catch, effort, and value derived from fishing (Lew
and Larson 2012, 2015), social surveys of participant demographics, distribution, and preferences
(Himes-Cornell et al. 2015), and the EDR forms.
Apart from primary administrative functions, data produced from administrative data collections are used
extensively by NMFS, ADF&G and Council staff for analytical and statistical purposes. Statistical
applications include use of data sets extracted from the catch accounting system in combination with
other data sources in stock assessment models to estimate fishery mortality and other NS1 reference
points. Analytical applications include use of landings data and COAR buyer report data to calculate
aggregate ex-vessel revenues for use in regulatory review analyses. In general, the objectives of statistical
and analytical data applications are to synthesize general information about a population of entities and to
draw inferences regarding systematic differences captured in the data. In contrast to administrative data
applications, which concern specific regulated entities individually, a single isolated data point is of
negligible statistical or analytical value and the inferential utility of a dataset in analytical/statistical
applications decreases as the number of independent entities represented in the dataset declines.
The distinction between the EDR program and administrative data systems is important for several
reasons. Administrative data are used routinely by agency staff to execute specific regulatory procedures,
in many cases producing direct effects on specific regulated entities. As a result, the content of
administrative data systems, procedures and applications for data use, and relevant data quality
requirements and limitations are familiar to a relatively large number of both agency staff and data
submitters. The much smaller scope of EDR data collections, and distinct decision support function it is
intended for, limit the range and frequency of applications of the data and the pool of potential users.
Many of the data collection procedures employed by the EDR program, including use of censuses (rather
than sampling), mandatory submission, and signed certification statements are incorporated in the
5

The AKRO Application and Forms webpage provides a fairly comprehensive catalog of administrative report
forms, applications, and other data collection forms, including EDRs, that are administered by AKRO.
https://alaskafisheries.noaa.gov/fisheries-applications.
6
Such administrative purposes include granting or renewing a particular permit or fishery allocation to an individual
or a designated entity, assessment and collection of a specified fee from an individual or entity, and monitoring an
individual entity’s conduct of regulated activities, identifying violations, and executing penalties. Primary
applications of such administrative data systems may involve use of aggregate or statistical values as composite
measurements over a population , such as determining the number of QS units represented in a pool of qualified IFQ
applicants for use in distributing an annual allocation among individual IFQ permits, estimating the average per-unit
value (price) of fishery resources extracted by fishery participants for use in assessing ad valorum fees and taxes, or
monitoring the cumulative amount of withdrawals of an allocated fishery resource to determine when a catch limit is
reached and a closure is ordered. Some elements of administrative records may be considered public information,
such as public permit registries enumerating permit numbers, the names and addresses of permit holders,
endorsements, and history of permit transfers and renewals. In general, however, most administrative records are
confidential under federal and/or State of Alaska statutes and regulations.

Economic Data Reporting – Discussion Paper, April 2019

21

D5 Economic Data Reporting
APRIL 2019
program design for data quality control purposes specific to EDR data.7 Because these elements closely
resemble features of NMFS and ADFG administrative reporting forms, however, EDR submitters may
confuse the distinct purpose and permissible uses of EDR data collections with those associated with
administrative reporting requirements, and have expectations for data quality requirements appropriate to
the latter that may be excessive for the intended uses of EDR data.
In most cases of Council engagement in overseeing development, design or revision of administrative
record systems or other data collections used in in-season management and/or the harvest specification
process, the Council is substantially guided by the framework of quantitative metrics defined in National
Standard 1 and by specific data quality needs identified by the stock assessment and in-season
management processes. The institutional structures associated with harvest specifications (i.e., Crab and
Groundfish Plans Teams and the SSC) and in-season management provide continuous mechanisms for
improving the quality of information available to support the conservation management process.
Although the specific institutional structures established by different Regional Fishery Management
Councils (RFMCs) differ, the common framework of conservation management under NS1 (and
international equivalents) is associated with large body of science and associated communities of practice
that are endemic to fishery management and are densely populated within NMFS and other fishery
management agencies. In contrast, institutional structures related to economic and social science
information in decision-making are substantially thinner than for other science domains within fishery
management. The National Standards provide much less guidance to RFMCs about the use of social
science and economic information in defining and assessing management objectives and outcomes.
Agency staff resources in economics and social science at regional offices and science centers are
similarly limited, including at AFSC and AKRO. Economic and social science expertise available to the
Council is generally concentrated in resource management subject areas, and does not generally include
deep expertise in business survey design and data QA/QC that are particular to statistical agencies to a
degree comparable to the depth of NMFS’ scientific expertise in fields endemic to fishery management.
Over a 20-year history of Council engagement on economic data collection, agency and Council staff
economists and data system managers have been contributors to temporary EDR-related workgroups
initiated by the Council (as well as plan teams and scientific panels dealing with data quality issues in
other domains). Over the successive iterations of the EDR development process, however, the Council’s
reliance during the initial phases on agency staff (independently or in collaboration with industry) to
provide research and technical analysis to support its decision making has declined relative to industry
input and other information sources.
3.2.2

Data quality principles and guidance

At the most general level, ‘data quality’ refers to the degree to which the attributes of a body of data
fulfill requirements for use in a particular setting. Beyond this most general sense, operationalizing the
concept of data quality is necessarily context-specific, depending on the setting in which a decision is to
be informed through use of data and the nature of data proposed for use. There is no definitive framework
of terms and definitions used in technical discussions of data quality. Such discussions often begin with
acknowledgement that data quality is a complex, multidimensional concept, and that the vernacular
understanding of the term “accuracy” is inadequate as an operational shorthand for the complex task of
rigorously designing a data system or evaluating data for fitness-for-use in a particular situation.
Apart from abstract conceptual and methodological perspectives on the issue of data quality, as a federal
agency, NMFS is subject to multiple tiers of statutory, regulatory, and administrative information quality

7

Due to the impracticality of representative sampling in the small population frames targeted by the EDR
data collections, and prior history of Alaska fishery industry response to voluntary economic surveys.
Economic Data Reporting – Discussion Paper, April 2019

22

D5 Economic Data Reporting
APRIL 2019
requirements that apply to data and information8 that it collects and disseminates, each of which includes
a set of definitions and standards that generally increase in specificity as they narrow in scope. At the
highest statutory level, the federal Paperwork Reduction Act of 1995 (PRA)9 and Data Quality Act (DQA;
2001)10 vest the OMB with the principal responsibility for directing the promulgation of data quality
policy and standards throughout federal agencies, and statutory provisions of the MSA relate to standards
and mechanisms for ensuring the quality of information used by NMFS and RFMCs in fishery
management. The following discussion provides a brief overview of regulatory guidelines and standards
issued by OMB and NOAA implementing the respective statutes with respect to data quality and
associated requirements associated with the EDR program.
OMB regulations implementing the PRA are intended to “reduce, minimize and control burdens and
maximize the practical utility and public benefit of the information created, collected, disclosed,
maintained, used, shared and disseminated by or for the Federal government” (5 CFR 1320). All
collections of information11 proposed to be conducted or sponsored by a federal agency must gain
clearance from OMB subject to, among other items, completion of documentary and procedural
requirements for public notice, solicitation and response to public comment, and review by OMB. The
PRA review process12 requires that an agency provide certification and supporting documentation (using
the PRA Supporting Statement, OMB Form 83I) demonstrating that a proposed information collection
meets specified criteria:
“Is necessary for the proper performance of the functions of the agency, including that
the information to be collected will have practical utility; is not unnecessarily duplicative
of information otherwise reasonably accessible to the agency; reduces to the extent
practicable and appropriate the burden on persons who shall provide information to or
for the agency[…]; is written using plain, coherent, and unambiguous terminology and is
understandable to those who are to respond; is to be implemented in ways consistent and
compatible, to the maximum extent practicable, with the existing reporting and
recordkeeping practices of those who are to respond; indicates for each recordkeeping
The terms ‘data quality’ and ‘information quality’ are sometimes used interchangeably; in the following
discussion, as explained in more detail below, “data quality” is used to focus on the narrower scope of issues
involving the design and assessment of systems and methods for capturing and managing discrete items of
information, i.e., data and information collection; “information quality” encompasses a broader range of topics,
including information synthesis, interpretation, production, and dissemination.
9
https://www.govinfo.gov/app/details/USCODE-2010-title44/USCODE-2010-title44-chap35-subchapI-sec3501
10
Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106‐
554); although Section 515 of the Act is not officially titled, it is commonly referenced in official federal documents
variously as the Data Quality Act or the Information Quality Act.
11
Defined in 5 CFR 1320.3(c) as: “the obtaining, causing to be obtained, soliciting, or requiring the disclosure to
an agency, third parties or the public of information by or for an agency by means of identical questions posed to,
or identical reporting, recordkeeping, or disclosure requirements imposed on, ten or more persons, whether such
collection of information is mandatory, voluntary, or required to obtain or retain a benefit. ‘Collection of
information’ includes any requirement or request for persons to obtain, maintain, retain, report, or publicly disclose
information. As used in this Part, “collection of information” refers to the act of collecting or disclosing
information, to the information to be collected or disclosed, to a plan and/or an instrument calling for the collection
or disclosure of information, or any of these, as appropriate. […] Any recordkeeping, reporting, or disclosure
requirement contained in a rule of general applicability is deemed to involve ten or more persons.”
12
NOAA’s “Paperwork Reduction Act Guidance” webpage provides extensive information about PRA clearance
requirements, and official NOAA processes, procedures, schedules, and guidance to agency staff regarding PRA
compliance (https://www.cio.noaa.gov/services_programs/praguide.html). NMFS Standard Operating Procedures
for PRA compliance are posted online at https://www.cio.noaa.gov/itmanagement/pdfs/NMFSSOP_032409.pdf.
8

Economic Data Reporting – Discussion Paper, April 2019

23

D5 Economic Data Reporting
APRIL 2019
requirement the length of time persons are required to maintain the records specified;
[…]; has been developed by an office that has planned and allocated resources for the
efficient and effective management and use of the information to be collected, including
the processing of the information in a manner which shall enhance, where appropriate,
the utility of the information to agencies and the public; uses effective and efficient
statistical survey methodology appropriate to the purpose for which the information is to
be collected; and to the maximum extent practicable, uses appropriate information
technology to reduce burden and improve data quality, agency efficiency and
responsiveness to the public.”(5 CFR 1320.9)
Stringent adherence to these criteria requires that an agency clearly demonstrate need for and the intended
(or actual, in the case of renewal or clearance for ongoing collections) use of the collected information
and balance the cost of the collection, in terms of financial and time burden required of respondents,
against the quality of information obtained relative to its intended use. As defined in the rule, “practical
utility” requires that:
“the actual, not merely the theoretical or potential, usefulness of information to or for an
agency, taking into account its accuracy, validity, adequacy, and reliability, and the
agency's ability to process the information it collects[…] in a useful and timely fashion.
In determining whether information will have ‘practical utility’, OMB will take into
account whether the agency demonstrates actual timely use for the information either to
carry out its functions or make it available […] for the use of persons who have an
interest in entities or transactions over which the agency has jurisdiction. In the case of
recordkeeping requirements or general purpose statistics […], ‘practical utility’ means
that actual uses can be demonstrated.” (5 CFR 1320.3(l))
The public input requirements of the PRA clearance process and the review criteria represented in the
PRA Supporting Statement (Part A) apply to all proposed information collections, and are primarily
concerned with quantifying, minimizing, and justifying the reporting burden and cost expended by the
collection. As defined by OMB in Section 3.2.1 above, statistical surveys are a distinct category of
information collections that require additional documentation and review standards that do not apply to
fishery permit applications and recordkeeping and reporting requirements in regulations. PRA clearance
for statistical surveys requires completion of PRA Supporting Statement -Part B, describing sampling
design and procedures,13 survey design methods, testing procedures and results, statistical and analytical
methods, and contact information for individuals consulted in the statistical design and the personnel
responsible for conducting the collection and data analysis. This additional information specifically
addresses data quality, and represents review criteria premised on the production of statistical estimates of
key variables from collected data that are reliably representative of the population being surveyed. OMB
has issued Standards and Guidelines for Statistical Surveys,14 describing review standards for PRA
clearance and best practices guidance on seven topic areas (sections): 1) development of concepts,
methods, and design; 2) collection of data; 3) processing and editing of data; 4) production of estimates
and projections; 5) data analysis; 6) review procedures; and 7) dissemination of information products.
Many of the standards described apply directly to aspects of data collections implemented according to
Council recommendations, including EDR programs, particularly Sections 1, 2, 6 and 7. Two key

13

OMB has defined sample design to include a full population census, as employed in the EDR program.
71 FR 55522; OMB Statistical Policy Directive Number 2 Standards and Guidelines for Statistical Surveys
(2006).
https://obamawhitehouse.archives.gov/sites/default/files/omb/assets/omb/inforeg/statpolicy/standards_stat_surveys.p
df
14

Economic Data Reporting – Discussion Paper, April 2019

24

D5 Economic Data Reporting
APRIL 2019
standards define design principles for aligning the objectives of the data collection, the design of survey
instruments and procedures, and the quality of expected data and information output:
Survey Planning
Standard 1.1: Agencies initiating a new survey or major revision of an existing survey
must develop a written plan that sets forth a justification, including: goals and objectives;
potential users; the decisions the survey is designed to inform; key survey estimates; the
precision required of the estimates (e.g., the size of differences that need to be detected);
the tabulations and analytic results that will inform decisions and other uses; related and
previous surveys; steps taken to prevent unnecessary duplication with other sources of
information; when and how frequently users need the data; and the level of detail needed
in tabulations, confidential microdata, and public-use data files.
Data Collection Methodology
Standard 2.3: Agencies must design and administer their data collection instruments and
methods in a manner that achieves the best balance between maximizing data quality and
controlling measurement error while minimizing respondent burden and cost.
In distinctly referencing measurement error and data quality, Standard 2.3 makes a distinction between
the quality of measurement achieved by individual survey questions, and the broader data quality
considerations addressed in Standard 1.1. That is, for a proposed statistical survey to comply with PRA
requirements, the justification must describe data quality requirements broadly and in context, not in
terms of measurement error and individual survey questions, but rather in terms of well-framed decision
scenarios, how statistical values estimated from collected data are expected to inform such decisions, and
the minimum precision of estimates necessary to effectively provide such information. Failure to address
this broader conceptual framework in the justification risks failure in the PRA review process, regardless
of whether the agency adequately demonstrates that measurement error is appropriately minimized.
Consistent with principles stated in PRA review guidelines, NOAA IQ guidelines acknowledge that
“accuracy” is not an absolute metric, but must be assessed on the basis of whether information is “within
an acceptable degree of imprecision or error appropriate to the particular kind of information at issue and
otherwise meets commonly accepted scientific, financial, and statistical standards, as applicable;…
original and supporting data that are within an acceptable degree of imprecision, or an analytic result that
is within an acceptable degree of imprecision or error, are by definition within the agency standard and
are therefore considered correct.”
National Standard 2 develops additional data quality guidance beyond NOAA IQ Guidelines that is
particularly applicable to evaluation of EDR data as scientific information in developing and evaluating
EDR data collections:
600.315 (a)(6): Criteria to consider when evaluating best scientific information are
relevance, inclusiveness, objectivity, transparency and openness, timeliness, verification
and validation, and peer review, as appropriate.
(i) Relevance. Scientific information should be pertinent to the current questions or issues
under consideration and should be representative of the fishery being managed. ...
(ii) Inclusiveness. Three aspects of inclusiveness should be considered when developing
and evaluating best scientific information: (A) The relevant range of scientific disciplines
should be consulted to encompass the scope of potential impacts of the management
decision. (B) Alternative scientific points of view should be acknowledged and addressed

Economic Data Reporting – Discussion Paper, April 2019

25

D5 Economic Data Reporting
APRIL 2019
openly when there is a diversity of scientific thought. (C) Relevant local and traditional
knowledge (e.g., fishermen's empirical knowledge about the behavior and distribution of
fish stocks) should be obtained, where appropriate, and considered when evaluating the
BSIA.
(iii) Objectivity. Scientific information should be accurate, with a known degree of
precision, without addressable bias, and presented in an accurate, clear, complete, and
balanced manner. Scientific processes should be free of undue nonscientific influences
and considerations.
(iv) Transparency and openness. (A) The Magnuson-Stevens Act provides broad public
and stakeholder access to the fishery conservation and management process, including
access to the scientific information upon which the process and management measures
are based. ...(B) Scientific information products should describe data collection methods,
report sources of uncertainty or statistical error, and acknowledge other data limitations.
Such products should explain any decisions to exclude data from analysis. ...
(v) Timeliness. ... Data collection methods are expected to be subjected to appropriate
review before providing data used to inform management decisions. ...
(vi) Verification and validation. Methods used to produce scientific information should be
verified and validated to the extent possible. (A) Verification means that the data and
procedures used to produce the scientific information are documented in sufficient detail
to allow reproduction of the analysis by others with an acceptable degree of precision.
External reviewers of scientific information require this level of documentation to
conduct a thorough review. (B) Validation refers to the testing of analytical methods to
ensure that they perform as intended.

Economic Data Reporting – Discussion Paper, April 2019

26

D5 Economic Data Reporting
APRIL 2019

4

Description and History of Economic Data Collection

4.1

Overview of national fisheries economic data collections

Evaluation of the economic effects of fishery management decisions emphasizes analysis of how
regulatory programs affect net benefits to society as well as the profitability of fishing firms, which
requires information on both benefits and costs. Additionally, Councils and NMFS have developed and
adopted measures of economic performance to monitor whether fishery management programs are
meeting management objectives. These economic performance measures may include: costs, earnings,
and profitability (net revenue); productivity change and economic efficiency; capacity; employment,
economic stability; net benefits to society; distribution of economic net benefits; and market power or
concentration.
To meet these needs, NMFS’ Office of Science and Technology has invested in cost data collection of
commercial fisheries by providing dedicated funding to regional Science Centers. Funding of cost data
collection in catch share fisheries has been further enhanced by the NMFS Office of Sustainable Fisheries
and through cost recovery. This programmatic support has led to an expansion of systematic cost data
collections in the U.S., from five collections in 2002 to 26 in 2018. Each of these data collections has
been tailored to suit regional Council requirements and complement and take advantage of other regionspecific fishery-dependent or fishery-independent data collection programs.
NMFS has a long history of economic studies of costs and returns in U.S. domestic commercial fisheries.
Most early cost and earnings studies were conducted to evaluate the economic performance of one or
more fisheries due to a resource change or external shock having an adverse effect on profitability or
competitiveness. While such surveys provided useful economic data at the time, they were done without
dedicated funding and so could not be replicated. This inhibited the ability to conduct economic
assessments of management changes over time.
Beginning in the 2001, NMFS began a strategic initiative to provide funding for regional economics
programs to take a systematic programmatic approach to cost data collection. These efforts led to a
gradual expansion of data collection programs across regions, which are chronicled in Table 1. By 2002,
continuous data collection was in place in the Northeast, South Atlantic, and Highly Migratory Species
(HMS) fisheries, including the South Atlantic coastal logbook reporting form, the Agency’s first
mandatory cost data collection program. Similar data collection programs were implemented in the
Hawaii longline fishery in 2004, and in 2005 continuous annual data collection programs were
implemented in fisheries of the Gulf of Mexico and the BSAI crab fishery. Systematic rotation of cost
surveys for key fisheries in the Northwest was established by 2006. With the exception of 2012, at least
one new data collection program was added in each year through 2013. The most recent new data
collection program began in 2015 when the Gulf of Alaska Groundfish Trawl data collection was
established.
Table 2 displays the 19 data collection programs, which include all 26 data collections reference above,
implemented and managed by economists in each of NMFS’ six Science Centers through 2018. The
Northwest Groundfish Trawl Rationalization Economic Data Collection and Alaska Economic Data
Reports include multiple fleets or fisheries but share common data collection methods and protocols. For
this reason, each of the two are treated as a single data collection program within their region. Each of the
programs within the Alaska Economic Data Reports will be discussed in detail below in Section 4.2.3.

Economic Data Reporting – Discussion Paper, April 2019

27

D5 Economic Data Reporting
APRIL 2019
Table 1

Summary of NOAA Fisheries Cost Data Collections 2000 to 2018 (cells shaded in green indicate data collection events)

Data Collection Program
AK BSAI Crab

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

3

AK Amendment 803
AK Amendment 91 Chinook Salmon3
AK Gulf of Alaska Trawl3
NW Groundfish Trawl Rationalization Economic Data Collection1
NW Limited Entry Groundfish Trawl2
NW Limited Entry Groundfish Fixed Gear
NW Open Access Groundfish, Salmon, Crab, and Shrimp Cost and
Earnings
PI Cost Data Collection of the Hawaii Longline Fishery
PI Cost Data Collection of the American Samoa Longline Fishery
PI Cost Data Collection Program in Three Territorial Areas
SW West Coast Albacore Troll and Pole-and-Line Fishery
SW West Coast Commercial Swordfish Fishery
SE Trip-level Economic Survey of South Atlantic Coastal Fisheries
SE Annual Economic Survey of South Atlantic Coastal Fisheries
SE Trip-level Economic Survey of Gulf of Mexico Coastal Fisheries
SE Annual Economic Survey of Gulf of Mexico Coastal Fisheries
SE Economic Survey of Federal Gulf of Mexico Shrimp
SE Economic Survey of Federal South Atlantic Shrimp
SE Economic Survey of Federal South Atlantic Golden Crab
SE Economic Survey of Wreckfish ITQ Holders
US Caribbean Small-scale Fisheries4
NE Northeast Trip Costs Survey
NE Northeast Fixed Costs Survey
Atlantic HMS Trip Cost Survey5
Atlantic HMS Annual Cost Survey5
1 Includes data collection for catcher vessel, catcher-processor, mothership, and first receiver sectors of the Northwest Groundfish Trawl Rationalization program.
2
The limited entry groundfish trawl data collection transitioned to the mandatory Groundfish Trawl Rationalization Economic Data Collection program in 2010.
3
Part of Alaska Economic Data Report Program including BSAI Crab, Amendment 80, Amendment 91 Chinook Salmon, and the GOA Trawl EDR.
4 Includes Puerto Rico and U.S. Virgin Islands (St. Thomas, St. Croix, and St. John).
5 Voluntary reporting of Atlantic HMS cost data collection was initiated in 1996 and became mandatory in 2003.

Economic Data Reporting – Discussion Paper, April 2019

28

D5 Economic Data Reporting
APRIL 2019
Table 2

Meta-Data Summary of NOAA Fisheries Economics Program Current Cost Data Collection Programs (2018 or most recent year)

Requirement

Samplin
g
Regime

Unit of
Observation

Survey Vehicle

Frequency

Y = yearly,
O=
ongoing,
3Y = every 3 years,
5Y = every 5 years
5-7Y = 5 to 7 years

M = mandatory,
V = voluntary

S=
sample, C
= census

T = trip,
A=
annual

M=
mail, W
= web,
T = telephone,
L = logbook,
PI = personal interview,
OB = observer

M

C

A

W

Y

M

C

A

M,W

Y

NW Open Access Groundfish, Salmon, Crab, and Shrimp Cost and Earnings

V

C

A

T,PI

3Y

NW Limited Entry Groundfish Fixed Gear

V

C

A

T,PI

3Y

PI Cost Data Collection Program of the Hawaii Longline Fishery

V

S

T

OB

O

PI Cost Data Collection Program of the American Samoa Longline Fishery

V

S

T

PI,OB

O

PI Cost Data Collection Program in Three Territorial Areas

V

S

T

PI

O

SW West Coast Albacore Troll and Pole-and-Line Fishery

V

S

A

M,PI

5Y

SW West Coast Commercial Swordfish Fishery

V

S

A

M

5Y

SE Trip-level Economic Survey of Southeast Coastal Fisheries

M

S

T

L

O

SE Annual Economic Survey of Southeast Coastal Fisheries

M

S

A

M

Y

SE Economic Survey of Federal Gulf and Atlantic Shrimp

M

S

A

M

Y

SE Economic Survey of Federal South Atlantic Golden Crab

V

C

A

M

5Y

SE Economic Survey of Wreckfish Individual Transferable Quota Holders

V

C

A

M

5Y

US Caribbean Small-scale Fisheries

V

S

T

T,PI

5-7Y

NE Northeast Trip Costs Survey

V

S

T

OB

O

NE Northeast Fixed Costs Survey

V

S

A

M,W

3Y

Atlantic HMS Trip Cost Survey

M

S

T

L

O

Program Name
AK Alaska Economic Data Report1
NW Groundfish Trawl Rationalization Economic Data Collection

Program2

Atlantic HMS Annual Cost Survey
M
S
A
M
1 Alaska EDR program covers data collection programs for BSAI Crab, Amendment 80, Amendment 91 Chinook Salmon, and Gulf of Alaska Trawl.
2 Includes data collection for catcher vessel, catcher-processor, mothership, and first receiver sectors of the Northwest Groundfish Trawl Rationalization program.

Economic Data Reporting – Discussion Paper, April 2019

29

Y

D5 Economic Data Reporting
APRIL 2019
Figure 2 breaks down the evolution of commercial fisheries cost data collections across the U.S., by those
collecting fixed costs and those collecting operating costs in each region. What is clear from Figure 2 is
that despite the attention paid to collecting better economic data in the North Pacific, other regions have
been more successful in implementing economic data collection programs over this period. One program
that benefitted substantially from learning from the missteps in the original Crab EDR and is successfully
implementing an economic data collection for a similar fleet of vessels is Northwest Groundfish Trawl
Rationalization Economic Data Collection (EDC) Program, which is summarized in the following
section.

Figure 2

Percent of U.S. Fisheries with Fishing Vessel Cost Data (2001-2016)

Source: Slide 11 from Drew Kitts presentation for the NMFS Office of Science and Technology Economics and Human Dimensions
Science Review, September 2017. Available at: https://www.st.nmfs.noaa.gov/Assets/science_program/econ-hd-programreview/commercial_fisheries_kitts_FINAL.pdf

Economic Data Reporting – Discussion Paper, April 2019

30

D5 Economic Data Reporting
APRIL 2019
4.1.1

Summary of the Northwest Groundfish Trawl Rationalization Economic Data Collection
Program

The U.S. West Coast groundfish fishery takes place off the coasts of Washington, Oregon, and California,
and targets more than 90 species of fish, harvested both commercially and recreationally. The commercial
fishery has four components: limited entry with a trawl endorsement, limited entry with a fixed gear
endorsement, open access, and tribal. In January 2011, the West Coast Limited Entry Groundfish Trawl
fishery transitioned to the West Coast Groundfish Trawl Catch Share Program. The catch share program
consists of cooperatives for the at-sea mothership (including catcher vessels and motherships) and
catcher-processor fleets, and an individual fishing quota (IFQ) program for the shore-based trawl fleet.
The economic benefits of the West Coast groundfish trawl fishery and the distribution of these benefits
were expected to change under the West Coast groundfish trawl catch share program. To monitor these
changes, the Pacific Fishery Management Council (PFMC) proposed the implementation of the
mandatory collection of economic data. Using data collected from industry participants—including
information on operating costs, revenues, and vessel and processing facility characteristics—the EDC
Program monitors whether some of the goals of the catch share program have been met. The EDC
program is also intended to help meet the MSA requirement to determine whether a catch share program
is meeting its goals, and whether any modifications of the program are necessary to meet those goals.
Economic performance measures include: costs, earnings, and profitability (net revenue); economic
efficiency; capacity; economic stability; net benefits to society; distribution of economic net benefits;
product quality; functioning of the quota market; incentives to reduce bycatch; market power; and
spillover effects in other fisheries. Some of these measures are presented in regularly-published reports
produced using EDC data, while others will require more specific and involved analysis.
The EDC Program is a mandatory component of the West Coast Groundfish Trawl Catch Share Program,
collecting information annually from all (census) catch share participants: catcher-processors, catcher
vessels, motherships, first receivers, and shore-based processors. Catcher vessels and catcher-processors
are required to fill out the survey if they had a Limited Entry Trawl permit on their vessel at any time
during the calendar year. Motherships with a mothership permit on their vessel at any time during the
calendar year must fill out the survey, as must any first receiver or shore-based processor that held a firstreceiver license at any point during the preceding year.
Separate survey forms are used for catcher vessels, catcher processors, motherships, and firstreceivers/shore-based processors. Each survey form is tailored to the circumstances appropriate to each of
these categories and are mailed each year to collect data covering information for the prior year.
Participants in the EDC Program may also complete their forms via an online web-form. EDC survey
forms and analytical reports are available on the NWFSC EDC webpage.15
4.2

Review of North Pacific economic data collections

4.2.1

Non-EDR data sources of fisheries economic data

The requirements for participants in the North Pacific groundfish, halibut, and crab fisheries to submit
information about their fishing and processing activities are organized into about thirty different
“information collections.” These collections include fishermen, vessel, processor, and cooperative permit
applications; quota transfer applications; vessel and processor logbooks; data collected by observers and
through electronic monitoring (EM) and other equipment and catch monitoring requirements; landing and
production reports; annual reports; cost recovery submissions; and economic data reports. While the EDR

15

More information about the EDC Program is available at
https://www.nwfsc.noaa.gov/research/divisions/fram/economic/overview.cfm.

Economic Data Reporting – Discussion Paper, April 2019

31

D5 Economic Data Reporting
APRIL 2019
requirements are focused specifically on the collection of economic and business information from
individual fishermen and processors, almost all of the other data collections also provide information that
is economic in nature and essential to analyzing the economic impacts of fishery conservation and
management actions.
Some of the most important economic information collected through non-EDR sources is information
about participants in the fisheries; the species, product form, weight, and ex-vessel or first wholesale
value of the catch and production; and the location of landings and production. This information is
provided by vessel landing reports (“fish tickets”), production reports, observer and electronic monitoring
data; and the State of Alaska’s Commercial Operator’s Annual Report. Information collected through
vessel logbooks provides detailed information about the timing and location of fishing, gear used, catch
and discards, and number of crew onboard the vessel each fishing day. This information is used to
describe the existing fisheries and participants, and to project, either qualitatively or quantitatively, the
changes in the amount, location, and timing of fishing and processing that may occur as a result of a
change in a fishery or a proposed fishery conservation or management action. Based on those projected
changes, analysts address qualitatively and, where possible quantitatively, the potential benefits and costs
and distributive impacts of a proposed action or alternative on individuals, entities, and communities, and
the “net benefits to the nation.”
4.2.2

Overview of current EDR program framework

To enhance the availability of social and economic information needed to inform its oversight of catch
share management in North Pacific fisheries, the Council has overseen the development, and
implementation by NMFS, of four mandatory Economic Data Report data collections to date. At early
stages of developing FMP amendments for BSAI Crab Rationalization (70 FR 10174) and BSAI
Amendment 80 (72 FR 52668) programs, the Council included mandatory annual reporting of
comprehensive cost, earnings, production, and employment data by program participants as an element of
the program design described in the respective FMP amendments. Following implementation of Chinook
salmon bycatch management measures in the AFA pollock fishery under Amendment 91 to the Bering
Sea groundfish FMP, the Council designed an EDR specifically intended to inform analyses of the cost
and effectiveness of the A91 bycatch avoidance measures by collecting a targeted set of variables from
vessel owners and other AFA program participants (77 FR 5389). Following an extensive review of Crab
EDR implementation, the Council took final action on Amendment 42 to the Crab FMP (78 FR 36122),
substantially revising crab EDR reporting requirements. Most recently, the Council recommended the
implementation of an EDR to collect cost and employment data from vessels and processors active in the
Gulf of Alaska (GOA) groundfish trawl fishery (79 FR 71313); although Council action on GOA
rationalization was suspended in December 2016, the Gulf of Alaska Trawl Economic Data Report
represents an effort to improve the quality of information describing baseline economic conditions
achieved in implementation of earlier catch share programs.
As described in more detail in Section 4.2.3, each of the EDRs was developed through the Council’s FMP
and regulatory development and review process, beginning with the specification of purpose and needs
for the data collection followed by the development, analysis, and selection of a preferred alternative. In
reaching final action on preferred alternatives for each new or revised EDR, the Council specified
submission requirements, administrative procedures, and enforcement mechanisms for the data
collections, and in all cases included detailed descriptions of the information content of EDR forms in
their regulatory recommendations to NMFS.16 In EDR development and ongoing oversight, the Council
16

Detailed specifications of the content of EDR forms by the Council have been alternately described in the text of
final action motions, by reference to draft EDR forms in addenda, and/or by reference to detailed descriptions in
regulatory review documents. Per Council recommendations, final rules implementing the Crab Rationalization
Program and Amendment 80 included detailed specifications of EDR form content describing each data element in

Economic Data Reporting – Discussion Paper, April 2019

32

D5 Economic Data Reporting
APRIL 2019
has relied on committees and/or workgroups of varying industry, agency, and/or scientific composition
and purpose, and has varied in its responsiveness to AP and SSC review recommendations.
Notwithstanding differences in EDR form content and specific elements of implementing rules (e.g.,
target populations) between the four EDRs, the general structure of the EDR program is largely consistent
with that of the original Crab EDR as developed by the Council and implemented by NMFS. Each of the
four EDRs employs mandatory annual censuses of the target populations of designated reporting entities
participating in the associated fishery management programs,17 and all include provisions for third-party
data verification audits in the implementing rules.
Within the recommended framework developed by the Council, the EDR program is managed jointly by
AKRO and AFSC (primarily by the ESSR program), with Pacific States Marine Fisheries Commission
(PSMFC) acting as NMFS’ Data Collection Agent (DCA).18 In conjunction with issuance of
implementing regulations for EDRs, AKRO is required to gain PRA clearance for EDR forms from OMB
as described in Section 3.2.2 above, which must be renewed every three years. AFSC economists, in
collaboration with AKRO and Council staff, develop and refine draft survey questionnaires consistent
with Council specifications, coordinate and conduct outreach to industry entities to pretest and improve
survey wording and identify potential data quality concerns with individual data items for referral to the
Council where substantive changes may be required. Finalized draft EDR forms are submitted to the
Council before submission to OMB for PRA review. AFSC assists with preparing documentation for
PRA review, particularly in developing and documenting statistical methods required to complete Part B
of the PRA Supporting Statement and in preparing responses to public comment received by OMB.
As the DCA for the EDR program, PSMFC provides primary administrative support for collection and
database management for all four EDR collections. AFSC and PSMFC collaborate on development and
maintenance of workplans for implementation of new or revised EDRs, including development of Scope
of Work documents and RFP procedures for soliciting and selecting bids for required IT application
development and Data Verification Audit work subcontracted by PSMFC, with AFSC monitoring
implementation and overseeing quality control of PSMFCs administrative process and communication
with submitters. PSMFC hosts and maintains webpages for each of the EDRs that provide access to
current (reporting year and OMB expiration dates) versions of EDR forms in pdf format, general
submission instructions and background information, and access to the EDR web portal.19 Annually, 3-4
months in advance of EDR form submission deadlines, PSMFC’s Alaska Fisheries Information Network
(AKFIN) queries eLandings and permit registry databases to develop contact lists for entities subject to
submission requirements for each EDR form according to the implementing rules, and confirms the list
with AFSC. Subject entities and individuals are notified by PSMFC via certified mail 60 days prior to the
respective submission deadline, with instructions for online EDR submission or submission by mail, and
the respective forms. In the final action motion on the A91 EDR in December, 2009, the Council recommended that
NMFS develop the implementing rule in a manner that provides greater flexibility to revise survey forms as needed
(subject to Council oversight), and subsequent rules implementing new or revised EDRs (i.e., all EDR forms
currently in use) have not specified survey form content.
17
All EDR forms collect data for the previous calendar year of operations (i.e., forms reporting information
pertaining to 2018 calendar-year operations will be collected during 2019).
18
Defined in 50 CFR 679.2 and 50 CFR 680.2 as “Data collection agent (DCA) means the entity selected by the
Regional Administrator to distribute an EDR to a person required to complete it, to receive the completed EDR, to
review and verify the accuracy of the data in the EDR, and to provide those data to authorized recipients.” As
described further in sections 4.2.3.2 and 4.2.3.6, the Council specified enhanced confidential data protections for the
Crab EDR (50 CFR 680.6(a)(2)) and the GOA Trawl EDR (50 CFR 679.110(b)(1)), requiring that associated EDR
forms be submitted directly to the DCA. Although applicable rules for other EDR forms do not require NMFS to
administer the data collection through a third-party DCA, it has proven more practical to employ PSMFC to perform
applicable DCA functions for the EDR program as a whole.
19
PSMFCs EDR Program webpage: http://www.psmfc.org/program/prog-2?pid=17.

Economic Data Reporting – Discussion Paper, April 2019

33

D5 Economic Data Reporting
APRIL 2019
contacts for obtaining support and information from PSMFC and AFSC staff.20 EDR pdf files posted
online are updated for the current reporting year, and the webform implementation is updated and
reviewed for possible improvements to streamline the submission process and incorporate automated
error checking and primary data validation procedures, with testing completed prior to distribution of
EDR notices.
All nine EDR forms include a certification section which serves two functions: specifying conditions
under which the individual noticed by PSMFC is exempt from completing the data portion of the EDR
form,21 and a statement requiring the submitter to attest, by signature that “I certify under penalty of
perjury that I have reviewed all the information in this report and that it is true and complete to the best of
my knowledge”. With the exception of the A91 EDR (see Section 4.2.3.5 below), EDR forms may be
submitted by mail or email using the posted pdf versions, but all EDR submitters are encouraged to use
the secure online EDR web portal hosted by PSMFC, with customized web applications for each EDR
form and submitter type. During the EDR collection window (i.e, 60 days prior to submission deadlines,
with additional time needed for late submitters granted deadline extensions), PSMFC actively monitors
submissions, inputs data from forms submitted by mail, provides daily (Monday-Friday) email and phone
support to answer submitter questions and resolve webform problems. Upon receipt of certified EDR
forms (webform submission is finalized by a digital signature), PSMFC reviews the results of automated
data validation logs and contacts submitters to confirm or correct identified errors. Noticed entities that do
not complete the certification and submission of required forms by the deadline are contacted by PSMFC
during the next business day to determine if reasonable extensions are warranted, and any noncompliance
as of 14 days after the submission deadline is referred to AFSC and/or AKRO for consideration of
additional extensions or referral to NMFS OLE as appropriate. Noncompliance with applicable EDR
reporting requirements may result in enforcement action by OLE, including fines, and could potentially
result in permit sanctions. In addition, under several provisions in 50 CFR 680, timely submission of the
annual Crab EDR form submission to the DCA is required as a condition of an application for issuance of
an annual permit issued under the CR program (e.g., annual Crab IFQ/Individual Processing Quota (IPQ)
allocation permits, RCR permits, Hired Master permits). However, since initial implementation, the
annual submission deadline for Crab EDRs has shifted from May 1 to July 31, which is too late to allow
AKRO to confirm EDR compliance as a condition of IFQ allocations.
Following receipt of all final, certified EDR forms, completion of primary data validation, the
preproduction (stage) version of the EDR data records are integrated with catch accounting, fish tickets,
observer data and other sources and analyzed for secondary validation by AFSC and AKFIN. Reported
data values and various pro-rata indices are visually reviewed for outliers and anomalies (e.g., significant
deviations of reported values from those reported by the same entity in previous years). Potential data
errors identified in secondary validation are reviewed for follow up with submitters by PSMFC or for
third party verification audit by the CPA firms contracted by PSMFC. Procedures and results of data
verification audits are described in Section 5 below. Data corrections confirmed with submitters by
PSMFC and/or auditors are logged and entered in place of error values in the database, and loaded to the
production version of the dataset and made available to authorized analysts by AKFIN.

20

PSMFC EDR Program Manager Geana Tyler and AFSC Economist Brian Garber-Yonts have been the designated
staff contacts for the EDR program since 2006.
21
Exemption conditions are, in general, those in which the owner of a vessel or plant did not participate in the
activities to which the data portion of the form pertains, because either the vessel/plant was idle during the fishery
season, or because the vessel/plant was sold prior to the season or was operated during the season by a lessee. In the
event that an entity is noticed by PSMFC of a requirement to submit an EDR but meets one of the specified
exemptions, they are only required to indicate the exemption, sign the certification statement, and complete a
“certification-only” submission. When generating the annual contact list for EDR notices, program staff make an
effort to minimize notification of exempt submitters where possible.

Economic Data Reporting – Discussion Paper, April 2019

34

D5 Economic Data Reporting
APRIL 2019
EDR data records are considered confidential information and are protected from public disclosure
consistent with MSA Section 402(b), 50 CFR 600.402-425, and NOAA Administrative Order 216-100.
Access to confidential EDR records is limited to agency personnel, contractors, and Council staff that are
authorized to access confidential fishery data and have a signed nondisclosure agreement on file with
AKRO and PSMFC.
In addition to data confidentiality requirements that apply to other categories of confidential fisheries
data, the Council has specified additional protocols for EDR data. As noted above, implementing rules for
Crab and GOA Trawl EDRs require that the data collection be conducted by a DCA, and limits release of
unaggregated EDR data in blind format only.22 AKFIN staff maintain analytical versions of crab and
GOA Trawl EDR data tables, integrated with ancillary data and with identifiers replaced with anonymous
record IDs for use by authorized analysts; blind data protocols are not applied to A80 and A91 EDR data.
Due to concerns regarding the sensitivity of proprietary cost data collected in EDRs, the Council’s
requested AFSC to develop enhanced confidential data protocols for EDR data following the initial
collection of annual Crab EDRs in 2006; based on a review of OMB guidance and best practices for
nondisclosure control and interagency consultation, it was determined that a minimum aggregation
standard of 5 data records would be employed for public disclosure of aggregate statistics reporting EDR
results (compared to a minimum of three records required for all other federal and state sources of North
Pacific fishery data). The same “rule of 5” standard has subsequently been applied by PSMFC/AKFIN
and AFSC to all public release of statistics derived from EDR Program data. In addition, AKFIN and
AFSC follow federal guidelines for primary and secondary cell suppression described in FCSM (2005).
4.2.3

Current EDR Data Collections

The following subsections provide summary descriptions of each of the four current EDR data
collections, including the initial year of implementation, target entity populations and conditions requiring
submission of the associated EDR forms, and a summary description of the data elements collected in the
respective forms. This is followed by a summary overview of EDR variables collected in the EDR
Program as a whole.
4.2.3.1

Crab rationalization program EDR

The Council set forth the purpose and need for the Crab EDR in its June, 2002 motion as follows:
“A mandatory data collection program shall be developed and implemented as part of
the crab rationalization program and continued through the life of the program. Cost,
revenue, ownership and employment data will be collected on a periodic basis (based on
scientific requirements) to provide the information necessary to study the impacts of the
crab rationalization program as well as collecting data that could be used to analyze the
economic and social impacts of future FMP amendments on industry, regions, and
localities. This data collection effort is also required to fulfill the Council problem
statement requiring a crab rationalization program that would achieve “equity between
the harvesting and processing sectors” and to monitor the “...economic stability for
harvesters, processors and coastal communities. Both statutory and regulatory language
shall be developed to ensure the confidentiality of these data.
Any mandatory data collection program shall include:

Defined in 679.2 and 680.2 as “Blind data means any data collected from an economic data report by the data
collection agent that are subsequently amended by removing personal identifiers, including, but not limited to social
security numbers, crew permit numbers, names and addresses, Federal fisheries permit numbers, Federal processor
permit numbers, Federal tax identification numbers, and State of Alaska vessel registration and permit numbers, and
by adding in their place a nonspecific identifier.”
22

Economic Data Reporting – Discussion Paper, April 2019

35

D5 Economic Data Reporting
APRIL 2019
A comprehensive discussion of the enforcement of such a program, including
enforcement actions that would be taken if inaccuracies in the data are found. The intent
of this action would be to ensure that accurate data are collected without being overly
burdensome on industry for unintended errors.”
The Crab EDR23 was implemented concurrent with the Crab Rationalization Program under Amendments
18 and 19 of the BSAI Crab FMP (70 FR 10174), effective April 1, 2005. The rule requiring EDR
submission was codified in 50 CFR 680.6, which retroactively required affected entities to submit
“historical” EDR forms for 1998, 2001, and 2004 calendar year operations by June 1, 2005, and to submit
an annual EDR form for calendar year 2005 and thereafter by a deadline of May 1 of the following year.
The Council took final action on Amendment 42 in December, 2012, revising Crab EDR reporting
requirements, and NMFS published the final rule (78 FR 36122), effective July 17, 2013. The amended
rule extended the annual submission deadline to July 31. This section focuses on a description of the
current Crab EDR data collection, with Section 4.3 below providing a more detailed discussion of the
Council and NMFS process for developing and implementing the Crab EDR prior to 2013. However, as
each of the revised EDR forms maintained a subset of the original data elements, the majority of data
elements in the current Crab EDR have been collected continuously (with modifications where noted)
since the baseline historical EDRs were submitted in 2005.
Under 680.6, the reporting requirements for the Crab EDR apply to a) owners and leaseholders of vessels
and catcher/processors with landings of BSAI program crab (including CDQ allocation crab), and b)
owners and leaseholders of shore-based processing plants, and Registered Crab Receivers (RCRs), who
purchase and/or process landed BSAI crab during a calendar year.24 For both groups, the annual
submission requirement is conditional on active participation in harvest, purchase, and/or processing
(including providing custom processing) of CR crab.
Under the CR program, both harvest quota (QS/IFQ) and processing quota (PQS/IPQ) are held by
qualified corporate entities or harvest cooperatives that are typically distinct from the entities that operate
the crab vessels and from the processors that are subject to the EDR requirement. The Crab EDR is
comprised of three EDR forms developed for the respective sectors: the Crab CV EDR, Crab Processor
EDR, and the Crab C/P EDR.25 The CV and processor forms collect distinct sets of data elements, with
the CP form comprised of a combination of all data elements collected in the catcher vessel form and
applicable elements from the processor form. Data elements collected in each of the Crab EDR forms are
the following:
Crab CVs and CPs
• Estimated market value and replacement value of vessel;
• Crab landings volume (pounds) and ex-vessel revenue, by CR fishery and quota type;
• Annual total fuel cost and gallons;
• Fuel gallons consumed, by CR fishery;
• Provisions costs, by CR fishery;
• Bait costs, by CR fishery;
• Quota lease costs, by CR fishery and quota type
PSMFC’s Crab EDR webpage provides access to EDR forms, submitter instructions, and validation audit reports:
http://www.psmfc.org/alaska_crab/.
24
The EDR requirement for RCRs was added in the Amendment 42 EDR revision, beginning 2012 calendar year.
Prior to 2012, RCRs that held crab IPQ and purchased landed crab for custom processing, and did not operate a
plant, were not required to submit an annual EDR.
25
The forms are formally labeled in 680.6(b) as the Annual Crab Catcher Vessel Crab EDR, Annual stationary
floating crab processor and shoreside crab processor EDR, and the Annual catcher/processor crab EDR.
23

Economic Data Reporting – Discussion Paper, April 2019

36

D5 Economic Data Reporting
APRIL 2019
•
•
•
•
•
•

Total labor payments to crew (total of final settlement payments), by CR fishery;
Total labor payments to captains (total of final settlement payments), by CR fishery;
Annual total direct labor payments to crew (inclusive of crab settlements);
Health Insurance and Retirement Benefits provided to crew; (Y/N), by fishing crew/captains;
Commercial crew license number or CFEC gear operator permit number, by individual crew
member that worked on vessel during CR crab season; and
Vessel used for tendering during calendar year, (Y/N)

Crab processors, RCRs, and CPs
• Estimated market value and Borough assessed value (shore plants) or Replacement value
(floating processors);
• Crab product sales to affiliated/unaffiliated buyers, volume (pounds) and first wholesale revenue,
by crab species, product code, process code, and box size (large/small);
• Custom processing services provided, revenue, raw pounds, and finished pounds, by CR fishery,
product code, and process code;
• Crab purchased from landing vessels, pounds and cost, by CR fishery and quota type;
• IPQ leased, pounds and cost, by CR fishery and quota type; and
• Custom processing services purchased, raw pounds, finished pounds, and processing fees paid, by
CR fishery, product code, and process code;
Crab processors and RCRs
• Processing labor gross wages and paid hours, by CR fishery (CPs report processing crew labor
cost combined with fishing crew);
• Processing employee count, by location of residence, CR Crab total and Annual total
• Non-processing employment (annual total number employed), and total annual gross wages and
salaries
4.2.3.2

Amendment 80 economic data EDR

The Council set forth the purpose and need for the Amendment 80 Non-AFA Trawl C/P EDR (A80 ER)
in its June 10, 2006 motion as follows:
“The purpose of the data collection program is to understand the economic effects of
the Amendment 80 program on vessels or entities regulated by this action, and to
inform future management actions. The data is needed to assess whether Amendment
80 addresses some goals in the problem statement to mitigate, to some degree, the
costs associated with bycatch reduction. Data will be used by Council and agency
staff, recognizing that confidentiality is of extreme importance.
Economic data collected under this program include employment data by vessel
collected to determine the labor amounts and costs for the sector. In addition, revenue
and cost data by vessel will be collected to evaluate trends in returns to the sector that
may be compared with elements of the Amendment 80 program, such as bycatch
reduction measures”
The A80 EDR26 was implemented in regulation at 50 CFR 679.94, as part of the Amendment 80
management program, published by NMFS on September 14, 2007 (72 FR 52668), effective January 20,
2008. The initial A80 EDR submissions were due June 1, 2009 reporting data for the 2008 calendar year.
PSMFC’s Amendment 80 EDR webpage provides access to EDR forms, submitter instructions, and validation
audit reports: http://www.psmfc.org/am80edr/.
26

Economic Data Reporting – Discussion Paper, April 2019

37

D5 Economic Data Reporting
APRIL 2019
The A80 EDR reporting requirement under the original rule applied to all Amendment 80 Quota Share
(QS) permit holders, with permit holders who actively operated an A80 vessel required to complete and
the entire EDR form, and QS permit holders who did not operate a vessel required to complete portions of
the form pertaining to QS permit sale and/or lease costs and revenues.
NMFS’ publication of the rule implementing the GOA Trawl EDR program in 2014 included
amendments to 679.94, redesignating the A80 EDR as the “Annual Trawl Catcher/Processor Economic
Data Report” and added additional reporting elements to the form; the rule also extended the requirement
to complete the all portions of the EDR form to owners/leaseholders of any vessel named on a LLP
groundfish license authorizing a C/P using trawl gear to harvest and process LLP groundfish species in
the GOA.27 The association between the GOA Trawl (CV and Processor) EDR and Annual Trawl C/P
EDRs has resulted in confusion. For the sake of clarity, the EDR currently specified under 50 CFR 679.94
is referenced in this discussion paper as the A80 EDR, and that under 679(a)(1) and (2) as the GOA Trawl
EDR; any relevant distinctions and/or overlaps are described as needed.
The A80 EDR form has been submitted annually by A80 QS holders since 2008, consistently collecting
comprehensive, quantitative data for the following data elements:
•
•
•
•
•
•
•

•
•
•

Vessel characteristics and registry details (home port, tonnage, fuel capacity, shaft horsepower,
year built);
Survey value, date, and included assets;
Fuel consumption rate (gal/hour), and annual total gallons consumed, by operating activity;
Freezer storage and throughput capacity, and processing line throughput capacity, by A80 and
GOA groundfish species and product code;
Fishery product sales volume and revenue, LLP sale revenue, quota lease revenue and pounds,
and other vessel operations income;
Annual total capital expenditure, grouped by fishing gear, processing equipment, other
equipment, and other vessel capital;
Non-labor vessel operating expenses, annual totals grouped by: fuel; lubrication; provisions,
repair and maintenance, vessel/equipment lease costs, fishing gear purchases, leases and repair
costs; freight and storage costs for product sales; other freight and storage; materials; observer
fees and reporting/monitoring costs; cooperative fees, general administrative/management
overhead, vessel insurance; fisheries landing taxes, total cost and volume of raw fish purchases;
and QS lease quantity and costs by A80 species;
Gross labor costs, grouped by: deck crew, processing crew, and all other on-board crew
Average number of crew onboard and total crew members employed in year, grouped by: deck
crew, processing crew, and all other on-board crew; and
Use of share-system for crew compensation (y/n), by processing/non-processing crew

Beginning in 2016, the revised Annual Trawl CP EDR added collection of individual commercial crew
license or CFEC gear operator permit numbers for all individual crew members that worked on the vessel
during the calendar year.
4.2.3.3

Amendment 91 Chinook salmon EDR

The Council set forth the purpose and need for the Amendment 91 Chinook salmon EDR (A91 EDR) in
its December, 2009 motion as follows:

27

As a matter of public record, the addition of the EDR requirement to GOA Trawl CPs as defined in the 2014 rule
effectively added the owner of one CP to the population of entities subject to the A80 EDR requirement.

Economic Data Reporting – Discussion Paper, April 2019

38

D5 Economic Data Reporting
APRIL 2019
“In April 2009 the Council approved Amendment 91 to the BSAI groundfish fishery FMP
to reduce Chinook salmon bycatch in the Bering Sea pollock fleet. Under Amendment 91,
the pollock fishery has the option of participating in a NMFS-approved Incentive Plan
Agreement (IPA) to access a higher hard cap than is available in the absence of an IPA.
The IPAs provide a new and innovative method of bycatch management. A data
collection program is needed in conjunction with Amendment 91 to understand the effects
and impact of the IPAs. The data collection program will focus on: (1) evaluating the
effectiveness of the IPA incentives in times of high and low levels of salmon bycatch
abundance, the hard cap, and the performance standard in terms of reducing salmon
bycatch, and (2) evaluating how the Council’s action affects where, when, and how
pollock fishing and salmon bycatch occur. The data collection program will also provide
data for the agency to study and verify conclusions drawn by industry in the IPA annual
reports. To ensure that a full assessment of the program is possible, the data collection
program should be implemented at the time Amendment 91 is implemented or as soon as
practicable.
To ensure that a full assessment of the program is possible from the start of the program,
the data collection program should be separated into two phases, with a suite of data
collection measures implemented at the time Amendment 91 goes into effect and sent to
the Comprehensive Economic Data Collection Committee after IPAs have been fully
developed and submitted to NMFS. The objective of this collection is to provide an
improvement in the amount of data available to evaluate the effectiveness of incentives to
minimize Chinook salmon bycatch under Amendment 91.”
The A91 EDR28 and additional record keeping and reporting requirements associated with monitoring of
Chinook salmon bycatch avoidance measures implemented concurrently, were published by NMFS on
February 2, 2012 (77 FR 5389), effective March 5, 2012, approximately 17 months after rules
implementing Amendment 91 (75 FR 53026) went into effect. The initial submission of EDR forms
required under 50 CFR 679.65 were due on June 1, 2013 reporting data for the 2012 calendar year.
The A91 EDR reporting requirement applies most broadly to owners and leaseholders of AFA-permitted
catcher vessels, catcher-processors, and motherships active in the Bering Sea pollock fishery, and to
entities eligible to receive Chinook salmon PSC allocations (apart from AFA vessel owners, this includes
AFA In-shore Sector harvest cooperative representatives, sector-based Incentive Plan Agreement
representatives, and Community Development Quota Program group representatives), all of whom are
annually noticed of EDR submission requirements by PSMFC as described previously. In addition,
captains of AFA vessels who were active in the A or B season of the previous year pollock fishery are the
target population of one of the three A91 EDR forms, but are assigned by vessel owners and not directly
required to submit EDR forms to NMFS.
The Amendment 91 EDR is comprised of three separate forms: the Compensated Transfer Report, the
Vessel Fuel Survey, and the Vessel Master Survey. The Compensated Transfer Report (CTR) is intended
to collect transaction-level data on all bipartite transfers of Chinook PSQ allocation units during the
pollock season in which monetary payment is included the transaction (i.e., “in-kind only” transactions
are exempted). For each individual PSC transfer, the submitter is required to report: the NMFS id of the
other party, the type of association between the submitter and the other party, the entity type of the other
party, the number of Chinook salmon PSC transferred, the payment in $US transferred, and a Y/N
indicator that other assets besides Chinook PSC were included in the transfer. It was the NPFMC’s

PSMFC’s Amendment 91 Chinook Salmon EDR webpage provides access to EDR forms, submitter instructions,
and validation audit reports: http://www.psmfc.org/chinookedr/.
28

Economic Data Reporting – Discussion Paper, April 2019

39

D5 Economic Data Reporting
APRIL 2019
intention that the CTR would capture "spot-market" PSC transfers, exempting pre-season or other
transfers in which salmon PSC and pollock quota are coupled and avoiding revelation of pollock quota
lease value. The form is to be completed by all entities participating as lessor or lessee in one or more
"compensated transfers" of Chinook PSC; however, no such transactions have been reported, and all CTR
form submissions to date have been “certification-only” submissions.
The Vessel fuel survey is required for all AFA vessels that harvested BSAI pollock during the previous
year, and collects four data elements:
•
•

Average hourly rate of fuel consumption for the vessel while operating in the BSAI pollock
fishery, reported separately for fishing and transiting; and
Total annual amount (in gallons) of fuel loaded to the vessel during the year, and total fuel cost.

The vessel master survey is comprised of a series of qualitative response questions regarding fishing and
bycatch conditions observed by vessel masters during the BSAI pollock fishery, and factors in effect that
motivated Chinook bycatch avoidance (survey questions are listed below).
•
•
•
•

•
•
•
•

•
•
•

If the vessel participated in an Incentive Plan Agreement, did the IPA affect your fishing
strategy? If yes, please describe and discuss what incentives had the largest impact on your
strategy.
Did the amount and/or cost of Chinook PSC allocation available to the vessel lead you to make
changes in pollock fishing operations? If yes, please describe.
How would you compare the Chinook salmon bycatch and pollock conditions during the A and B
seasons this year relative to the last two years? Please describe any unique aspects of the season.
Did Chinook salmon bycatch conditions cause you to delay the start of your pollock fishing or
otherwise alter the timing of your pollock fishing for some period during the past A and/or B
season? If yes, please describe the Chinook salmon bycatch condition, when it occurred, and any
change in your pollock fishing as a result.
In the past year, did you end a trip and return to port early because of Chinook salmon bycatch
conditions? [ ] YES [ ] NO. If YES, please indicate the number of trips that this occurred in each
season (use a checkmark to indicate appropriate answer for each season).
Please describe how any area closures or restrictions for the purpose of reducing Chinook salmon
bycatch affected where and how you fished.
Please describe how any regulatory or other area closures or restrictions for a purpose other than
reducing Chinook salmon bycatch affected where and how you fished.
Compared to a typical year, did weather or sea ice conditions have more, less or about the same
impact on fishing as in a typical year? Please describe especially if there were particularly
uncommon conditions at any point this year. If these conditions had an impact on your ability to
avoid Chinook salmon bycatch, please describe.
Were there exceptional factors that affected your pollock fishing this year? For example, were
there unusual market or stock conditions, unusual pollock fishing conditions, or maintenance
problems? Please describe.
Separate from an Incentive Plan Agreement, were there other incentives for you to reduce
Chinook salmon bycatch? If yes, please describe.
Did actual or potential bycatch of species other than Chinook salmon cause you to change your
harvesting decisions during the pollock season? If yes, please describe.

The structure of the A91 EDR is distinct from the other three EDRs in that its three forms are submitted
separately, with AFA vessel owners as the primary submitter group, from which all three of the forms are
required. The CTR form is also required from PSC entities, for whom it is the only EDR requirement.
Vessel owners are also required to submit the fuel survey form, and to collect and submit vessel master
Economic Data Reporting – Discussion Paper, April 2019

40

D5 Economic Data Reporting
APRIL 2019
surveys completed by the captain(s) of the vessel designated by the owner.29 All three forms include
certification sections, which include conditions under which the submitter is exempted from the data
reporting portion of the form, and is required only to submit the certification section of the form if such
exemptions apply. The requirement to complete the data portion of the CTR form is conditional on
participation in a “compensated transfer” as defined in the form, and for the vessel master and fuel survey
forms, is conditional on the vessel being active in harvesting BSAI pollock during the reporting year. In
addition, the implementing rule for the A91 EDR specified that all forms be electronically submitted
online. This required development by PSMFC of a more complicated web application interface to
facilitate vessel owners assignment of vessel master surveys while ensuring security of confidential data
between linked users accounts.
4.2.3.4

Gulf of Alaska trawl EDR

The Council set forth the purpose and need for the GOA Trawl EDR in its February, 2013 motion as
follows:
“The Council is interested in developing a data collection program that can be
established prior to the implementation of a trawl catch share program in the GOA. This
fast-tracked data collection would provide the Council and analysts with relevant
baseline information that can be used to assess the impacts of a catch share program on
affected harvesters, processors, and communities in the GOA.
In developing a data collection program that can be implemented quickly, efficiently, and
with minimal burden on participating stakeholders, the Council intends to prioritize the
collection of information that is relevant, reliable, and for which existing data sources do
not exist. Given the potential for implementation of catch shares in both the Central and
Western GOA, the scope of the analysis should include participants in both management
areas.”
The final rule implementing the GOA Trawl EDR30 was published December 2, 2014 (79 FR 71313),
effective January 1, 2015, and establishing an initial submission due date of June 1, 2016 for EDRs
reporting 2015 calendar year data. As noted previously, the EDR was intended by the Council to be
implemented in advance of a catch-share program for the GOA that was in-development at the time of its
2013 motion. However, Council action on GOA bycatch management was suspended in December 2016.
The target population for the GOA Trawl EDR includes owners and leaseholders of catcher vessels and
catcher/processors active in the Central and Western GOA groundfish trawl fishery, and operators of
shoreside processing facilities that receive groundfish catch from the GOA. The EDR is comprised of
three EDR forms: in addition to the Annual Trawl CP EDR described in Section 4.2.3.2 above, the
Annual Trawl Catcher Vessel EDR, Annual Shoreside Processor EDR, and Annual Trawl CP EDR forms.

679.65(d) states: “Vessel Master Survey. (1) For any AFA ­permitted vessel used to harvest pollock in the Bering
Sea in the previous year: (i) The vessel master must complete the Vessel Master Survey, and the Vessel Master
certification following the instructions on the form. (ii) An owner or leaseholder must complete the Vessel owner
certification following instructions on the form. (iii) An owner or leaseholder must submit all Vessel Master
Surveys, and each Vessel owner certification electronically on or before …” However, no regulatory definition of
“vessel master” is applicable to AFA vessels.
30
PSMFC’s GOA Trawl EDR webpage provides access to EDR forms, submitter instructions, and validation audit
reports: http://www.psmfc.org/goatrawl/.
29

Economic Data Reporting – Discussion Paper, April 2019

41

D5 Economic Data Reporting
APRIL 2019
The Trawl CV EDR form is required for all trawl CVs that harvested groundfish in the GOA during the
previous year. The form collects the following data elements:
•
•
•
•
•

Estimated market value and replacement value of vessel;
Fishing gear costs – total direct capitalized expenditures and fully expensed costs for purchase,
lease, installation and repair of a) salmon and halibut excluder gear, and b) trawl gear (including
excluder gear other than salmon and halibut);
Annual total fuel and lubrication cost and gallons;
Total labor payments to a) crew and b) captain (total of final settlement payments), and number
of crew, GOA groundfish only;
Commercial crew license number or CFEC gear operator permit number, by individual crew
member that worked on vessel during GOA groundfish trawl fishing.

The Annual Shoreside Processor EDR form is required from all shore-based processors that receive and
process groundfish from GOA trawl fisheries. The forms collects the following data elements:
•
•
•
•
•
•
4.2.3.5

Estimated market value; Borough assessed value or Replacement value;
Municipal water utility consumption, gallons and cost, by month, Kodiak plants only;
Municipal electrical utility consumption, kilowatt-hours and cost, by month, Kodiak plants only;
Processing labor gross wages and hours, by month and housing-status (housed, non-housed),
groundfish processing only;
Number of processing employees, by month, groundfish only;
Non-processing employment, number employed, total wages and salaries, annual total.
Summary overview of EDR variables by EDR form

Table 3 below provides a comparative overview of all data elements collected in the EDR program as a
whole (with the exception of the A91 Vessel Master Survey). The first column groups together data
element collected in one or multiple EDR forms by category: vessel/plant characteristics; revenue, capital
expenditures, non-labor operating costs; employment and labor costs; and other operational data, with
individual data elements broken out to show the comparison the scope of elements collected in the
respective EDR forms. The description of data elements by EDR form shown in column 2-9 indicate the
particular specification of the data element in the respective from, including stratification/aggregation (by
fishery, annual), scope or reporting (annual, groundfish only), and other variations between EDR forms.

Economic Data Reporting – Discussion Paper, April 2019

42

D5 Economic Data Reporting
APRIL 2019
Table 3

Comparative overview of EDR variables across EDR forms
BSAI crab

EDR Variables, by
general group

Catcher vessel

Vessel / plant characteristics
Name of Cooperative
Annual
General vessel
characteristics (1)
Value of Vessel (Plant)
and equipment
Note: Assessed value
reported for Shoreside
Estimated market
processors only;
value;
Replacement value
replacement value
reported for CVs and
floating processors
only

GOA trawl / Amendment 80
Catcher Processor

Shoreside &
floating
processor

Catcher vessel

Annual

Amendment 91
Shoreside &
floating
processor

Catcher processor

Vessel Fuel
Survey

Annual
Annual

Estimated market
value; replacement
value

Fuel consumption rate,
average (gal/hour)
Freezer capacity storage capacity
(pounds) and
maximum product
throughput (pounds per
hour)
Processing capacity number of processing
lines and maximum
throughput (pounds per
hour)

Economic Data Reporting – Discussion Paper, April 2019

Estimated
market value;
Borough
assessed value
or Replacement
value

Estimated market
value;
replacement value

Estimated
market value;
Borough
assessed value
or Replacement
value

Survey value (survey
date and inclusions)

By activity
(fishing/processing;
steaming loaded;
steaming empty);
Annual

By activity
(fishing;
transiting);
Pollock
fishery

Annual

By species and product;
A80 and GOA
Groundfish

43

Compensated
Transfer
Report

D5 Economic Data Reporting
APRIL 2019
BSAI crab
EDR Variables, by
general group

Catcher vessel

GOA trawl / Amendment 80
Catcher Processor

Shoreside &
floating
processor

Catcher vessel

Amendment 91
Shoreside &
floating
processor

Catcher processor

Revenue
Ex-vessel

Revenue and
pounds, by CR
fishery and quota
type

1st Wholesale

Revenue and pounds,
by affiliated (y/n),
crab species, product,
process, and box size

Custom processing
provided

Revenue, raw pounds,
and finished pounds,
by CR fishery,
product, and process

Revenue and
pounds, by
affiliated (y/n),
crab species,
product,
process, and
box size
Revenue, raw
pounds, and
finished pounds,
by CR fishery,
product, and
process

Revenue and pounds
(includes custom
processing); Annual

Other vessel operation
income
LLP sale revenue

Revenue; Annual
By LLP sold
Shares (mt) and royalty
revenue; by A80 quota
species

Quota royalty revenue
Capital expenditures

Fishing gear(3)

Processing equipment
Other equipment
Other capital
expenditures
LLP purchase cost

Economic Data Reporting – Discussion Paper, April 2019

Capitalized plus
expensed value;
by type
(halibut/salmon
excluder), Trawl
gear

Annual

Annual
Annual
Annual
Annual

44

Vessel Fuel
Survey

Compensated
Transfer
Report

D5 Economic Data Reporting
APRIL 2019
BSAI crab
EDR Variables, by
general group

Catcher vessel

GOA trawl / Amendment 80
Catcher Processor

Shoreside &
floating
processor

Catcher vessel

Amendment 91
Shoreside &
floating
processor

Catcher processor

Vessel Fuel
Survey

Compensated
Transfer
Report

Operating costs, non-labor (annual expenses)

1) Fuel cost and
gallons; Annual
2) Fuel gallons,
by CR Fishery

1) Fuel cost and
gallons; Annual
2) Fuel gallons, by CR
Fishery

Food and provisions
Bait cost
Vessel and equipment repair and maintenance
costs
Vessel and equipment lease costs
Fishing gear purchases, lease, repair
costs (excluding
finance costs)
Freight, storage, other
sales costs for nonFOB sales
Freight and storage
other than for products
Product and packaging
materials
Observer / monitoring
fees
Cooperative fees
General Administrative
Cost
Insurance
Fisheries landing taxes
Raw fish purchases
from other vessels,
quantity and cost

By CR fishery
By CR fishery

By CR fishery
By CR fishery

QS/PQS lease amounts
and cost

By CR fishery
and quota type

Fuel and lubrication

Custom processing
purchased - quantity
and revenue

Fuel and
lubrication cost
and fuel gallons;
Annual

1) Fuel cost, lubrication
cost; Annual
2) Fuel gallons, by
activity
(fishing/processing;
steaming loaded;
steaming empty);
Annual
Annual

Fuel cost
and gallons;
Annual

Annual
Annual

Annual

Annual
Annual
Annual
Annual
Annual
Annual
Annual
Annual
By CR fishery and
quota type

By CR fishery
and quota type

By CR fishery and
quota type

By CR fishery
and quota type

By CR fishery,
product, process

By CR fishery,
product, process

Economic Data Reporting – Discussion Paper, April 2019

Annual
Chinook PSC;
by
compensated
transfer

By A80 quota species

45

D5 Economic Data Reporting
APRIL 2019
BSAI crab
EDR Variables, by
general group

Catcher vessel

GOA trawl / Amendment 80
Catcher Processor

Shoreside &
floating
processor

Catcher vessel

Catcher processor

Final settlement
paid, total by
crew-type (fishing
crew, captains);
GOA trawl

Gross wages, total by
crew-type (deck crew;
other non-processing
crew); Annual

Amendment 91
Shoreside &
floating
processor
Gallons and
cost, by month;
Kodiak plants
only
kWh and cost,
by month;
Kodiak plants
only

Utilities (municipal) water quantity and cost
Utilities (municipal) electricity quantity and
cost
Labor cost and employment
Final settlement
paid, total by
Labor cost - harvesting
crew-type
(4)
(fishing crew;
captains) and CR
fishery

Labor cost - processing
(5)

Final settlement paid,
total by crew-type
(fishing/processing
crew; captains) and
CR fishery

Combined with
harvesting labor cost

Labor cost - non-wage
expenses

Gross wages and
hours, by month
and housingstatus (housed,
non-housed);
Groundfish only
Total wages and
salaries, nonprocessing
personnel;
Annual

Gross wages; Annual

Total wages and
salaries, nonprocessing
personnel;
Annual

Labor cost - Other
personnel(6)

Labor cost - total
vessel labor

Gross wages
and hours; by
CR fishery

Total direct
payment to crew
(inclusive of
settlements);
Annual
Benefits provided
(Y/N), by crewtype (fishing
crew; captains);
CR Crab

Total direct payment
to crew (inclusive of
settlements); Annual
Benefits provided
(Y/N), by crew-type
(fishing crew;
captains); CR Crab

Total benefits,
recruitment, travel, and
non-wage employment
costs; Annual
Count of paid
crew (excluding
captains); GOA
trawl

Employment harvesting

Employment processing

Economic Data Reporting – Discussion Paper, April 2019

Employee
count, by
location of
residence; CR

Employee count and
average positions, by
crew-type (deck crew;
other non-processing
crew); Annual
Employee count,
average positions, and
average hours per
employee-day; Annual

Employee count,
by month;
Groundfish
fisheries

46

Vessel Fuel
Survey

Compensated
Transfer
Report

D5 Economic Data Reporting
APRIL 2019
BSAI crab
EDR Variables, by
general group

Catcher vessel

GOA trawl / Amendment 80
Catcher Processor

Employment - other
non-processing
Employment - Crew
licenses and permits

License/permit
number, by crew
member; CR
Crab

License/permit
number, by crew
member; CR Crab

Shoreside &
floating
processor
Crab and
Annual
Employee
count; Annual

Catcher vessel

Amendment 91
Shoreside &
floating
processor

Catcher processor

Vessel Fuel
Survey

Compensated
Transfer
Report

Employee count;
Annual
License/permit
number, by crew
member; GOA
groundfish

License/permit number,
by crew member;
Annual
Y/N, by some/all,
processing/nonprocessing; Annual

Crew share system in
use
Other operational data

By activity (fishing;
processing) and fishery
(A80, GOA groundfish,
other)
Annual
Annual

Active days fishing/processing
Inactive days
Travel/offload days
Did vessel perform
tendering?

Y/N; Annual

Notes:
1: Home port, gross/net tonnage, length overall, beam, shaft horsepower, fuel capacity, year built
2: BSAI crab CV + CP + GOA trawl CV: estimated market value and replacement value; GOA trawl CP: survey value; BSAI crab shoreside processor + GOA
trawl shoreside processor: borough assessed value, current estimated value; BSAI crab floating processor + GOA trawl floating processor: current estimated
market value, current estimated replacement value
3: GOA trawl CV: separate reporting of excluder gear and trawl gear costs, includes total direct expenditures for lease, purchase, installation, and repair of gear;
excludes finance costs; GOA trawl CP: separate reporting of fishing gear capital expenditures and fishing gear leases, repairs, and purchases fully expensed in
calendar year
4: BSAI crab CV + CP + GOA trawl CV: reporting of labor payments to harvest crew and captain excludes non-wage expenses such as payroll taxes,
unemployment insurance, and worker's compensation; GOA trawl CP: reporting of deck crew labor expenses lumps together captain and other harvesting crew
reporting, and includes bonuses and payroll taxes but excludes benefits and insurance
5: GOA trawl CP: includes bonuses and payroll taxes but excludes benefits and insurance
6: BSAI + GOA trawl shoreside/floating processor: reporting of labor payments excludes non-wage expenses such as payroll taxes, unemployment insurance,
and worker's compensation; GOA trawl CP: reporting of labor expenses for other employees includes bonuses and payroll taxes but excludes benefits and
insurance.

Economic Data Reporting – Discussion Paper, April 2019

47

D5 Economic Data Reporting
APRIL 2019
An examination of Table 3 indicates a number of inconsistencies, at different scales, across EDR forms.
The most obvious disparity is between the relative comprehensiveness of the content reported in the A80
EDR form compared to the scope of data collected in other EDR forms.
The A80 EDR collects measures of the physical capital stock of the vessel, and collects revenue and costs
using a framework that has been tested for consistency with financial and other record systems in use by
vessel owners. Revenue is collected for four primary income streams generated by the vessel and
associated assets, each of which is reported as a simple annual aggregate value rather than disaggregated
by fishery or bounded to one fishery or period during the year. Capital expenditures are collected for four
major categories that collectively represent the physical and intangible assets comprising the productive
capital of the vessel, and annual expenses are broken out into a reasonably complete set of accounting
categories that likely correspond readily to information that vessel owners maintain as a matter of
standard business tax and financial accounts. Labor costs and employment are broken out into coherent
labor classes.
In contrast to the A80 form, no other EDRs collects general capital investment expenditures. The crab CP
EDR form collects four categories of non-labor operating costs compared to 14 in the A80 CP form, but
requires stratification by individual crab fishery. The Crab CV form collects fuel, provisions, and bait by
crab fishery, whereas the GOA CV form collects annual fuel expenditures.
At a finer scale, there are additional inconsistencies across EDR forms in the specification of individual
data items, as in the GOA CV reporting of trawl gear and excluder devices combines capitalized
expenditures (paid over multiple years) with annual expenses, compared to separate treatment of fishing
gear capitalized and expense costs in the Trawl CP form. Also notably, the GOA CV form includes three
alternate scales of reporting: values aggregated to total annual value, GOA trawl value, and GOA
groundfish value.
4.3

Historical overview of EDR development process

A review of the documentary history of the Council and NMFS efforts to develop economic data
collections spans 20 years of Council minutes and Federal Register notices. Table 4 below provides a
sequential timeline of significant events in the 20 year period over which EDRs evolved from the
ambitiousness of the original crab EDR to the more modest goals of the GOA Trawl EDR. Current status
of the EDR program. The timeline is drawn largely from Council minutes, and follows the course of
significant actions and events in the development of each of the respective EDR collections, initially
through the Council process, followed by rule-making and OMB review processes, to administration of
annual EDR submissions and production of data. The brief text describing the identified events are
primarily intended to provide sufficient context and a reference to the documentary record (i.e., minutes
from the Council; FR notice, or other source). Rows are color-coded for each of the four EDR’s, Council
Process for actions pertaining to economic data collection generally, and Comprehensive Data Collection
for the Council committee and associated initiative suspended in 2010.

Economic Data Reporting – Discussion Paper, April 2019

48

D5 Economic Data Reporting
APRIL 2019
Table 4

Comprehensive timeline of Alaska Economic Data Reporting actions in the Council and regulatory processes, 1998-2018.

Program
Council Process
Council Process

Action Date
April-98
June-00

Council Process
Council Process

September-00
April-01

Council Process
Crab

December-01
April-02

Crab

June-02

Crab

October-02

Crab

February-03

A80

December-03

Crab

July-04

Crab

May-05

A80

June-05

Crab

July-05

A80

February-06

A80

April-06

Action
Council received report on first meeting of the Social and Economic Data Committee (Dennis Austin- Chair)
SSC received a report from AFSC economists on the voluntary Cost, Earnings and Employment Survey of BSAI Pollock Fishery
project
The Council received the report of the Social and Economic Data Committee’s Aug-00 meeting regarding AFSC survey project.
Council minutes regarding committees notes that the Socioeconomic Data Committee is still in place but the Council had determined
earlier that the committee would remain inactive until fall of 2001.
Interagency ‘Initiative to Collect Socio-economic Data’ proposal on Council agenda
At initial review of Crab Rationalization alternatives, elements and options for analysis, the Council approved an amended problem
statement and elements and options for analysis, adding Element 7: “Implement a systematic data collection system for economic
data, sufficient to monitor the relative distribution of both revenue and “quasi-rents”/profit in the processing and harvesting sectors.”
Council takes final action on selection of Crab Rationalization preferred alternative, including a more detailed description of Element
16: a mandatory economic data collection re: scope, purpose and need, confidentiality, and enforcement, and noting need for
congressional action to authorize collection of processor economic data. Tasks data collection committee to develop data collection
alternatives for analysis.
Council receives data collection committee report with alternative draft survey designs; approves motion advancing three alternatives
for treatment of fixed costs and suboptions for spatial disaggregation of cost data, direction to develop enhanced confidentiality
protections and mandatory audit.
Council approves motion specifying mandatory data collection program elements A-F, defining scope of reporting to CR crab fishery
costs; limiting fixed costs associated with variable costs; third-party data collection and blind data protocol, verification and
enforcement.
The Council finalized Amendment 80 a and b components and options for analysis, including a socioeconomic data collection
program.
NMFS publishes Final EIS for BSAI Crab Fisheries and RIR/IRFA for Voluntary Three-Pie Cooperative Program; RIR/IRFA Ch.
3.17 and Appendix 3-6 compile detailed record of EDR development process.
EDR data collection implemented as part of the BSAI crab rationalization program under CFR 680.6, with Pacific States Marine
Fisheries Commission designated as the official Data Collection Agent (DCA) charged with administration of the data collection and
database custody. EDR forms are described in detail in CFR 680.6, based on design process in collaboration between AFSC and crab
industry under Council oversight.
Council final motion on A80 tasks staff to develop evaluation of “collecting cost, revenue, ownership, and employment data on a
periodic basis to provide the information necessary to study the impacts of the program” in EA/RIR/IRFA.
Deadline for mandatory EDR submission for pre-rationalization reference years 1998, 2001, and 2004. PSMFC distributes follow-up
questionnaire to solicit submitter feedback.
Council final motion on A80 tasks staff to work with NMFS to develop specific elements of socioeconomic data collection and
include as appendix to EA/RIR/IRFA.
Council reviews revised draft EA/RIR/IRFA, with draft economic survey as appendix; NMFS letter to Council (dated 3/28/06)
informing of newly issued OMB guidance re: requirements for PRA clearance for statistical surveys, advising appointment of data
committee to address OMB guidelines in design of economic data collection element. Final motion includes description of Council
process for developing data collection program: 1) convene staff workgroup to address OMB requirements; 2) host industry
workshop at June Council meeting; 3) Council review and approval of program in consideration of SSC comments.

Economic Data Reporting – Discussion Paper, April 2019

49

D5 Economic Data Reporting
APRIL 2019
Crab

May-06

A80

June-06

Comprehensive Data
Collection
Comprehensive Data
Collection

June-06

Crab

October-06

Crab

November-06

Crab

December-06

Crab

March-07

Comprehensive Data
Collection

March-07

Crab
Crab

April-07
June-07

Crab

August-07

A80
A80
Comprehensive Data
Collection

August-07
September-07
October-07

A80

October-07

Comprehensive Data
Collection

February-08

October-06

Deadline for first Annual EDR submission, with mandatory submission of completed EDR forms reporting data for the previous
calendar year crab operations; EDR forms revised to incorporate limited modifications to address survey design errors identified by
submitter feedback.
Council reviewed a final draft EA/RIR/IRFA and took final action to implement Amendment 80; Section 3.2.12.15 of analysis
includes detailed description of program corresponding to PRA Supporting Statement Part B (i.e., justification; specification of data
elements; models and measures, confidentiality protection; data verification and audit process; costs and reporting burden estimates).
NMFS representative recommends Council develop a comprehensive data collection rather than program-specific “islands of
information”; Council tasks staff to develop discussion paper.
During staff tasking Council requested that the agency prepare discussion paper on a comprehensive socioeconomic data collection
program, and bring it to the Council for review in October.
Council reviews discussion paper on comprehensive economic data collection. Approves motion requesting AFSC to coordinate
workgroup of agency, Council, GC, OLE staff to further develop discussion paper on structure data collection program and draft
surveys by sector (including shoreside processors/motherships), and be responsive to AP and SSC comments.
Selected EDR submitters notified with directions for submission of audit materials, following AFSC/PSMFC development of
procedures for audit validation as required by CFR 680.6; selection of CPA firm AKT, LLP contracted by PSMFC as the third party
EDR auditor.
Informal discussions between AFSC and Council staff and industry representatives following the 2006 EDR submission and
initiation of audit proceedings, identifying an array of data quality and confidentiality concerns.
Council requests development of draft protocols for use of EDR data to address data quality and confidentiality concerns for Council
and industry review.
Brian Garber-Yonts of the AFSC presented “Confidentiality and Data Quality Protocols for BSAI Crab Economic Data: A
Discussion and Proposal.” The AP recommended the processes contained in the confidentiality and data quality protocols for BSAI
Crab Economic Data paper be followed. The Council motion acknowledges the process laid out in the discussion paper and approves
the Advisory Panel’s recommendation.
Council receives comprehensive economic data collection discussion paper and workgroup progress report; noting need for industry
input, NMFS indicates formal Council workgroup may be necessary to fully pursue data collection program. Council takes no action
pending SSC review of discussion paper.
Council receives discussion paper on development of data quality and confidentiality protocols and approves process proposed.
Submission of EDR reports for CY 2006; deadline revised from May 1 to June 28 to accommodate tax reporting schedule and
finalization of ex-vessel and crew settlement contracts; online EDR form is implemented for catcher vessel sector EDR with
automated validation checks; additional EDR revisions to address survey design errors identified by submitter feedback. [Note: as of
December 2011, EDR forms and administrative process has remained largely constant since 2007.
Formal public meetings in Kodiak and Seattle to solicit further crab industry feedback regarding potential reporting errors and survey
design flaws were held in July and August.
BSAI Amendment 80 EDR PRA package was pre-approved by OIRA
BSAI Amendment 80 EDR PRA package was approved without change by OIRA
Council receives update on inter-agency workgroup and reports from AP and SSC on discussion paper. At staff tasking, Council
agrees that Chair will appoint small committee, to include industry sector and community representatives, to work with inter-agency
workgroup on developing proposed data collection program, including clarification program goals.
NMFS publishes final rule implementing BSAI Amendment 80 EDR (72 FR 52668); includes A80 EDR program under CFR 679.94,
designating PSMFC as data collection agent.
Council announces appointments to Comprehensive Socioeconomic Data committee (Glenn Reed, Chair); Committee holds first
meeting.

Economic Data Reporting – Discussion Paper, April 2019

50

D5 Economic Data Reporting
APRIL 2019
Crab

February-08

Crab

March-08

Crab

May-08

A80

June-08

Crab

June-08

Crab
Crab

September-08
October-08

Crab

December-08

Comprehensive Data
Collection
Crab

February-09

A91

April-09

A91

May-09

A91

June-09

Crab

July-09

Crab

October-09

Council Process

October-09

A91

October-09

February-09

Council receives report from AFSC on Crab EDR database documentation in the form of detailed tabular metadata, including all data
quality evaluation protocols and results to-date; Council initiates process for industry review of data use and confidentiality protocols
through Pacific Northwest Crab Industry Advisory Committee (PNCIAC).
PSMFC/AKFIN completes initial transfer of the Crab EDR database from MS Access into AKFIN’s Oracle relational database
system, enabling more robust database management and integration of EDR database with other fisheries databases in AKFIN
system; completes A80 EDR database design in Oracle.
Council receives updated report from AFSC on Crab EDR database documentation/metadata; Council establishes a process for
formal review of EDR metadata and suspends use of EDR data pending completion of review. PNCIAC EDR subcommittee holds
meeting to review metadata document; formal public review of Crab EDR database initiated.
Deadline for first annual Amendment 80 EDR submission, with mandatory submission of completed EDR forms reporting data for
the previous calendar year operations.
PNCIAC EDR subcommittee meeting: PNCIAC completes formal review Crab EDR metadata/data quality; subcommittee provides
detailed comments on metadata and data quality findings.
PNCIAC EDR subcommittee meeting: AFSC issues replies to comments; subcommittee meeting.
PNCIAC EDR subcommittee meeting: Two-day PNCIAC subcommittee workshop; Three-tier (A/B/C) data quality classification
applied to EDR data.
Council receives report on Crab EDR data quality findings and data use and confidentiality protocol recommendations finalized by
PNCIAC subcommittee; Council votes to endorse Three-tier data quality classification and approves use of A/B quality data items;
tasks staff to initiate process to revise EDR forms to improve data quality and reduce burden.
Council receives staff report inter-agency workgroup progress, includes draft agenda for industry workshop in February.
AFSC releases proposals for revisions to EDRs; subcommittee meetings to review data use protocols and best practices guidance to
EDR submitters for recordkeeping.
Council takes final action to approve BSAI FMP Amendment 91. In staff tasking, Council requests AFSC develop a discussion paper
for a data collection program for the pollock fleet to provide information necessary to evaluate whether the program is meeting the
Council's intent; Chair to assign Salmon Bycatch Committee members to the Socioeconomic Data Committee.
Comprehensive Data Collection Committee meeting to review Council’s Chinook bycatch motion and the data collection motion,
drafts recommendations on range of potential data collection alternatives.
Council receives discussion paper on establishing the BSAI Amendment 91 Chinook salmon EDR from AFSC and report on Data
Collection Committee recommendations; tasks staff with an analysis of a range of alternatives for the BSAI Amendment 91 Chinook
salmon EDR.
PNCIAC EDR subcommittee meets to review AFSC working drafts of revised Crab EDR forms; PNCIAC rejects proposed EDR
revisions and initiates crab sector workgroups to complete industry review of accuracy and burden by EDR variable.
PNCIAC Subcommittee Sector workgroups complete industry review of accuracy and burden by EDR variable. PNCIAC issues
report to Council on conclusion of metadata/data quality review process.
Council approves motion tasking staff to draft a discussion paper to: review objectives and structuring of data collection; address
potential to directly inform relatively immediate, specific, and routine management questions versus research questions of indirect
relevance to specific Council analyses and decisions; incorporate AFSC’s data quality review of the crab economic data reports,
PNCIAC's review, and other information from the Amendment 80 EDR and Chinook salmon bycatch data collection analysis;
discuss the effectiveness of data collection in serving analytical and research needs before the Council with the goal of assisting the
Council in developing future data collection programs, setting collection and analytical priorities, and revising the Crab Economic
Data Reports.
Council initial review of draft RIR/IRFA for BSAI Amendment 91 Chinook salmon EDR; the Council; final motion amends the
alternative set and tasks staff to return draft analysis for initial review in December.

Economic Data Reporting – Discussion Paper, April 2019

51

D5 Economic Data Reporting
APRIL 2019
A91

December-09

Crab

February-10

Crab
A91
Crab

July-10
August-10
October-10

Crab
A91

October-10
October-10

Crab
Crab

April-11
August-11

A91

February-12

Crab

February-12

A91
GOA Trawl

March-12
October-12

GOA Trawl

February-13

GOA Trawl

June-13

GOA Trawl

October-13

Council receives public review draft of A91 BSAI Salmon Bycatch Data Collection RIR/IRFA; approves motion adopting a purpose
and needs statement for the data collection, selecting a preferred alternative, and advising that implementing rule should be designed
to provide flexibility to revise EDR forms as needed, subject to Council review.
Council receives staff discussion paper on economic data collection and initiates review of crab EDR program, to be followed by a
review of the A80 EDR; approves motion requesting staff discussion paper assessing crab EDR purpose and need and evaluation of
informative value, accuracy, and collection cost by variable; motion also suspends further development of economic data collection
(i.e., Comprehensive Data Collection initiative) pending completion of review.
PSMFC/AKFIN develop and implement database audit test plan to validate database integrity.
NMFS publishes final rule implementing Amendment 91 to BSAI Groundfish FMP (75 FR 53026)
Council receives discussion paper on Crab EDR revision; adopts and amends AP motion stating purpose and need for Council action
on Crab EDR Revision and tasking discussion paper developing alternatives for EDR revision based on retaining variables identified
as “critical operational components” and options for stratification/aggregation by fishery; motion states “As analysts develop, refine,
and verify methods for accurately collecting additional informative data elements the Council will consider expansion of the data
collection program to include those elements. This process can also inform the future Council action regarding other existing and
future EDR programs.”
AFSC releases draft Crab SAFE Economic Status Report, representing first public release of statistical summaries of Crab EDR data.
Council review of draft regulations, EDR forms, draft of revised logbook forms, and PRA Supporting Statement for A91 Chinook
salmon EDR, and regulatory markup of IPA and cooperative annual report requirements and logbook revision; Council adopts the AP
motion to approve EDR forms with minor revisions.
Council receives staff discussion paper on crab EDR revision and advances alternatives for initial review.
AFSC holds Center for Independent Experts (CIE) review of BSAI Crab EDR program, to review methods and practices employed to
date and provide independent reviews and recommendations for methodological improvements and appropriate standards. Public
meeting convened at AFSC 8/23-24 (Dr. Chris Anderson/Univ. Rhode Island, Chair) included the participation of crab industry
representatives and other members of the public.
NMFS publishes final rule implementing BSAI Amendment 91 Chinook salmon EDR data collection (77 FR 5389) under CFR
679.65
Council adopts a preferred alternative for Amendment 42 to Crab FMP amending the crab EDR program; final motions recommends
implementing regulations be developed to permit flexibility to modify forms as needed, subject to Council review. Discussion in staff
tasking recommends “cooling off” of efforts to implement new economic data collection.
OMB approves PRA clearance for BSAI Amendment 91 Chinook salmon EDR
Council approves motion tasking staff to draft a discussion paper developing proposed elements and options on a baseline economic
data reporting program for Western and Central GOA trawl industries, including harvesters, processors, and catcher processors.
Council receives discussion paper on economic data collection for Central GOA Trawl fishery; approves motion to initiate analysis
of a data collection program for the CGOA and WGOA trawl sectors that would collect economic data pre-catch shares to understand
the effects of a GOA trawl catch share program on harvesters, processors, communities and catcher processors.
Council initial review of draft RIR/IRFA for GOA Trawl Data Collection; approves motion adopting modified Alternative 2 as the
PPA, and recommends release of RIR/IRFA for public review. SSC recommends that the draft document not be released for public
review at this time, pending clearer articulation of purpose and objectives for the proposed data collection action. AP recommends
that third-party EDR data collection agent be used.
Council final action on GOA Trawl Economic Data Collection; adopts preferred alternative including specified reporting
requirements for catcher vessels, catcher processors, and shoreside processors active in Central and Western GOA groundfish trawl
fisheries, revising A80 EDR form, and requiring third-party data collection agent, blind data protocol for CV and shoreside processor
data, and data verification consistent with Crab EDR audit protocols. SSC recommends that the draft document not be released for
public review.

Economic Data Reporting – Discussion Paper, April 2019

52

D5 Economic Data Reporting
APRIL 2019
A91

February-14

GOA Trawl

April-14

A80

April-14

A91
GOA
GOA/A80
Crab

June-14
December-14
December-14
June-16

Council Process
GOA
GOA
Council Process

June-16
June-16
December-16
April-18

Council receives report from AFSC on A91 Chinook Salmon EDR data collection measures, process, data quality findings and other
implementation issues to date; report notes problems in logbook checkbox implementation, no data submitted in Compensated
Transfer Report forms, and potential need for revising Vessel Master Survey questions. Council takes no action.
Council receives staff presentation from AFSC on proposed data collection procedures and draft EDR forms for GOA Trawl EDR,
and approach for implementation rule. Council approves motion recommending NMFS proceed with rulemaking, and provide PRA
clearance package and any revisions to EDR forms for Council review prior to submission to OMB.
Council receives report on early draft of Amendment 80 5-year review document from staff. SSC report on review of draft document
identifies suggestions for improvement, noting the draft includes an evaluation of quality and the accessibility of the A80 EDR data,
identifies some duplication with other data reporting, and suggesting some refinements in questionnaire to improve clarity that should
be considered in finalizing revised Trawl CP form for GOA Trawl EDR implementation.
Deadline for first annual A91 Chinook salmon EDR submission.
OMB approves PRA clearance for GOA trawl EDR (includes three-year extension with revisions for A80/Trawl CP EDR)
NMFS publishes final rule implementing GOA Trawl EDR and Annual Trawl Catcher/Processor (revised A80) EDR (79 FR 71313).
Council receives staff presentation on BSAI Crab Rationalization 10-Year Review document and Social Impact Analysis appendix;
approves motion accepting the review as complete and final, with addition of items recommended by SSC
Council approves motion to develop a proposal to establish a Social Science Planning Team
Deadline for first annual GOA Trawl EDR submission.
Council moved to postpone further work on the Gulf of Alaska Trawl Bycatch Management action indefinitely
Staff Tasking: The Council requests that NMFS prepare a discussion paper that describes the Economic Data Report requirements for
all programs, explains how the data are used, and provides estimates of the costs of complying with the EDR requirements. The
Council can then use the information in the discussion paper to determine if revisions to EDR requirements are needed and the
priority and process for analysis of proposed revisions.

Sources: Council minutes available at https://www.npfmc.org/meeting-minutes/, PRA Clearance search available at
https://www.reginfo.gov/public/do/PRASearch

Economic Data Reporting – Discussion Paper, April 2019

53

D5 Economic Data Reporting
APRIL 2019
The detailed history of the various economic data collection initiatives shown in Table 4 is documented in
the RIR/IRFA sections31, including workgroup reports, descriptions of alternatives, and the factors
considered in evaluating alternatives in the analyses. For the purpose of this discussion paper, a synthesis
of this history is more appropriate than a detailed recounting.
With passage of the American Fisheries Act in 1998, following on from the introduction of the
Halibut/Sablefish IFQ program in 1995, both the Council and agencies were confronted by limitations in
their ability to assess the complex social and economic dynamics involved in transitioning to rationalized
management. A critical and pervasive analytical limitation was the lack of economic data collections
consistently collecting social and economic data beyond gross revenue values from commercial fishing
industry participants. The Council formed the Social and Economic Committee in 1998 to work with
members of the AFA pollock sectors to develop an agreement from industry to voluntarily report firmlevel cost data. Concurrently and in coordination with that effort, AFSC economists worked with pollock
industry economists and financial analysts to develop detailed cost, earnings and employment surveys for
the CV, CP, Floating processor, and Shoreside sectors. Survey instruments and other materials jointly
developed by AFSC and pollock industry economists for the survey project are available on PSMFC’s
website.32 A visual comparison of the pollock surveys developed in that project with the original crab
EDR forms, the pollock CP33 survey, and the current A80 survey reveals obvious evidence of parentage.
It is also notable that the data verification process envisioned - for voluntary surveys - employed thirdparty CPA audit review of supporting records, and that this element of the project was included at the
request of pollock industry representatives to ensure that “information collected is consistent across firms
and industry sectors.” Following more than two years of industry consultation and development, AFSC,
working with PSMFC, fielded the pollock cost/earnings surveys in early 2000, receiving only one
completed response. Although the pollock survey project was unsuccessful as a voluntary survey, it laid
the groundwork for both the Crab and A80 EDRs, although ultimately to different effect, and several of
the questionnaire and survey design and implementation elements of that project are reflected in the
framework of the current EDR program as summarized in Section 4.2.2 above.
With the failure of both AFSC’s pollock survey project and the Council’s Social and Economic
Committee, which was discontinued after 2000, an interagency effort to develop mandatory economic
data reporting for FMP fisheries was initiated in 2001. The course of development of the original Crab
EDR beginning in 2002 followed from the work undertaken by the interagency working group, and to a
large extent followed the model established by the pollock survey project, though in the context of
31

Crab EDR: a) An extract of EIS (NMFS, 2004a) and RIR/IRFA (NMFS, 2004b) sections addressing the economic
data collection element of the Crab Rationalization program, with Appendix 1.3-6 (missing from the RIR/IRFA) are
available from AFSC at https://www.afsc.noaa.gov/REFM/Socioeconomics/PDFs/EIS_EDRsections.pdf.
b) The RIR/IRFA for Amendment 42 to the Crab FMP (NMFS, 2013) describes the analysis of alternatives for
restructuring the Crab EDR and rationale for the preferred alternative that specified the current crab EDR forms. The
summary of the CIE review of the Crab EDR program is a notable representation of the competing visions of
economic data collection that have contended throughout the series of initiatives referenced in Table 4 above.
https://alaskafisheries.noaa.gov/sites/default/files/analyses/amd42ririrfa0213.pdf.
A80 EDR: The Amendment 80 EA/RIR/IRFA (NPFMC, 2007), Section1.11.13.16 (available at
https://alaskafisheries.noaa.gov/sites/default/files/analyses/earirfrfa0907.pdf) contains the analysis of alternatives for
the A80 EDR, including the justification and statistical methods incorporated into the PRA Statement - Part B
prepared for OMB review.
A91 EDR: Draft RIR/IRFA for a Proposed Chinook Salmon Bycatch Data Collection Program (NPFMC, 2014),
available at https://www.npfmc.org/wp-content/PDFdocuments/bycatch/ChinookDataCollection1209.pdf.
GOA Trawl EDR: RIR/IRFA(NMFS, 2014b) available at
https://www.regulations.gov/contentStreamer?documentId=NOAA-NMFS-2014-0035-0010&contentType=pdf.
32
PSMFC Fisheries Economics Data Program Surveys webpage http://www.psmfc.org/efin/surveys/survey.html.
33
http://www.psmfc.org/efin/surveys/ak_surv_cp.pdf.

Economic Data Reporting – Discussion Paper, April 2019

54

D5 Economic Data Reporting
APRIL 2019
mandatory reporting. The process is well documented in the RIR/IRFA produced for the CR Program
(NMFS, 2004; in particular, Appendix 306 to the RIR/IRFA).
The draft Crab EDR forms developed by the Council-appointed data collection committee were
adaptations of the pollock survey instruments, and were intended to support the production of the same
set of standard economic and financial performance metrics that pollock industry and AFSC economists
had spent two years developing. As such, the committee retained an equivalent scope of variables in the
Crab EDRs, but increased the level of disaggregation. That is, whereas the pollock surveys directed
respondents to report the annual total value for each variable, followed by more detailed breakouts by
fishery, the crab EDRs required submitters to report by-fishery values for all variables, but not annual
values. Further, in order to address community effects of rationalization, the crab forms added
disaggregation by location of purchase for most of the cost variables. The decision was also made that the
EDRs would be limited as much as possible to collecting data about crab fishery activity only. Therefore,
the EDR design that the Council selected as the preferred alternative specified that variable costs were
only reported for crab fisheries, and fixed costs would only be reported for expenditures that affected
variable cost expenditures in crab fisheries. The result of the additional layers of stratification resulted in
surveys of daunting complexity. Industry representatives on the data committee were nonetheless
confident that they could be completed, and pretesting of the forms with a small number of volunteer
vessel owners and accountants was appeared to be reasonably successful at the time, but did not fully
replicate the breadth of challenges for the actual submission process.
The design of the A80 EDR also started by adapting the pollock CP survey and relied on the same
conceptual framework of measures and metrics. The Council’s purpose and need for the A80 EDR was
more narrowly focused on assessing economic performance within the A80 sector, and in particular, the
effectiveness of efficiency gains achieved by the program in providing more flexibility to avoid bycatch.
As such, rather than increasing the complexity of the pollock survey by adding additional stratification,
the A80 survey simplified the original by eliminating by-fishery disaggregation and limited required
reporting to annual aggregate values for most variables. As a result, 1) the reporting burden and cost are
much lower; 2) the accuracy of the data reported is sufficient for use in most applications; and 3) the
analytical framework originally conceived in the design of the EDR has been effectively applied in the
A80 5-Year review and is used as the basis for annual updates of the A80 chapter of the Groundfish
Economic SAFE. In simplifying the A80 EDR from the more disaggregated detail used in the pollock
survey, significant data quality may have been sacrificed. That is, the aggregate level of the data may not
capture the additional degree of statistical variation that would be needed to test a model using EDR data
alone. The A80 sector is, by some measures, increasingly homogeneous, and further statistical
investigation of changes within the sector in response to ongoing management may prove limited by the
aggregate level of the data. This has not proven to be a critical limitation for the Council’s purpose thus
far, and may be irreducible with the small number of operators in this fishery.
The outcome of the original Crab EDR was markedly different. The two-step approach used in the
pollock survey, reporting annual aggregate values in the first step, followed by disaggregating fisherylevel values in the second step, might have prevented some of the ensuing problems. This would likely
have been straightforward and unchallenged on the basis of accuracy or burden. The complexity of the
crab EDRs, however, resulted in excessive submitter burden and heightened industry doubts about the
quality of the data. In addition, the optics of verification audits and certification statements threatening
prosecution of perjury caused anxiety and misapprehensions about the precision that respondents were
expected to meet in EDR data. If the EDRs had retained annual aggregate values, these could have been
readily reported by respondents, verified by auditors if needed, and fishery-level breakouts would likely
have been interpreted as “to the best of your ability.” Alternately, if disaggregated reporting had actually
proved intractable, a ready solution would have been to retain annual-level reporting and to assess
alternatives for revising the stratification design of the forms. Annual-level data would also have been
made available to Council staff much sooner and synthesized into information of utility to the Council
Economic Data Reporting – Discussion Paper, April 2019

55

D5 Economic Data Reporting
APRIL 2019
much sooner, with a clearer path to rebalancing the burden and data quality in revising the EDR design.
This retrospective analysis of the Crab and A80 EDR designs is informed by hindsight. At the time, Crab
EDRs were being designed in a collaborative effort with industry, but in the midst of developing the rest
of the rationalization program. The Council’s purpose and needs statement for the Crab EDR identified
multiple analytical objectives, and the EDRs were designed in an effort to accomplish all of them. Given
the commitment under statute of limited timeline for implementation, the pretest of the survey
instruments with a small panel of crab vessel owners and processing sector accountants was incomplete
and not adequately representative of the heterogeneous populations of submitters, or the actual business
processes that would be involved in completing the surveys.34
In retrospect, AFSC and PSMFC were unprepared to respond to the Council’s expectations in providing
timely results from the crab EDR, both in response to the Council’s inquiries regarding data quality, and
in producing and facilitating useful analyses from the data. Apart from the burden of completing the
original EDRs for submitters, the complexity of the data collected overwhelmed administrative resources
needed to manage the data efficiently. The highly stratified nature of the data required the use of a
relational database and qualified database programmers. As noted in the timeline above, it wasn’t until
March of 2008 that Crab EDR data were transferred to the AKFIN Oracle server and became reasonably
accessible to analysts, and database administration continued to present significant challenges until July
of 2011.
The complexity of the challenges in implementing the Crab EDR program were underestimated and many
were unanticipated. AFSC’s attempt to retroactively implement data QA/QC best practices without
sufficient experience and resources, contributed to counterproductive communication with industry and
the Council. The development and presentation of the Crab EDR metadata document to the Council at the
March, 2008 meeting did not provide sufficient basis for determining how to proceed toward release of
EDR data for use by analysts, and posed the Council with the technical problem of synthesizing metadata
into a practical index of data quality.
This was resolved by approval of a motion initiating a metadata review process recommended by
PNCIAC35, specifying a series of public meetings for staff to present EDR metadata, receive comments
and recommendations provided by PNCIAC and the public and then to be incorporated “as appropriate”
into a revised draft metadata document, and final comments and recommendations resulting from the
review to be provided to the Council by PNCIAC. The result of that process was the introduction of an
A/B/C data quality grade, summarizing the comments and recommendations AFSC received from
PNCIAC and crab industry members as a summary indicator of data quality in the EDR metadata.
PNCIAC presented its report to the Council at the October, 2009 meeting, and the Council initiated a staff
discussion paper “reviewing the potential objectives for economic data collection and the structuring of
data collection initiatives to achieve those objectives”, specifically addressing:
(1) Relatively immediate, specific, and routine management questions and
(2) Less defined research initiatives that may have more indirect relevance to specific Council
analyses and decisions.
The Council took final action at the December, 2009 meeting on its preferred alternative for the A91
Chinook salmon EDR. As described above, in its purpose and need and selection of preferred alternative,
the Council pursued a narrow data collection and analytical objective focused on assessing the
34

Snijkers, et al. (2013) provides a detailed treatment and guidelines for implementing survey design and testing of
complex surveys of business enterprises. The burden-hour estimates that Crab EDR submitters reported to NMFS
and PSMFC during the initial years of the data collection exceeded 40 hours, and were evidence of a more complex
response process than indicated in the pretests performed in finalizing the Crab EDR forms.
35
NPFMC April 2008 Motion, C-2(b)BSAI Crab Rationalization Program: Economic Data Reporting
Economic Data Reporting – Discussion Paper, April 2019

56

D5 Economic Data Reporting
APRIL 2019
effectiveness of specific bycatch avoidance incentives measures under Amendment 91. The preferred
alternative limited cost data collection to two items relevant to bycatch avoidance choice behavior (fuel
and Chinook salmon PSC). The alternatives considered for analysis did not include additional data
collection items and analytical methods recommended by AFSC to more fully capture the direct and
opportunity costs of bycatch avoidance and other factors forming the economic context of bycatch
avoidance choices.
The discussion paper reviewing economic data collection objectives and associated data needs was
presented at the February, 2010 meeting. The paper covered some of the same history discussed here and
offers additional insights on the process. The paper made several recommendations, three of which appear
to have been influential in subsequent Council actions: data collections should be 1) implemented
independent of major management actions; 2) limited to data that inform management decisions, are not
duplicative, and can be accurately and cost effectively collected; and 3) should be developed deliberately
and incrementally. The Council tasked staff to begin an analysis of the Crab EDR, assessing the purpose
and need and evaluating the accuracy, cost, and information value of data elements in the Crab EDR
forms, and suspending further action on new data collection pending resolution of challenges with the
Crab and A80 EDRs.
In the process of developing Amendment 42 to revise the Crab EDR, the Council defined its purpose and
need as follows:
“...Council review of the EDR program, development of the EDR metadata through
PNCIAC and testimony from the industry has resulted in the identification of substantial
portions of the EDR data that are inaccurate. In addition, several elements are wholly or
partially redundant with other existing data collection requirements, and some
components may not further the Council's objectives. The cost to industry, both directly
through data submission, and indirectly through cost recovery funding of program
administration, outweigh the benefits of the resultant data and greatly exceed estimates
provided in the initial analysis of the EDR program and in the accompanying regulatory
analyses.
To address these problems, the Council intends to amend the EDR process so that the
data collected is accurate, informative to the Council, not redundant with existing
reporting requirements, and can be reported by industry and administered at a
reasonable cost.
The Council expressly wants to limit the EDR to the collection of data that have been
demonstrated, through the development of the EDR metadata, and other reviews of the
data, to be sufficiently accurate. Data collection should be structured and specific
elements identified, to minimize costs while maintaining accuracy and providing the
greatest information value to the management decision making process.
As analysts develop, refine, and verify methods for accurately collecting additional
informative data elements the Council will consider expansion of the data collection
program to include those elements. This process can also inform the future Council
action regarding other existing and future EDR programs.
The Council requests staff to prepare a discussion paper developing the following
alternatives for Council consideration:
1) critical operational components by individual crab fishery,
2) critical operational components from all crab fisheries (aggregated across all crab
fisheries), 3) critical operational components from all fisheries (aggregated across all
fisheries), and

Economic Data Reporting – Discussion Paper, April 2019

57

D5 Economic Data Reporting
APRIL 2019
4) all operational components by individual crab fishery (similar to current data
collection program).”
It is unclear to what degree this purpose and need modified or superseded what had previously been
conveyed as the fundamental purpose of economic data collection in the purpose and need statements and
analyses for the Council’s previous action. Previously, the purpose of economic data collection had been
described in analyses as collecting data to permit economic analysis, using specific metrics recognized by
economists and policy makers as indicators of economic performance. The analysis of alternatives for the
Council’s action addresses their potential to address the Councils original intent:
“In its original consideration of this action, the Council suggested the data collected by
the program should be used to support several types of economic and social analyses
(such as estimates of profits, quasi rents, and the distribution of revenues from the
fisheries). The Council’s purpose and need for this action suggests that the data collection
program may not be providing the benefit anticipated due to data inaccuracies. Implicit in
that statement is the suggestion that the data may not support the anticipated analyses.
The following table (see Table 1) is a brief summary of analyses identified by in the
analysis of the Council’s initial action and an assessment of the potential for the various
alternatives considered here to support those analyses. In general, none of the data
collection alternatives under consideration (including the status quo) provide adequate
data to support most of the economic measures of concern to the Council in the initial
analysis.” (NMFS, 2013, pp.82)
As is clear from review of the analysis, no alternatives were considered that simplified the disaggregated
reporting requirements identified as the principal cause of reporting errors in metadata reviewed by
PNCIAC and in the CIE review of the Crab EDR program (CIE, 2011). In stating a purpose and need
limiting EDRs to collecting data that are accurate and informative in themselves, the Council did not
identify a revised analytical purpose other than that conveyed by the “critical operational component”
criteria.
Relatively soon after the Council adopted their preferred alternative for Amendment 42 amending the
crab EDR program, the Council approved a motion tasking a discussion paper developing proposed
elements and options on a baseline economic data reporting program for Western and Central GOA trawl
industries, including harvesters, processors, and catcher processors in October, 2012. The Council
received a discussion paper on economic data collection for Central GOA Trawl fishery in February 2013
and approves motion to initiate analysis of a data collection program for the CGOA and WGOA trawl
sectors that would collect economic data pre-catch shares to understand the effects of a GOA trawl catch
share program on harvesters, processors, communities and catcher processors. By June 2013, the Council
reviewed the draft RIR/IRFA for GOA Trawl Data Collection and approves motion adopting modified
Alternative 2 as the preliminary preferred alternative (PPA). On final review in October, the Council
adopted the preferred alternative including specified reporting requirements for catcher vessels, catcher
processors, and shoreside processors active in Central and Western GOA groundfish trawl fisheries,
revising the A80 EDR form, and requiring a third-party data collection agent and blind data protocol for
CV and shoreside processor data, and data verification consistent with Crab EDR audit protocols. OMB
approved the PRA clearance for the GOA trawl EDR in December 2014, with a June 2016 deadline for
the first year’s EDR submission. The Council postponed further action on GOA Trawl Bycatch
Management in its December 2016 meeting, but the GOA Trawl EDR reporting requirements remain
unchanged.

Economic Data Reporting – Discussion Paper, April 2019

58

D5 Economic Data Reporting
APRIL 2019

5

EDR Program Operations, Costs, and Limitations

5.1

Summary of EDR program operations

5.1.1

Data collection to-date

5.1.1.1

Summary of EDR forms submitted and reporting compliance

Table 5 summarizes the number of EDR forms submitted for each reporting year, beginning with
historical Crab EDR forms that were submitted to PSMFC in 2005. The table reports submission of
completed and certified EDR data forms. Certification-only EDR submissions are not shown.36
Compliance with EDR submission requirements is effectively 100%. Gross non-compliance with EDR
submission requirements has been limited to a small number of cases that involved bankruptcy and/or
more extensive violations of federal fishery regulations. Late EDR submissions are handled by PSMFC
on case-by-case grant of deadline extensions up to two-weeks. Since 2005, 40 EDR submissions have
been referred to NMFS OLE due to multiple missed deadline extensions or failure to provide timely
response to audit requests. Other than one formal written warning from OLE in 2007, late EDR and audit
materials have submitted following a phone contact from OLE.
Timely compliance with EDR submission and audit requests have been somewhat more problematic in
the GOA CV sector, but not excessive for a new reporting requirement, and submitters have generally
cooperated with PSMFC in good-faith to complete EDR submissions and audit requirements. Currently, 9
2017 Annual GOA Trawl CV EDRs remaining outstanding from 2018, however 7 of these appear to be
incidental catch amounts and only two appear to have significant landings of Central and Western GOA
groundfish. Referral to OLE will be considered depending on compliance in the ongoing 2018 EDR
collection.

36

As described in Section 4.2, certification-only submissions occur in cases where entities are subject to the EDR
submission as a permit holder or owner of a vessel or processing plant under the applicable subsection of 50 CFR
679 or 680, but did not operate in the fishery or management program that an EDR form pertains to and is exempted
from completing the data portion of the form. Certification-only Crab EDR submissions prior to 2005 were nearly
equivalent to the number of completed data forms, and remained as high as 25% of the number of completed data
forms through 2011. To avoid needless paperwork burden of certification-only EDRs, in 2012 PSMFC/AKFIN
improved methods for minimizing the number of certification-only submissions by avoiding distribution of EDR
notices to entities that can be confirmed by administrative records (e.g., catch accounting) as exempt from EDR data
submission requirements.
Economic Data Reporting – Discussion Paper, April 2019

59

D5 Economic Data Reporting
APRIL 2019
Table 5

Counts of Completed EDR Data Forms by EDR Reporting Year
CRAB EDR

EDR
Reporting
Year

CV

CP

Processors

A80/GOA TRAWL EDR

A91 CHINOOK SALMON EDR

A80/GOA
CP

CTR

CV

GOA
SP

Fuel
Survey

Vessel
Master
Survey

1998

218

8

25

All EDR Forms
251

2001

218

7

23

248

2004
Total
1998-2004
2005

237

10

20

267

673

25

68

766

166

8

17

191

2006

96

5

13

114

2007

82

5

14

101

2008

91

5

15

24

135

2009

84

5

18

23

130

2010

76

3

18

24

121

2011

74

3

19

24

120

2012

80

3

20

20

2013

79

2

24

2014
2015
2016
2017
Total
To-date

5.1.1.2

74
80
80

2
2
2

19
19
18

86

135

344

18

0
0

86

133

342

18

0

75

126

314

19

12

0

64

121

386

6

0

65

117

376

61

116

366

437

748

3806

18

69
70

70

2

18

20

66

13

0

1805

72

300

208

205

31

0

Data verification/audit administration

EDR data verification is required under EDR rules in 50 CFR 679 and 680. The rules state that “the DCA
shall...” (680.6), or “NMFS, the DCA, or the DDCA will…” (679 subsections 65, 94, and 110) “conduct
verification of information with [a person required to submit the applicable EDR or a designated
representative]”. In the subsections that follow this shall direction to the DCA, the rules require the EDR
submitter to respond to inquiries from the DCA within 20 days, require the submitter to provide
supporting records to the DCA as requested, and authorize the DCA auditor to review the records for the
purpose of substantiating values reported in the EDR.37 The Council’s intent for the verification process,
and of the third-party audit in that process, is not explicitly stated in the rule, and authorizes rather than
directs that data verification is accomplished by auditor review of supporting records. In developing the
data verification and audit procedures for PSMFC, AFSC has relied on the Council’s record of decision
for guidance regarding intent. The Crab Rationalization Program RIR/IRFA (NMFS, 2004b) provides this
background, and has been re-used in subsequent analyses for the other EDRs:
“Anticipated Enforcement of the Data Collection Program
Under 680.2, “Auditor means an examiner employed by, or under contract to, the data collection agent to verify
data submitted in an economic data report.” There is some inconsistency between the 679 and 680 rules pertaining to
NMFS’ access to supporting records and roles of NMFS, the DCA, and the third-party auditor (DDCA) in
verification audits; 680.6(f) states the clearest differentiation between the role of the DCA versus the DDCA, and
PSMFC’s audit procedures have been developed by AFSC based on the 680.6 specification.
37

Economic Data Reporting – Discussion Paper, April 2019

60

D5 Economic Data Reporting
APRIL 2019
The analysts anticipate that enforcement of the data collection program will be different
from enforcement programs used to ensure that accurate landings are reported. It is
critical that landings data are reported in an accurate and timely manner, especially
under an IFQ system, to properly monitor catch and remaining quota.
However, because it is unlikely that the economic data will be used for in-season
management, it is anticipated that persons submitting the data will have an opportunity
to correct omissions and errors before any enforcement action would be taken. Giving
the person submitting data a chance to correct problems is considered important because
of the complexities associated with generating these data. Only if the agency and the
person submitting the data cannot reach a solution would the enforcement agency be
contacted. The intent of this program is to ensure that accurate data are collected
without being overly burdensome on industry for unintended errors.
A discussion of four scenarios will be presented to reflect the analysts understanding of
how the enforcement program would function. The four scenarios are: 1) a case where
no information is provided on a survey; 2) a case where partial information is provided;
3) a case where the agency has questions regarding the accuracy of the data that has
been submitted; and 4) a case where a random “audit” to verify the data does not agree
with data submitted in the survey.
In the first case, the person required to fill out the survey does not do so. In the second
case, the person fills out some of the requested information, but the survey is incomplete.
Under either case that person would be contacted by the agency collecting the data and
asked to fulfill their obligation to provide the required information. If the problem is
resolved and the requested data are provided, no other action would be taken. If that
person does not comply with the request, the collecting agency would notify enforcement
that the person is not complying with the requirement to provide the data. Enforcement
would then use their discretion regarding the best method to achieve compliance. Those
methods would likely include fines or loss of quota and could include criminal
prosecution.
In the third case the person fills out all of the requested information, but the agency
collecting the data, or the analysts using the data, have questions regarding some of the
information provided. For example, this may occur when information provided by one
company is much different than that provided by similar companies. These data would
only be called into question when obvious differences are encountered. Should these
cases arise, the agency collecting the data would request that the person providing the
data double check the information. Any reporting errors could be corrected at that time.
If the person submitting the data indicates that the data are accurate and the agency still
has questions regarding the data, that firm’s data could be “audited”. It is anticipated
that the review of data would be conducted by an accounting firm selected jointly by the
agency and members of industry. Only when that firm refuses to comply with the
collecting agencies attempts to verify the accuracy of the data would enforcement be
contacted. Once contacted, enforcement would once again use their discretion on how to
achieve compliance.
The fourth case would result when the “audit” reports different information than the
survey. The “audit” procedure being contemplated is a verification protocol similar to
that which was envisioned for use in the pollock data collection program developed by
NMFS and Pacific States Marine Fisheries Commission (PSMFC). During the design of
this process, input from certified public accountants was solicited in order to develop a
verification process that is less costly and cumbersome than a typical “audit” procedure.
That protocol involves using an accounting firm, agreed upon by the agency and
industry, to conduct a random review of certain elements of the data provided.”
Economic Data Reporting – Discussion Paper, April 2019

61

D5 Economic Data Reporting
APRIL 2019
“Since some of the information requested in the surveys may not be maintained by
companies and must be calculated, it is possible that differences between the “audited”
data from financial statements and survey data may arise. In that case the person filling
out the survey would be asked to show how their numbers were derived (footnote 41). If
their explanation resolves the problem, there would be no further action needed. If
questions remained, the agency would continue to work with the providers of the data.
Only when an impasse is reached would enforcement be called upon to resolve the issue.
It is hoped that this system would help to prevent abuse of the verification and
enforcement authority.
In summary, members of the crab industry will be contacted and given the opportunity to
explain and/or correct any problems with the data, that are not willful and intentional
attempts to mislead, before enforcement actions are taken. Agency staff does not view
enforcement of this program as they would a quota monitoring program. Because these
data are not being collected in “real” time, there is the opportunity to resolve occasional
problems as part of the data collection system. Development of a program that collects
the best information possible to conduct analyses of the crab rationalization program,
minimizes the burden on industry, and minimizes the need for enforcement actions are the
goals of the data collection initiative.”
[…]
“Verification of data including auditing and error checking
The mandatory data collection program provides that verification of data, auditing, and
error checking would be the primary responsibility of the third party agent. Consistent
with procedures set forth in the motion, the agent will be obligated to develop an
appropriate system for identifying outliers, incomplete data, or anomalies in the data
submissions. Further, the third party agent will be obligated to retain qualified
professional analysts or accountants to review data submissions and identify errors or
flag possible fraudulent submissions.”
ASFC and PSMFC began developing data verification protocols and procedures for the Crab EDR in
2005 and have continued to improve and refine the process to efficiently identify and correct data
reporting errors while reducing the cost and burden of the audit process. Prior to incorporation of EDR
data into the AKFIN relational database in 2011, EDR data validation was largely reliant on the audit
process. Automated validation routines now allow PSMFC to identify most errors and obtain corrections
from submitters shortly after EDRs are submitted. AFSC developed revised audit selection and review
protocols in 2017, which were used by PSMFC in the RFP for CPA firms to contract the audit review.
EDR data verification currently employs a series of validation procedures, including 1) primary,
automated data validation procedures programmed and maintained by AKFIN on the EDR database, 2)
secondary validation employing statistical procedures and visual inspection to identify data anomalies and
statistical outliers, and 3) editing and imputation for data errors identified by data users that were not
detected and corrected in primary and secondary validation.
Primary validation procedures involve programmed tests to identify logical errors and inconsistencies in
individual EDR records, e.g., upper and lower bounds for reported values and ratios of values, crew
missing data for one or more by-fishery EDR data fields where fishery participation is indicated in the
EDR record or in catch accounting data. Primary routines are executed by PSMFC staff on each EDR
record shortly after receiving a certified EDR submission, with follow-up contacts with submitters to
obtain corrections as needed. Most primary validation errors are identified and corrected easily with a
phone call and result in a re-certified EDR submission within 2 weeks of the submission.

Economic Data Reporting – Discussion Paper, April 2019

62

D5 Economic Data Reporting
APRIL 2019
Secondary validation begins after primary validation is completed and all EDR records are certified final
by submitters. Once EDRs are completed, AKFIN completes integration of current year EDR records
with other datasets, calculation of various pro-rata and statistical indices, and plotting for visual
inspection. AFSC and PSMFC review the results to identify and flag visual outliers and anomalies as
potential reporting errors. Flagged values are selected for correction through follow-up by PSMFC staff,
or selection to third-party verification audit.
Audit protocols specified in the Scope of Work (SOW) for PSMFC’s contract with EDR auditors require
auditors to notify EDR submitters that have been selected for audit and to request appropriate supporting
materials to enable auditors to substantiate reported values. After audit selections have been identified,
and prior to the auditor distributing notices, ASFC and PSMFC consult with the auditor to determine the
appropriate forms of supporting evidence and level of review appropriate for different types of data. For
example, quota lease data tends to be more challenging to validate and requires a higher level of review
compared to provisions costs. Once auditors have received the requested records, and/or with additional
phone contacts, the auditors identify and confirm a correct value for the data item (either the original
reported value or a corrected value). Auditors also evaluate the quality of supporting records and
information provided by the submitter, and characterize the quality of support and nature of reporting
errors using a coding system developed by AFSC and specified in the SOW.38 Audit corrections are
entered into the EDR database by PSMFC and AKFINs production version of the EDR database is
finalized after all audit results are entered.
As noted above, the data validation process and procedures have been implemented by AFSC and
PSMFC based on interpretation of the Council’s record of decision, and the third-party audit process has
been modified as the process envisioned in the Council record has been implemented through alternative
database management procedures that enable more timely and efficient error corrections at lower cost and
burden to submitters.
Two issues that have emerged from the practical experience of AFSC and PSMFC in working with CPA
firms under contract are especially worth noting: 1) in all audits reviews conducted since 2006, there has
not been a single finding of intentional misreporting, or of any bias in the direction of reporting errors
identified by auditors; and 2) verifying the quality of results produced by auditors requires considerable
effort by AFSC and PSMFC. On the latter point, contracting for the services of CPA firms to conduct
data validation audits is not straightforward, and the tasks involved are unfamiliar to CPAs and require
one or two iterations to gain experience. However, CPA firms face staff turnovers and can’t be relied
upon to maintain staffing stability for EDR contracts, and PSMFC is required to issue RFPs to renew
ongoing service every three years at minimum.
5.1.1.3

Program expenditures and cost recovery

This section describes the financial cost of implementing the EDR Program and identifies the extent of
which those costs have been recovered from the fishing industry by the National Marine Fisheries
Service. These costs are primarily borne by the AFSC and will be the main focus of this section, but the
AKRO does also provide funds for the Crab Rationalization program and will be described in context.
This section focuses on the cost recovery amounts rather than the full cost to the NMFS as in the years
prior to cost recovery being implemented in the programs, NMFS did not calculate the in-kind
contribution of staff time on EDRs until required to do so for cost recovery purposes.
The cost of running the EDR Program also includes the costs of the PSMFC and their subcontractors in
their role as DCA, providing administrative support for the data collections, software development, web
38

The SOW for the audit of 2017 Annual Crab EDR data is attached as Appendix B, and all audit reports posted on
PSMFCs webpages for the four EDR programs, which can be reached through PSMFC’s EDR Program page at:
http://www.psmfc.org/program/prog-2?pid=17.
Economic Data Reporting – Discussion Paper, April 2019

63

D5 Economic Data Reporting
APRIL 2019
services, and database administration. FTE time provided by the AFSC includes oversight of PSMFCs
work, performing additional data QA/QC, survey development and refinement, collaboration with AKRO
staff on PRA clearance and publication of authorizing regulations, and associated public outreach
(meetings, consultations and user support). AFSC also provides office space, computer equipment, and
other administrative services.
In addition to cost recovery measures implemented by AKRO concurrently with rationalization of the
crab and Central GOA rockfish fisheries and in 2000 in halibut and sablefish, new cost recovery
requirements went into effect during 2016 for AFA pollock, Amendment 80, and all CDQ fisheries. The
GOA Trawl fishery is not part of a catch share fishery and is therefore not subject to cost recovery. The
costs reported for the GOA Trawl EDR only reflect the PSMFC administrative costs and do not include
the costs of NMFS staff time, and therefore serve as a lower bound on the total cost of the GOA Trawl
EDR.
Table 6 describes the annual cost recovery amounts for the three cost recovery eligible EDR fisheries and
the PSMFC administrative costs for the GOA Trawl EDR. Note that the cost recovery amount for the
Crab EDR is listed in the first year of the crab season, but is typically received and used by NMFS and
PSMFC during the NMFS fiscal year that coincides with the second year of the crab season. The costs
have been quite variable in the Crab EDR Program, which averaged $286,013 over all years, and
fluctuates largely due to changes in the cost of audits each year as well as the costs associated with
database administration, support, and changes to the EDR forms. Costs have remained relatively stable in
the A80 EDR, averaging $90,733/year for the first three years of cost recovery (2016-2018). For the
inshore sector of the A91 EDR, the only sector from which EDR Program costs are now recovered, costs
have averaged $57,260 per year since costs have been recovered since 2016. To approximate the cost of
implementing the GOA Trawl EDR, the PSMFC administrative costs of implementing the GOA Trawl
EDR are included, but have not included any NMFS staff time as these are not routinely documented for
non-cost recoverable activities. These costs have averaged $70,159 per year over the four years of the
data collection, with costs varying largely due to changes in the need for audits.

Economic Data Reporting – Discussion Paper, April 2019

64

D5 Economic Data Reporting
APRIL 2019
Table 6

Cost Recovery and PSMFC Administrative costs of the EDR Programs

Program/
Crab1
Year
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
1
2
3

$ 150,000
$ 150,000
$ 259,938
$ 338,276
$ 314,303
$ 352,508
$ 323,588
$ 373,316
$ 318,278
$ 342,703
$ 269,583
$ 345,509
$ 180,168

A80

$
$
$

Cost
Recovery
AFA
Total
$150,000
$150,000
$259,938
$338,276
$314,303
$352,508
$323,588
$373,316
$318,278
$342,703
$269,583
88,254 $62,859 $496,622
91,482 $69,369 $341,019
92,462 $40,631
2

GOA
3

Trawl

$ 53,771
$ 73,221
$ 91,879
$ 61,765

Total
EDR Cost
$150,000
$150,000
$259,938
$338,276
$314,303
$352,508
$323,588
$373,316
$318,278
$342,703
$323,354
$569,843
$432,898

The year listed in this table reflects the first year of the crab fishing season.
Only includes costs associated with the inshore sector.
Only includes PSMFC administrative costs.

While these costs are not insignificant, they represent a small fraction of the ex-vessel value generated by
these fisheries (Table 7), with EDR-related costs averaging 0.15% of the ex-vessel value for the Crab
EDR, 0.09% for the A80 EDR, 0.04% for the A91 EDR, and 0.10% for the GOA Trawl EDR. Ex-vessel
values for the Crab EDR, A80 EDR, and A91 EDR come from the annual cost recovery reports, while the
values for GOA Trawl represent their GOA Trawl related ex-vessel revenue for all vessels required to
submit a GOA Trawl EDR and was calculated directly by AKFIN.

Economic Data Reporting – Discussion Paper, April 2019

65

D5 Economic Data Reporting
APRIL 2019
Table 7

EDR Program costs as share of fishery ex-vessel value

Program/Year

Crab1

2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017

0.11%
0.13%
0.13%
0.16%
0.21%
0.13%
0.11%
0.16%
0.15%
0.15%
0.12%
0.18%

A80

AFA2

GOA Trawl3

0.10%
0.08%

0.04%
0.04%

0.08%
0.11%
0.13%

1

The year listed in this table reflects the first year of the crab fishing season.
Only includes the inshore sector.
3
Only includes PSMFC administrative costs.
2

However, the share of total cost recoverable costs associated with the EDR Program varies by each EDR
as incremental costs associated with catch share programs vary by program as well. The Crab EDR
represents on average approximately 9% of the total direct program costs which averaged $3.4 million
from the 2005/2006 fishing season through 2016/2017. The costs are slightly higher proportionally in the
A80 EDR Program, averaging 19% of the $584,541 average annual direct program costs for 2016 and
2017. The inshore A91 EDR represents over 29% of the average annual direct program cost of the inshore
sector in the AFA program, which has averaged $252,911 over 2016 and 2017. There is no comparable
metric for comparison in the GOA Trawl fishery.
5.1.1.4

Estimated costs to industry of preparing and submitting EDRs

As noted in an earlier section, the Paperwork Reduction Act (PRA) was implemented in 1980 to reduce
the total amount of paperwork burden the Federal Government imposes on private businesses and citizens
and to establish a process through which Federal agencies must obtain approval from the Office of
Management and Budget (OMB) before collecting information from the public. Under the PRA, NMFS is
required to obtain approval for new information collection requirements implemented through Federal
regulations and for voluntary requests for information. Voluntary requests include information collected
through surveys or through other non-regulatory means, such as the Council’s requests for the submission
of specific additional information in annual cooperative reports. NMFS also must apply for and receive
approval from OMB for any revisions to existing information collection requirements that occur as a
result of a change in Federal regulations or a change in a voluntary information request. When OMB
approves an information collection, it assigns the collection an “OMB control number.” The OMB control
number, expiration date of OMB’s approval, estimated burden hours, and other information must be
displayed on all forms used to collect information.
The Alaska Region manages approximately 30 information collections ranging from collections for
logbooks, catch and landings reports, scales and weighing, vessel monitoring systems, the Observer
Program and electronic monitoring, EDRs, and each of the catch share programs. Together these 30
information collections include approximately 200 forms or components, most of which are required by
Economic Data Reporting – Discussion Paper, April 2019

66

D5 Economic Data Reporting
APRIL 2019
regulation. The Alaska Region PRA supporting statements and documentation of OMB approval are on
the NOAA PRA Submission web page (http://www.cio.noaa.gov/services_programs/prasubs.html), listed
by OMB collection number, title of the collection, and approval date.
Although the regulations implementing information collection requirements only change if revised or
repealed by a final rule published in the Federal Register, OMB’s approval for each information
collection expires every three years. Prior to the expiration date of each collection, NMFS must submit a
request to OMB for approval to continue to collect the information. Table 8 provides the OMB collection
numbers and expiration dates for the four Alaska EDR programs.
Table 8

Office of Management and Budget (OMB) Information Collections for the Alaska
Economic Data Reports.

Name of Information
Collection

OMB Information
Collection Number

Regulatory
Citation

OMB Approval
Expires

Crab EDR

0648-0518

50 CFR 680.6

7/31/2019

Amendment 80 and GOA
trawl CP EDR

0648-0564

50 CFR 679.94

12/31/2020

GOA trawl EDR (CV and
processors)

0648-0700

50 CFR 679.110

12/31/2020

BS Chinook salmon bycatch
EDR

0648-0633

50 CFR 679.65

6/30/2021

To obtain approval from OMB for a new, revised, or expiring information collection, NMFS must prepare
and submit two Federal Register notices and an application package that consists of an analysis called a
“supporting statement,” a summary form (OMB form 83-I), and copies of all forms and instructions
associated with the information collection. The supporting statement describes the information collection
requirements, explains why the information should be collected or continue to be collected, estimates the
number of respondents and the cost to respondents of submitting the information, explains whether and
how confidentiality is protected, summarizes and responds to any public comments on the information
collection, and addresses a number of other related questions. The costs that are required to be included in
a supporting statement include the costs of the time that it takes to review instructions, search existing
data sources, gather and maintain the data needed, review the information to be submitted, and submit the
information.
Prior to the expiration date of an information collection, NMFS issues two notices in the Federal Register
to solicit public comment on the information collection requirements. For example, OMB’s approval for
the crab EDR collection expires on July 31, 2019. A notice was published in the Federal Register on
March 7, 2019 (84 FR 8308) soliciting comments on renewal of approval for this information collection.
This notice requests comments on any aspect of the information collection, but specifically requests
comments on whether the information collection is necessary, whether the data collected has “practical
utility,” the accuracy of the estimated burden hours and costs, and ways to improve collection or
minimize its burden. The second Federal Register notice will be published after NMFS submits the draft
renewal package to OMB. All notices soliciting comments on information collection renewals are posted
on NMFS’s website. NMFS responds to comments received on the information collection requirements in
the supporting statement submitted to OMB.
Table 9 summarizes the estimated hours and costs to industry of preparing and submitting each form or
information collection component of the four Alaska EDRs. The table provides the estimated annual

Economic Data Reporting – Discussion Paper, April 2019

67

D5 Economic Data Reporting
APRIL 2019
number of respondents for each form or component each year, the estimated time it takes a respondent to
prepare and submit the required information, the estimated cost per hour for preparing and submitting
each response, the estimated annual cost per respondent, and the estimated annual total labor cost for all
respondents. The rows title “Total for Collection” show the estimated annual total labor cost of
submitting the required EDR information for each of the four EDR programs. For example, NMFS
estimates that it costs approximately $312,000 per year for respondents to provide the information
required for the crab EDR; approximately $19,000 per year for the Amendment 80 and GOA trawl
catcher/processor EDR, approximately $48,000 per year for the GOA trawl catcher vessel and processors
EDR, and approximately $60,000 per year for the BS Chinook salmon bycatch EDR. The total estimated
cost for all of the EDRs is $439,504. These are the cost estimates for preparing, reviewing, and submitting
the required information and are in addition to the EDR administrative costs described in Section 5.1.1.3,
some of which are recovered from the industry through cost recovery.
Table 9

Estimated Number of Respondents and Costs to Prepare and Submit Alaska Economic Data
Reports.

Name of EDR
Program or
Submission

Number of
respondents
per year

Hours per
response

Estimated Cost Per Submission
and in Total
Cost per
Total labor
Cost per
hour for
costs of
respondent
respondent
submission

Crab EDR
70 – full EDR
20
$1651/
$3,300
Catcher vessels
2/
1 – cert. only
1
$165
$165
Catcher/processors
2 – full EDR
20
$165
$3,300
18 – full EDR
16
$165
$2,640
Processors
4 – cert. only
1
$165
$165
16 CVs
Verification/audit
0 CPs
8
$165
$1,320
4 processors
Total for Collection
95
Amendment 80 and GOA Trawl Catcher/Processors
21 – full EDR
22
$373/
$814
Annual EDR
6 – cert. only
1
$37
$37
Verification/audit
8
5
$37
$185
Total for Collection
27
Gulf of Alaska Trawl EDR for Trawl Catcher Vessels
and Shoreside Processors Taking Deliveries from Trawl CVs
67 – full EDR
15
$37
$555
Catcher vessels
34 – cert. only
1
$37
$37
Processors
13 – full EDR
15
$37
$555
10 CVs
4
$37
$148
Verification/audit
5 processors
5
$37
$185
Total for Collection
114
BS Chinook Salmon EDR
0 – transfer rpt
40
$754/
$3,000
Annual Compensated
96 – cert. only
1
$75
$75
Transfer Report
0–
4
$75
$300
verification/audit
Vessel Fuel Survey
61
4
$75
$300
Vessel Master
116
4
$75
$300
Survey
Total for Collection
TOTAL for all EDRs

Economic Data Reporting – Discussion Paper, April 2019

$231,000
$165
$6,600
$47,520
$660
$21,120
$0
$5,280
$312,345
$17,094
$222
$1,480
$18,796

$37,185
$1,258
$7,215
$1,480
$925
$48,063
$0
$7,200
$0
$18,300
$34,800
$60,300
$439,504

68

D5 Economic Data Reporting
APRIL 2019
1/ Estimated

cost per hour of an accountant hired to prepare the crab EDRs and information requested for the
verification process.
2/ Respondent submitted only the certification page indicating that they were not required to complete the full EDR
that year.
3/ Standard baseline assumption of cost per hour for most of the Alaska Region’s information collection components.
4/ Cost per hour estimate from the original supporting statement for the BS Chinook Salmon EDR final rule, assuming
a higher average cost per hour for submissions made by vessel owner or operators.

The estimates of time burden and cost per hour in Table 9 represent the estimates used in the most recent
PRA supporting statements or updates generated since then through ongoing operation of the program.
NMFS solicits comments on these burden hour estimates and cost estimates in the proposed rule for the
information collection requirement and again in each 3-year renewal. If specific comments are received
on the burden hour or cost estimates, NMFS generally adjusts the estimates in the specific collection.
Table 9 shows a fairly wide range of hourly cost estimates among the EDR programs. The $37 per hour
estimate is an average hourly cost estimate used for forms and components in most of NMFS’
information collections. This estimate is based on the assumption that information is being submitted by
operators of small vessels or administrative or management staff in processing plants or fishing
companies, and the closest average compensation for Federal Government employees of comparable
responsibility and compensation. This estimate has not been systematically validated through surveys and
has not been updated in several years. The estimates of $165 per hour for the crab EDR and $75 per hour
for the A91 EDR are based on comments received on past EDR renewals that explained of the type of
expertise needed to complete these particular EDRs and provided the associated costs per hour for people
with this expertise. As stated earlier, NMFS presents its burden hour and hourly cost estimates for public
comment and generally updates and revises them if it receives information that supports doing so.
NMFS is considering conducting a more comprehensive review of the burden hours and costs per hour for
all of its Alaska Region information collections; however, this project likely would require a survey of
industry and competes for time and resources with the Sustainable Fisheries Division’s other
management, analytical, and operational responsibilities and has, to date, not been undertaken. NMFS
welcomes the Council’s and industry’s input on the need and priority for improving estimates of the costs
of information collection requirements.
NMFS sometimes identifies that a component of an information collection required by regulation is no
longer necessary, through either staff analysis of the information collection or as a result of a comment
received from the industry on the collection. When this occurs as a result of a comment, NMFS responds
accordingly in the supporting statement. If NMFS agrees with the comment, NMFS follows up by
recommending a regulatory amendment to revise or remove the requirement, and, if the Council agrees,
by proceeding with that regulatory amendment. Two recent examples of proposals to remove information
collection requirements that were identified through the PRA renewal process are the BS pollock inshore
cooperative weekly catch report and the VMS registration fax/form. If NMFS does not agree with a
comment that an information collection or component of a collection is not necessary, NMFS responds in
the supporting statement by restating the original justification for the information collection requirement
from the rulemaking that implemented the requirement, with additional explanation and justification, as
appropriate. Generally, OMB accepts NMFS’s explanation and rationale for the continued need for the
information collection or component, although they may ask follow-up questions or require additional
justification.
5.2

Limitations of EDR data

Limitations of the EDR Program span a range of issues, and include limitations on the quality and utility
of the data collected in the current respective EDR forms that arise from the conceptual design of the data
collections, to challenges in making the data that has been collected more readily accessible to analysts,

Economic Data Reporting – Discussion Paper, April 2019

69

D5 Economic Data Reporting
APRIL 2019
more salient to the analytical applications intended by the Council, and more informative to the public. A
legitimate concern of the Council, as well as to industry and to EDR Program staff, is the relatively
limited use and utility EDR data have demonstrated, relative to Council expectations regarding frequent
and informative applications of the data. Given the expenditure of administrative and industry cost and
reporting burden incurred, the quality and utility of some portions of the EDR data collections are in need
of further consideration. The following provides a discussion of data quality limitations of data currently
collected in EDR forms, followed by a broader discussion of limitations associated with the overall
design of data collection in the EDR Program as a whole.
5.2.1
5.2.1.1

Data quality limitations in current EDR data collection
Crab EDR

Crab CV EDR: Crab IFQ cost reporting in CV and CP forms shows indications that multi-vessel owners
may pool quota costs across vessels, in some cases for the purpose of balancing crew share earnings to
account for vessels incurring higher quota and/or fuel costs associated with northern deliveries. This
conflicts with the EDR form instructions, and complicates validation of reported quota values. This may
be a case in which collecting annual-level quota lease costs at the vessel-level, by CR fishery and quota
type sufficiently diminishes data quality, in that vessel-level annual lease cost values are pooled over all
distinct lease arrangements at the vessel level; collecting quota transaction data from QS owners could
improve the calculation of reliable quota market activity statistics, including lease rates.
Crab Processor EDR: Processing labor data collection in the EDR form currently collects hours and labor
cost by CR fishery, which misses overtime hours as an important determinant of hourly earnings and total
wage rates, and is a relevant indicator of labor productivity. Also, crab processing labor is collected by
CR fishery, compared to GOA Trawl processors, where it is collected by month and housing status. The
reasons for inconsistency are unclear, but utility of the data would increase if collected consistently across
fisheries.
5.2.1.2

Amendment 80 EDR

The A80 EDR provides a comprehensive set of cost and earnings data that supports the Council’s
objectives for the data collection without excessive reporting burden. Some variables, including vessel
activity days and processing line throughput capacity are somewhat duplicative and may not be the best
source of data for their purposes. The collection of capital expenditure data in the EDR form aggregates
major, unique investment events (vessel purchase acquisitions and/or retrofits) which should be
differentiated from ordinary capital improvement cycle expenditures. This can be resolved by consulting
with the submitter, but as a general matter, improved methods for collecting capital investment data that
are large and infrequent could be explored.
5.2.1.3

Amendment 91 EDR

AFSC has reported to the Council on the implementation of the Amendment 91 EDR previously. The
concerns with the 91 EDR are:
Administration: The A91 EDR is more complicated to administer than other EDRs and yields minimal
data for the expense and burden. The fuel survey component was designed to complement logbook data
measurement identifying salmon avoidance movements of vessels, which have not been effectively
implemented, and given conversations with vessel operators, do not adequately quantify vessels’ salmon
avoidance travel costs. It was designed for a narrow set of analytical applications, rather than to yield
general purpose economic data. As a result, EDR data was not used in the AFA program review. The A91
EDR as a whole could produce data of much greater utility for the same or less cost and burden if revised.
A91 Vessel Master Survey: Well-considered, detailed answers are reported in the survey and are
informative, but an increasing proportion of answers are pro-forma (verbatim duplicates of other
responses) and are not likely to provide much utility as an ongoing information collection. The qualitative
Economic Data Reporting – Discussion Paper, April 2019

70

D5 Economic Data Reporting
APRIL 2019
response data requires time-consuming coding in order to analyze quantitatively, but results of formal
analysis are impaired by data quality. Changes in the timing and implementation of the survey, including
fielding the survey in-season or immediately post-season, direct reporting by skippers to NMFS, and
revising the survey content, could improve the data quality. These changes may increase cost and burden,
however, and would be difficult to implement within the current structure of the A91 EDR.
Compensated Transfer Report (CTR): A compensated transfer is defined in the CTR form as one in which
Chinook salmon PSC is transferred between entities in exchange for monetary compensation, with or
without the exchange of any other assets (pollock quota) included in the exchange. The CTR form
requires that such a transfer be reported, identifying the quantity of PSC, the monetary amount
exchanged, and a Y/N question indicating whether other assets were exchanged. The purpose of the latter
is to ensure that any bundled transfer pollock quota and PSC reported in the CTR does not identify the
quantity of pollock quota and reveal a per-unit price. However, the Council may wish to reconsider the
rationale for this approach as tracking quota lease prices in the AFA pollock fishery would provide an
informative statistic of the expected short-term profitability in the fishery (Holland et al. 2015), and may
be of interest to the Council to monitor as they consider broader changes to the EDR program or assess
the impact on the fishery if Chinook avoidance costs increase. As such, the design of the CTR form limits
the quality of the data. The CTR form has never been completed by a submitter, and industry has reported
that the IPA’s essentially prohibit “compensated transfers”. All AFA vessel owners and entity
representative are required under the A91 EDR rule to complete a certification statement indicating that
they did not participate in a compensated transfer.
Fuel survey: The A91 fuel survey collects four items of data. These are: hourly fuel consumption - a)
steaming, and b) towing, and annual fuel quantity and costs. Hourly rate data is largely estimated, and in
some cases is the daily fuel cost quoted for charter rates, divided by 24. As a result, the fuel rate data is
accurate to a degree, annual fuel expenditures are accurate to a higher degree, and although neither are
subject to verification audit, collectively represent the best scientific information available on the
operating costs of AFA pollock vessels.
5.2.1.4

GOA Trawl EDR

Trawl CV EDR: The reporting of non-labor vessel cost data in the CV EDR is limited, and is inconsistent
with the structure employed in other EDRs. Despite the Council’s stated intent in implementing the GOA
EDR to use components from other EDRs that have demonstrated utility and quality, the specifications of
two of three non-labor cost elements in the CV form are unique: annual trawl gear cost is reported as
inclusive of all expenditures, including expensed items and capitalized purchases; annual expenditures on
salmon and halibut excluder gear is also combined over expensed and capitalized purchases, and is not
collected in any other EDR.
Trawl Processor EDR: As noted above, the GOA processor EDR collects processing labor data as:
number of employees by month, and labor hours and gross pay, by month and housed/not housed. This
has two potentially important limitations: 1) regular and overtime hours should be reported separately in
order to control for the relative effect of overtime premiums on average labor cost, and 2) the different
stratification applied to employee counts compared to labor hours and pay limits the ability to identify the
number of housed and non-housed employees; the employment data should be differentiated by housing
status, consistent with labor hours and pay. The collection of monthly water and electrical utility
consumption by processing plants is of some concern as well. The data are not generalizable as the
variables only apply to Kodiak plants, and do not adequately capture energy and water costs to plants that
are not fully dependent on municipal utility supply. The narrow scope of this data as currently collected
may be more suited to an administrative reporting requirement than an EDR.

Economic Data Reporting – Discussion Paper, April 2019

71

D5 Economic Data Reporting
APRIL 2019
5.2.1.5

Usability

Assessing the utility and useability of EDR data requires a consideration of the context in which the data
are (or aren’t) being used. To varying degrees, the EDRs were designed by the Council to support
assessment of particular effects of management measures, as in the case of the A91 EDR. The useability
of the EDR data collections in regard to specific applications intended by the Council is separate from the
broader consideration of utility and useability of the data collections to support more general analyses, for
example, in ongoing assessment of the status of the Council’s social and economic objectives described in
the FMPs, or to providing a common set of economic performance metrics that are generally applicable to
industry sectors.
An important limitation on the use of EDR data for specific applications is the frequency with which the
particular management issues are taken up for consideration by the Council. For example, the Council’s
intent in initiating the GOA Trawl CV and processor EDRs was to establish a baseline of economic data
for use in analyzing the effects of a change to catch-share management. Notwithstanding the suspension
of GOA rationalization, the intent of the Council was to use the EDR to accumulate a set of baseline
measurements, against which later measurements collected after a management change could be
compared. The GOA EDR has captured a set of baseline measurements for the few variables that it
collects, and may continue to accumulate a longer baseline of the same data. The useability of these data
for this intended purpose is uncertain, however, given that the envisioned management transition has not
occurred. In addition, the narrow range of variables collected in the CV and processor EDRs poses the
risk of not effectively capturing the dimensions of economic change that are most significantly affected as
a result of management changes. As the EDR was designed to be implemented on a fast track before an
impending catch share program, revisiting the design of the data collection under less time constraint
would likely produce a data collection of more general utility, if that is desired by the Council.
The broader issue of useability of EDR data is primarily limited by the fragmentary nature of the various
data collection forms. As illustrated in Table 3, there are only a small subset of variables that are
somewhat consistently collected across the EDRs, e.g., harvesting and processing labor costs, crew
identifiers, and fuel costs. Most of the rest of the variables collected are unique to a particular EDR form.
Apart from the more fundamental limitations of not having general purpose EDRs that are administered
consistently at the sector-level, the fragmentary nature of the distinct sets of variables collected in the
current EDRs, and the distinctions between EDRs in the way a given variable is measured, e.g., fuel cost,
substantially limits the utility of the data, particularly in the context of Council analyses. The ability of
analysts to produce informative analysis requires familiarity with the base of readily available data.
Although EDR data are available to analysts through AKFIN, the fragmented information provided by
EDRs limit the potential for analysts to become sufficiently familiar with the data to enable general
usefulness. To make this more concrete: Council staff, and to a lesser degree AKRO analytical staff, rely
primarily on AKFIN as a centralized data source, and particularly on AKFIN's “comprehensive” data
tables. The comprehensive tables are integrations of the primary fisheries administrative and monitoring
data systems (e.g., fish tickets, COAR, DPR, NORPAC) developed by AKFIN to allow efficient selection
and summarization of relevant data records for analytical applications by agency staff. Existing EDR
datasets are not suitable for this approach due to the inconsistencies in the design of respective EDR
forms. In order for staff analysts to make ready use and application of cost, employment and other EDR
data requires that a consistent base of information is available across most or all industry sectors be
undertaken, that the data is structured to integrate into the existing data system efficiently, and that
sufficient time and access to the data are provided to allow development of routine analytical processes.
The unique confidentiality protocols that apply to EDR data records also impose limitations on the
useability of the data. The designated Data Collection Agent and “blind-data” protocol, and the “rule-of5” aggregation standard, are unique to EDR data, and were introduced by the Council to apply a higher
standard of confidential data protection to the cost data and other proprietary business information
collected in EDRs. Apart from the particular implications of each element on useability and access to
Economic Data Reporting – Discussion Paper, April 2019

72

D5 Economic Data Reporting
APRIL 2019
EDR data discussed below, these requirements are an additional aspect of the inconsistency of EDR data
that impedes regular use by Council and NMFS analysts. Analysts’ use of EDR data involves increased
material and perceived risk of inadvertently disclosing confidential data. This has likely resulted in
avoidance of using EDR data in cases where it may have been the best information available, but
alternatives with lower risk and complexity were chosen for the sake of timeliness.
The “rule-of-5” aggregation standard specifies that a minimum of five distinct EDR records is required
for public release of aggregated statistics and tabular summaries derived from EDR records. This is in
contrast to the “rule-of-three” standard applied to other confidential commercial fisheries data under
NMFS and Council reciprocal access agreements and MOAs with ADFG and CFEC, and respective
agency administrative rules concerning confidential data.39 After consulting with ADF&G and AKRO
staff, the rule-of-5 was proposed by AFSC in 2006 in response to a Council request for confidentiality
and data quality standards for use of Crab EDR data. The Council recommended the rule-of-5 as a
guideline rather than a formal requirement implemented in EDR rules, and AFSC has subsequently
applied this standard to all public release of statistical summaries using any EDR program data.
The small number of vessel and processor entities represented in EDR records, particularly in CR crab
fisheries, requires confidential data suppression of significant portions of the data collected in EDRs. In
particular, the small number of crab processors providing custom crab processing services prevents
release of data reported in the Crab Processor EDR form for custom processing service fees paid by
buyers and revenue received by custom process providers. This represents a substantial fraction of the
data reported in the crab processor EDR. Applying a rule-of-three standard would allow reporting of
custom processing data to some extent, but in many cases, there are only one or two providers within a
given crab fishery. The rule-of-5 also requires data suppression for cost and employment data in smaller
crab fisheries that would otherwise be publishable under a rule-of-3. It is also notable that, in the potential
event of Chinook salmon PSC transfers that would be subject to reporting in the A91 CTR form,
application of the rule-of-5 would potentially be quite complicated and could prevent release of
information on compensated transfers to the Council or public.
The DCA/blind-data rule requires the collection of EDR forms to be performed by a third-party DCA
(PSMFC), and requires removal of unique identifiers (e.g., vessel identifiers, permit numbers) from EDR
data records accessible to Council and agency staff. However, the Council only required this for Crab
EDR and GOA CV and processor EDR data. The blind data rule was considered when developing the
A80 and A91 EDRs, but was not included in the preferred alternatives for those EDRs. The blind-data
requirement introduces significant administrative challenges for AFSC’s oversight and management of
the EDR program in collaboration with PSMFC because AFSC staff responsible for oversight of data
verification and validation processes are prohibited from access to identifying information. This has
substantially impeded timely completion of verification audits and production of economic SAFE reports
on some occasions. In contrast, the DCA/blind data rules in 679.110 and 680.6 do not prohibit PSMFC
from authorizing subcontractors to access identifiers in EDR records (subject to nondisclosure
agreements). This is necessary for some IT application and database development for EDRs performed
for PSMFC under contract. In principle, this would not prohibit release of EDR microdata containing
identifiers to individuals contracted and authorized to perform research and analyses using EDR data, but
PSMFC and AFSC have consistently applied the blind-data protocol for all EDR data released to
contractors authorized for such purposes.

39

See Confidentiality Of Fisheries Information, Divisional Operating Procedure (DOP) CF-008, ADF&G Division
of Commercial Fisheries. https://www.admin.adfg.state.ak.us/confluence/display/CCFI/Confidentiality+DOP.

Economic Data Reporting – Discussion Paper, April 2019

73

D5 Economic Data Reporting
APRIL 2019
5.3

Applications of EDR data in analyses

Despite numerous limitations, the EDRs together provide considerable valuable insights into the
economic behavior of the fishing industry. While there have been a number of f specific valuable
applications, the EDRs have also given analysts who use the data a deeper understanding of the diversity
within and across fleets. For example, from the Chinook salmon EDR skipper survey, it is clear that the
pollock fishery is balancing a complex range of management challenges. Having a census of all skippers
reveals that different fishers have very different experiences in any given year, and that features such as
the extent of sea ice varies considerably and impact fishing choices and the difficulty of avoiding Chinook
salmon bycatch. In addition, all of the EDRs provide insights into the differences across the vessels in the
fleets they represent. This illustrates that some vessels may be much more flexible at moving in response
to changing target and bycatch encounter rates. This section describes some of the analyses that have been
completed, are presently underway, and/or are continuing to be conducted using EDR data.
5.3.1

EDR Data Annual Reporting

To assess the performance of the Amendment 80 fleet under the rationalization program and subsequent
changes in fishery management economists and analysts at the AFSC use the Amendment 80 EDR data
collection to prepare an annual summary report that is included as a chapter to the annual publication the
Economic Status of the Groundfish Fisheries off Alaska. The summary reports statistics that are intended
to indicate trends in a variety of economic indicators and metrics. The reported statistics provide a general
overview of fishery performance over time, and are not intended as a rigorous statistical analysis of
specific hypotheses regarding economic efficiency or other performance metrics. These generally include
changes in the physical characteristics of the participating vessel stock, including productive capacity of
vessel physical plant (freezer and processing line capacity and maximum potential throughput) and fuel
consumption rates, efficiency and diversification of processing output, investment in vessel capital
improvements, operational costs incurred for fishing and processing in the Amendment 80 fisheries and
elsewhere, and employment and compensation of vessel crews and processing employees.
In addition to the Amendment 80 EDR annual report, economists and analysts at the AFSC also prepare
an annual summary of the crab EDR data collection. The crab annual summary is prepared as the
Economic Status of the BSAI King and Tanner Crab Fisheries off Alaska (Garber-Yonts and Lee, 2018).
This report presents information on economic activity in commercial crab fisheries currently managed
under the Federal FMP for Bering Sea and Aleutian Islands King and Tanner Crab (with attention to the
subset of fisheries included in the Crab Rationalization Program). Statistics on harvesting and processing
activity; effort; revenue; labor employment and compensation; operational costs; and quota ownership,
usage and disposition among participants in the fisheries are provided. Additionally, this report provides a
summary of BSAI crab-related research being undertaken by the Economic and Social Sciences Research
Program (ESSRP) at the AFSC.
5.3.2

Council program reviews

The MSA requires a formal and detailed review of Limited Access Privilege Programs 5 years after the
implementation of the program, and thereafter to coincide with scheduled Council review of the relevant
fishery management plan (but no less frequently than once every 7 years). The Crab Rationalization
Program has had three-year, five-year and 10-year program reviews prepared thus far. Both the 5-year
and 10-year crab program reviews relied on EDR data to document fleet performance with regard to quota
usage and leasing, effort levels, vessel operating costs, gross and net earnings, crew participation and
crew earnings. This information is also used to document changes in crew employment and compensation
and state of residency of crew. Processing labor, employment, and wages are also assessed using EDR
data.
The 10-year crab program review also contained a Social Impact Assessment (SIA) as an appendix to the
review. The SIA utilizes EDR data along with other data sources to provide, within the bounds of data
Economic Data Reporting – Discussion Paper, April 2019

74

D5 Economic Data Reporting
APRIL 2019
confidentiality constraints, a quantitative participation description by community, including harvest trends
by crab fishery, local community fleet participation, catcher vessel crab harvest volume and value by
community, community processor participation, processor volume and value by community by share
type, and quota share distribution by community for Alaska, Washington, Oregon, and other U.S. states
combined. The 10-year Crab Rationalization Program review also summarizes the social impacts of crab
rationalization by community, including discussions of vessel participation, catcher vessel owner
shareholdings, crew participation, catcher vessel crew shareholdings, locally operating processors,
support services, and local governance and revenues.
In 2017, a program review was conducted for the Central GOA Rockfish Program. This program review
also included an SIA that made extensive use of EDR data by developing cross-walk tables for catcher
vessel ownership address community and community of residence of crew on those vessels, along with
payments to labor information, which gave a look at the “employment footprint of the fishery” in a way
that could not be done without EDR data. This analysis showed some interesting patterns across
communities and regions. Data were also presented on shore-based processing labor hours and payments
to labor by processing crew members housed and not housed by their employer. This analysis also made
use of the data on types of crew positions and payments to labor for relevant catcher/processor entities.
The Amendment 80 program 5-year review was completed in 2014 (Northern Economics, 2014). The
review provides an overview of the EDR data collected and uses the data to summarize expenses and
revenues fleet wide. Operating expenses, including payments to labor, are documented and the EDR data
is used to develop a cash flow model. The Amendment 80 5-year review does not contain a social impact
assessment.
5.3.3

Use of EDR Data in Analyses

Council staff, NMFS staff, contractors, and academic partners have used EDR data, both from published
reports and custom queries, in several important ways. As mentioned above, EDR data have been used
extensively in catch share program reviews. In addition, it has been used in several regulatory action
analyses, such as for analyzing crew employment in the 2014 Final Environmental Impact Statement:
Steller Sea Lion Protection Measures for Groundfish Fisheries in the Bering Sea and Aleutian Islands
Management Area. EDR data was also used in analyses of regulatory actions affecting the Amendment 80
fleet and is currently being used in a regulatory impact review of allowing deck sorting of halibut in nonpollock groundfish trawl fisheries (NMFS, 2019 in process).
EDR data have also been utilized in projects related to groundfish and crab stock assessments. Cost and
production data from crab EDRs were used to parameterize bioeconomic models to evaluate effects of
uncertainty buffers for catch projections (Punt et al. (2012), to parameterize cost and production functions
in bioeconomic models to evaluate long-term effects of ocean acidification on Bristol Bay red king crab
(Punt et al. 2014, Seung et al. 2015), and Eastern Bering Sea Tanner crab (Punt et al. 2016). In addition,
cost and production data from crab EDRs will be used to parameterize cost and production functions in
the joint snow-Tanner crab bioeconomic model under development.
EDR data have also been used in several journal articles and/or technical memos that evaluate fishery
productivity and efficiency changes (Walden et. al. 2014, Fissel et. al. 2015, Thunberg et. al. 2015), and
in an analysis measuring the multiregional economic contribution of an Alaska fishing fleet with linkages
to international markets (Waters et al., 2014). EDR data was used in an evaluation of economic impacts of
marine reserves in (Reimer and Haynie, 2018) and to calibrate a model that was used to explore the
sources of rents generated from ITQs (Reimer et al. 2014). Further, the Amendment 80 EDR data are
currently being used in an NPRB Project with Principal Investigators Matthew Reimer, Joshua Abbott,
and Alan Haynie. Amendment 91 Chinook salmon EDR data are also being used in several manuscripts
that are currently in peer review.

Economic Data Reporting – Discussion Paper, April 2019

75

D5 Economic Data Reporting
APRIL 2019
Several recent Council action analyses have used EDR data. The 2016 GOA trawl bycatch management
analysis included an SIA that made extensive use of EDR data. In addition, EDR data was used in the
recently completed (3/8/19) analysis titled BSAI Final Review Draft Social Impact Assessment:
Catcher/Processor Mothership Restrictions in the Bering Sea and Aleutian Islands and the Gulf of Alaska
when taking Directed Non-CDQ Pacific Cod Deliveries from Trawl Catcher Vessels. However, in this
case, complete data was not available for any of the different sectors involved and no EDR data was
available for some of the sectors involved. This action was essentially an allocation (or reallocation)
between sectors and it would not be acceptable to present detailed data on one sector and not another. To
overcome this limitation, the analysts used some of the crew residence data for catcher vessels that filled
out a GOA EDR and worked both in the GOA and the BSAI, with important caveats, as a work around
solution.
In addition to the use of EDR data in analysis identified above, several data evaluation reports have been
developed. These include the following:
•

•
•
•
5.3.4

Bering Sea/Aleutian Island Crab Economic Data Report Center for Independent Experts Review
August, 2011
(https://www.afsc.noaa.gov/REFM/Socioeconomics/PDFs/CIE%20review%20reports/2011_11%
20Anderson%20BSAI%20economic%20data%20collection%20meeting%20report.pdf)
Amendment 91 AFA Chinook Salmon EDR Validation Reports, 2013 and 2014: PSMFC,
https://www.psmfc.org/chinookedr/
Amendment 80 Annual Economic Data Report Validation Audit Reports, 2008-2016, PSMFC,
http://www.psmfc.org/goatrawl/index.html
BSAI Crab Annual Economic Data Report Validation Audit Reports, 1998-2016, PSMFC,
http://www.psmfc.org/alaska_crab/
Analyst Feedback

Analysts from the Council staff, NMFS staff, and contractors who have potentially used EDR provided
some useful feedback on the EDR collections. In cases where EDR data was not used in analyses where it
may have been helpful, analysts may not have full access to the data or feel that they do not have the
familiarity and/or technical skills to access the data without assistance. Further, it has been reported by
analysts that the technical aspects of using EDR data necessitates advanced planning to obtain assistance
with the data access and management tasks and the economic analysis skills needed to use the EDR data.
Analysts have also indicated in some cases the alternatives to be analyzed in a council action are not
always directly informed by the EDR data currently collected.
Analysts described several areas of additional data collection they would like to have included in the
future. These include the following suggestions:
•
•
•
•
•

•

The Council conducts (contracts) AFA Program Reviews; however, there are no EDR data for the
pollock fishery.
Collect variable and fixed cost data that would allow assessment of profitability in each fishery.
Collect crew license numbers for all harvesting crew.
Collect information on the payments to processing crew by their home address for groundfish and
crab fisheries.
Collect a description of how inputs to the production process are acquired by plants and vessels.
For example, are they purchased locally or from vendors outside the community where the
fishing and/or processing is based and is there a consistent pattern of how the flow varies by input
type?
Collect information for all fisheries a vessel participates in. For example, some (but not all) of the
A80 vessels fish in the GOA, and there seemed to be some uncertainty as to whether those boats

Economic Data Reporting – Discussion Paper, April 2019

76

D5 Economic Data Reporting
APRIL 2019

•

•
•

•

were required to summarize their GOA activity, or if they should summarize their GOA Activity
separately. In any case it doesn't seem like the EDR recognized that some A80 vessels participate
in other fisheries.
The Crab EDR doesn't acknowledge or account for participation in other fisheries. For the Crab
EDRs or any EDR to be of good value the forms need to acknowledge participation in other
fisheries and be specific in the questions as to whether or not the respondent should include data
from those other fisheries.
At present we don’t all have a complete picture of what may be available to analysts via queries
versus the reports appended to the SAFE documents.
Collecting data that are consistent (in terms of the variables collected), available in an easily
accessible format, and comparable across all like sectors would be useful. Accomplishing this
would require adding some sectors to the data collection process and perhaps decreasing the level
of detail currently collected from other sectors.
Improve access to EDR data to researchers that are not NMFS or NPFMC employees.

Economic Data Reporting – Discussion Paper, April 2019

77

D5 Economic Data Reporting
APRIL 2019

6

EDR Program Assessment and Recommendations

6.1

Short(er) term, practical recommendations to:
•

•

Reduce costs and burden
o

Eliminate routine third-party data verification audits and limit the audit requirement to
instances of gross noncompliance with EDR submission requirements or where
intentional strategic misreporting is indicated or suspected. NMFS will continue to
research the degree of flexibility we have to minimize requirements under existing
regulations, and which types of modifications will require FMP and regulatory
amendments to implement.

o

Review duplication of reporting requirements in EDR Program.

Improve data utility by streamlining data access
o

6.2

Re-assess EDR-specific data protocols to improve utility and efficiency while
maintaining confidential data protections: specify blind-data rule on the basis of a)
analytical users, and b) EDR administration users, and reconsider rule-of-5 aggregation
standard.

Long(er) term, recommendations to improve economic data collection processes:
•

Develop a systematic approach to identifying and prioritizing the Council’s needs for economic
and social science information. This includes identifying relevant analytical and performance
metrics, minimum requirements for accuracy and precision of information outputs, and a
framework for balancing tradeoffs between all relevant dimensions of information quality and
system costs.
o

Review survey population and survey frequency for EDR variables and consider survey
administration alternatives, including changes in the method, frequency, and respondent
population of data collections to achieve the Council’s analytical objectives.

o

Improve application of National Standard 2 Guidelines to information processes in EDR
program oversight and ensure clearer distinctions between scientific information from
other information content.

o

Minimize disincentives for voluntary industry cooperation with data collection efforts
and address concerns regarding confidentiality, cumulative reporting burden, and
negative consequences of revealing profitability and other financial information to the
federal government.

Economic Data Reporting – Discussion Paper, April 2019

78

D5 Economic Data Reporting
APRIL 2019

7

References

Alaska Fisheries Science Center (AFSC). 2019. Draft Social and Economic Data Gap Analysis v.2.
Unpublished manuscript under development for the NPFMC Social Sciences Planning Team May
2019 meeting.
Biemer, PP. 2010. Total Survey Error: Design, Implementation, and Evaluation. Public Opinion
Quarterly, 74(5): 817-848.
Center for Independent Experts (CIE), 2011. Bering Sea/Aleutian Island Crab Economic Data Report
Center for Independent Experts Review August, 2011. Available online
at: https://www.afsc.noaa.gov/REFM/Socioeconomics/PDFs/CIE%20review%20reports/2011_1
1%20Anderson%20BSAI%20economic%20data%20collection%20meeting%20report.pdf
Federal Committee on Statistical Methodology (FCSM). 2001. Statistical policy working paper No. 3:
Measuring and Reporting Sources of Error in Surveys. U.S. Dept. of Commerce, Office of
Federal Statistical Policy and Standards. 31 p.
FCSM. 2005. Statistical policy working paper No. 2: Report on statistical disclosure and disclosureavoidance techniques. U.S. Dept. of Commerce, Office of Federal Statistical Policy and
Standards. 69 p.
Fissel, B., R. Felthoven, S. Kasperski, and C. O’Donnell. 2015. “Decomposing Productivity and
Efficiency Changes in the Alaska Head and Gut Factory Trawl Fleet”. Marine Policy, 62: 337346.
Garber-Yonts, B., and J. Lee. 2018. Stock Assessment and Fishery Evaluation Report for King and
Tanner Crab Fisheries of the Bering Sea and Aleutian Islands Regions: Economic Status of the
BSAI Crab Fisheries, 2017.
Himes-Cornell, A., S. Kasperski, K. Kent, C. Maguire, M. Downs, S. Weidlich, and S. Russell. 2015.
Social baseline of the Gulf of Alaska groundfish trawl fishery: Results of the 2014 social survey.
U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-303, 98 p. plus Appendices.
Holland, D.S., E. Thunberg, J. Agar, S. Crosson, C. Demarest, S. Kasperski, L. Perruso, E. Steiner, J.
Stephen, A. Strelcheck, and M. Travis. 2015. “US Catch Share Markets: A Review of Data
Availability and Impediments to Transparent Markets”. Marine Policy, 57: 103-110.
International Organization for Standardization (IOS). 2000. Quality management principles.
Lew, D.K., and D.M. Larson. 2012. Economic Values for Saltwater Sport Fishing in Alaska: A Stated
Preference Analysis. North American Journal of Fisheries Management, 32(4): 745-759.
Lew, D.K., and D.M. Larson. 2015. Stated Preferences for Size and Bag Limits of Alaska Charter Boat
Anglers. Marine Policy, 61: 66-76.
National Marine Fisheries Service (NMFS), 2004a. “Final Environmental Impact Statement: Bering Sea
and Aleutian Islands Crab Fisheries.” National Marine Fisheries Service, Alaska Region and
North Pacific Fishery Management Council. August, 2004. 1003 pp plus appendices.
https://alaskafisheries.noaa.gov/sites/default/files/eisvol1.pdf
NMFS, 2004b. “Regulatory Impact Review/ Initial Regulatory Flexibility Analysis Voluntary Three-Pie
Cooperative Program for the Bering Sea and Aleutian Islands Crab Fisheries.” North Pacific
Fishery Management Council/National Marine Fisheries Service. August, 2004. 638 pp plus

Economic Data Reporting – Discussion Paper, April 2019

79

D5 Economic Data Reporting
APRIL 2019
appendices. https://alaskafisheries.noaa.gov/sites/default/files/analyses/Appendix1_RIR.pdf; An
extract of EIS and RIR/IRFA sections addressing the economic data collection element of the
Crab Rationalization program, with Appendix 1.3-6 (missing from the above URL) are available
from AFSC at https://www.afsc.noaa.gov/REFM/Socioeconomics/PDFs/EIS_EDRsections.pdf.
NMFS, 2013. “Secretarial Review Draft Regulatory Impact Review / Initial Regulatory Flexibility
Analysis Proposed Amendment 42 to the Fishery Management Plan for Bering Sea and Aleutian
Islands King and Tanner Crabs: Modification of Economic Data Reports”. February, 2013. 97 pp
plus appendices.
https://alaskafisheries.noaa.gov/sites/default/files/analyses/amd42ririrfa0213.pdf.
NMFS, 2014. “Final Environmental Impact Statement: Steller Sea Lion Protection Measures for
Groundfish Fisheries in the Bering Sea and Aleutian Islands Management Area.”
https://alaskafisheries.noaa.gov/sites/default/files/eisvol1.pdf
NMFS, 2014(b). “Regulatory Impact Review/ Initial Regulatory Flexibility Analysis for the Trawl
Economic Data Report: Fishery Management Plan for Groundfish of the Gulf of Alaska: Data
Collection from Vessels Using Trawl Gear to Harvest Groundfish from the Gulf of Alaska and
the Processors taking Deliveries from Those Vessels”. October, 2014. 48 pp. plus appendices.
https://www.regulations.gov/contentStreamer?documentId=NOAA-NMFS-2014-00350010&contentType=pdf
NMFS, 2018. “Economic Status Report Summary: BSAI Crab Fisheries,
2017.” https://www.npfmc.org/wpcontent/PDFdocuments/resources/SAFE/CrabSAFE/2017CrabEconomicSAFEappendix.pdf
NMFS, 2018. “Review of Regulations under E.O. 13771 and E.O. 13777.” A discussion paper presented
by NMFS to the North Pacific Fishery Management Council at its April 2018 meeting. Agenda
Item D2. 15 pp.
NMFS, 2018. Stock Assessment and Fishery Evaluation Report for the Groundfish Fisheries of the Gulf
of Alaska and Bering Sea/Aleutian Islands Area: Economic Status of the Groundfish Fisheries
Off Alaska, 2017. http://meetings.npfmc.org/CommentReview/DownloadFile?p=bf68dfea-11a3431f-8e9a9560cc2cc0ba.pdf&fileName=Economic%20Groundfish%20SAFE_Fissel%20revised%2011-1918.pdf
NMFS, 2019 in process. Regulatory Impact Review. “Halibut Deck Sorting Monitoring Requirements for
Trawl Catcher/Processors Operating in Non-Pollock Groundfish Fisheries off Alaska.” NOAA
Fisheries, Alaska Regional Office, Juneau Alaska.
North Pacific Fishery Management Council (NPFMC), 2007. “Final Environmental
Assessment/Regulatory Impact Review/Final Regulatory Flexibility Analysis For Amendment 80
to the Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands
Management Area”. July 20, 2007. 398 pp plus appendices.
https://alaskafisheries.noaa.gov/sites/default/files/analyses/earirfrfa0907.pdf.
NPFMC, 2010. Five-Year Program Review for the Crab Rationalization Management Program in the
Bering Sea/ Aleutian Islands. https://www.npfmc.org/wpcontent/PDFdocuments/catch_shares/Crab/SIAexS_911.pdf

Economic Data Reporting – Discussion Paper, April 2019

80

D5 Economic Data Reporting
APRIL 2019
NPFMC, 2010(b). “Public Review Draft Regulatory Impact Review/ Initial Regulatory Flexibility
Analysis for a Proposed Chinook Salmon Bycatch Data Collection Program” December, 2009. 93
pp. https://www.npfmc.org/wp-content/PDFdocuments/bycatch/ChinookDataCollection1209.pdf
NPFMC, 2014. “Regulatory Impact Review/Initial Regulatory Flexibility Analysis for the Trawl
Economic Data Report: Fishery Management Plan for Groundfish of the Gulf of Alaska”.
Prepared by the North Pacific Fishery Management Council and the National Marine Fisheries
Service. February 25, 2014. 49 pp plus appendices.
NPFMC, 2017. Central Gulf of Alaska Rockfish Program Review. https://www.npfmc.org/wpcontent/PDFdocuments/catch_shares/Rockfish/RockfishProgramReview1017.pdf.
NPFMC, 2017. Ten-Year Program Review for the Crab Rationalization Management Program in the
Bering Sea/ Aleutian Islands. https://www.npfmc.org/wpcontent/PDFdocuments/catch_shares/Crab/Crab10yrReview_Final2017.pdf
NPFMC, 2018. Regulatory Impact Review/Environmental Assessment for Amendment 116 to the Fishery
Management Plan for the Groundfish of the Bering Sea and Aleutian Islands Management Areas
Limiting Access for Catcher Vessels in the Bering Sea and Aleutian Islands Trawl Limited
Access Sector Yellowfin Sole Offshore Directed
Fishery. https://alaskafisheries.noaa.gov/sites/default/files/analyses/bsai-amd-116-yfs-tlas-ea-rir0718.pdf
Northern Economics, Inc. 2014. Five-Year Review of the Effects of Amendment 80. Prepared for North
Pacific Fishery Management Council. October, 2014.
https://alaskafisheries.noaa.gov/sites/default/files/amd805yrreview1014.pdf
Punt, A., Siddeek, M., Garber-Yonts, B., Dalton, M., Rugolo, L., Stram, D., Turnock, B., Zeng, J. 2012.
"Evaluating the impact of buffers to account for scientific uncertainty when setting TACs:
application to red king crab in Bristol Bay, Alaska", ICES J. of Mar. Sci., 69: 624-634.
https://academic.oup.com/icesjms/article/69/4/624/636410
Punt, A., Poljak, D., Dalton, M., Foy, R. 2014. Evaluating the impact of ocean acidification on fishery
yields and profits: The example of red king crab in Bristol Bay. Ecological Modelling, 285: 3953.
Punt A., Foy, R., Dalton, M., Long, C., Swiney, K. 2016. Effects of long-term exposure to ocean
acidification conditions on future southern Tanner crab (Chionoecetes bairdi) fisheries
management. ICES J. Mar. Sci., 73: 849-864
Reimer, M. and A.C. Haynie. 2018. “Mechanisms Matter for Evaluating the Economic Impacts of Marine
Reserves,” Journal of Environmental Economics and Management, 88: 427-426.
Reimer, M., Abbott, J., Wilen, J. 2014. Unraveling the Multiple Margins of Rent Generation from
Individual Transferable Quotas. Land Economics (90)3: 538-559.
http://le.uwpress.org/content/90/3/538.short
Seung et al. 2015. Economic impacts of changes in an Alaska crab fishery from ocean acidification.
Climate Change Economics 6(4): 1550017.
(https://www.worldscientific.com/doi/abs/10.1142/S2010007815500177)
Small Business Administration (SBA), 2010. “The RFA in a Nutshell: A Condensed Guide to the
Regulatory Flexibility Act.” SBA Office of Advocacy. October 2010. 32 pp.
(https://www.sba.gov/sites/default/files/advocacy/RFA_in_a_Nutshell2010.pdf)
Economic Data Reporting – Discussion Paper, April 2019

81

D5 Economic Data Reporting
APRIL 2019
Thunberg, E., J. Walden, J. Agar, R. Felthoven, A. Harley, S. Kasperski, J. Lee, T. Lee, A. Mamula, J.
Stephen, and A. Strelcheck. 2015. “Measuring Changes in Multi-Factor Productivity in U.S.
Catch Share Fisheries”. Marine Policy, 62: 294-301.
Walden, J., J. Agar, R. Felthoven, A. Harley, S. Kasperski, J. Lee, T. Lee A. Mamula, , J. Stephen, A.
Strelcheck, and E. Thunberg. 2014. Productivity Change in U.S. Catch Shares Fisheries. U.S.
Dept. of Commer., NOAA Technical Memorandum NMFS-F/SPO-146, p.137.
Wang RY, Strong DM. 1996. Beyond accuracy: What data quality means to data consumers. Journal of
management information systems, 12(4):5-33.
Watson, J.T. and A.C. Haynie. 2018. “Paths to resilience: Alaska pollock fleet uses multiple fishing
strategies to buffer against environmental change in the Bering Sea,” Canadian Journal of
Aquatic and Fisheries Sciences, 75(11): 1977-1989, https://doi.org/10.1139/cjfas-2017-0315.
Waters, E., Seung, C., Hartley, M., Dalton, M., (2014) Measuring the multiregional economic
contribution of an Alaska fishing fleet with linkages to international markets. Marine Policy, 50
A, 238-248. https://www.sciencedirect.com/science/article/pii/S0308597X14001778

Economic Data Reporting – Discussion Paper, April 2019

82

D5 Economic Data Reporting
APRIL 2019

Appendix A – FMP and Regulations
Fishery Management Plan and Federal Regulations for
Economic Data Collection Programs or Economic Data Reporting Requirements
Text below in italics are excerpts from the fishery management plans.
Fishery Management Plan for Bering Sea/Aleutian Islands King and Tanner Crabs (crab FMP)
Requirements for the Crab Rationalization Program Economic Data Collection are in Chapter 11, Section
14 of the crab FMP. These requirements were elements of the Crab Rationalization Program, which was
added to the crab FMP in 2004 through Amendment 18. These requirements were revised in 2013 through
Amendment 42 to the crab FMP. The current text of the crab FMP for the Economic Data Collection
Program and requirements are reproduced below:
14.

Data Collection Program

The Crab Rationalization Program includes a mandatory economic data collection program which
requires owners or leaseholders of catcher vessels, catcher/processors, shoreside crab processors, and
stationary floating crab processors, as well as PQS holders that purchase crab deliveries, in the BSAI
crab fisheries to submit an economic data report (EDR) on an annual basis. The purpose of the EDR is to
collect cost, revenue, ownership, and employment data to provide the Council and NMFS with the
information necessary to study the impacts of the Crab Rationalization Program. Participation is
mandatory.
14.1

Purpose

This data collection effort is required to address the Council’s original problem statement for the Crab
Rationalization Program. That problem statement requires a structure that achieves “equity between the
harvesting and processing sectors” and “…economic stability for harvesters, processors and coastal
communities.” The Council revised the data collection program in 2012 to improve the quality of data
collected and eliminate redundancies with other collections of data.
The data collected is intended to aid the Council and NMFS in assessing the efficacy of the Crab
Rationalization Program and to determine its relative impact on fishery participants and communities.
The collected data may assist with the development of amendments to the Crab Rationalization Program
or could be used to analyze the economic and social impacts of future FMP amendments on industry,
regions, and localities.
14.2

Collection of Data

The EDR is administered by NMFS through contracts with Pacific States Marine Fisheries Commission
(PSMFC), an independent third-party data collection agent. Each owner or leaseholder of the BSAI crab
fishing industry must fill out the appropriate EDR form annually. The data collected is specific to the
crab fisheries in the Crab Rationalization Program and includes information on costs of fishing and
processing, revenues for harvesters and processors, and employment data.
14.3

Use of data

Data will be supplied to NMFS, Council staff, and any other authorized users according to statutory and
regulatory data confidentiality requirements in a blind and unaggregated form. The blind format is
intended to safeguard information that is perceived to be highly proprietary and prevent analysts from
directly identifying the source of any observations. Specifically, all identifiers associated with a data
submitter are eliminated and replaced with a unique number, which does not reveal the identity of the
submitter. However, in cases where the data (including identifiers) are requested by NMFS Enforcement,
NOAA General Counsel, the Department of Justice, or the Federal Trade Commission for a purpose
Economic Data Reporting – Discussion Paper, April 2019

83

D5 Economic Data Reporting
APRIL 2019
connected to law enforcement or qualification for quota and other Federal permits, PSMFC will continue
to provide the data and the identity of the submitter.
14.4

Verification of Data

The third-party data collection agent will verify the data in a manner that assures accuracy of the
information supplied by private parties. The data collection agent may review and request for the owner
or leaseholder to provide copies of additional data.
14.5

Duration

The data collection program will continue through the life of the Crab Rationalization Program.
14.6

Failure to Submit Forms

Participation in the data collection program is mandatory. Should a submitter fail to submit the
appropriate EDR to PSMFC by the deadline, the infraction will be referred to the Office of Law
Enforcement.
14.7

Enforcement of the Data Requirements

The intent of Amendment 42 for the wording of what was (F) Enforcement of Data Requirements is
unclear and further research is needed. The FMP amendment may or may not have retained the following
text under paragraph 14.7:
The Council endorses the approach to enforcing the data requirements developed by the staff and the
Data Collection Committee, as set out on page 3.17-20 in the February 2003 document entitled “BSAI
Crab Rationalization Program, Trailing Amendments”, which provides:
Anticipated Enforcement of the Data Collection Program The analysts anticipate that enforcement of the
data collection program will be different from enforcement programs used to ensure that accurate
landings are reported. It is critical that landings data are reported in an accurate and timely manner,
especially under an IFQ system, to properly monitor catch and remaining quota. However, because it is
unlikely that the economic data will be used for in-season management, it is anticipated that persons
submitting the data will have an opportunity to correct omissions and errors37 before any enforcement
action would be taken. Giving the person submitting data a chance to correct problems is considered
important because of the complexities associated with generating these data. Only if the agency and the
person submitting the data cannot reach a solution would the enforcement agency38 be contacted. The
intent of this program is to ensure that accurate data are collected without being overly burdensome on
industry for unintended errors.
A discussion of four scenarios will be presented to reflect the analysts understanding of how the
enforcement program would function. The four scenarios are: (1) a case where no information is
provided on a survey; (2) a case where partial information is provided; (3) a case where the agency has
questions regarding the accuracy of the data that has been submitted; and (4) a case where a random
“audit” to verify the data does not agree with data submitted in the survey.
In the first case, the person required to fill out the survey does not do so. In the second case, the person
fills out some of the requested information, but the survey is incomplete. Under either case that person
would be contacted by the agency collecting the data and asked to fulfill their obligation to provide the
required information. If the problem is resolved and the requested data are provided, no other action
would be taken. If that person does not comply with the request, the collecting agency would notify
enforcement that the person is not complying with the requirement to provide the data. Enforcement
would then use their discretion regarding the best method to achieve compliance. Those methods would
likely include fines or loss of quota and could include criminal prosecution.

Economic Data Reporting – Discussion Paper, April 2019

84

D5 Economic Data Reporting
APRIL 2019
In the third case the person fills out all of the requested information, but the agency collecting the data,
or the analysts using the data, have questions regarding some of the information provided. For example,
this may occur when information provided by one company is much different than that provided by
similar companies. These data would only be called into question when obvious differences are
encountered. Should these cases arise, the agency collecting the data would request that the person
providing the data double check the information. Any reporting errors could be corrected at that time. If
the person submitting the data indicates that the data are accurate and the agency still has questions
regarding the data, that firm’s data could be “audited”. It is anticipated that the review of data would be
conducted by an accounting firm selected jointly by the agency and members of industry. Only when that
firm refuses to comply with the collecting agencies attempts to verify the accuracy of the data would
enforcement be contacted. Once contacted, enforcement would once again use their discretion on how to
achieve compliance.
The fourth case would result when the “audit”39 reports different information than the survey. The
“audit” procedure being contemplated is a verification protocol similar to that which was envisioned for
use in the pollock data collection program developed by NMFS and PSMFC. During the design of this
process, input from certified public accountants was solicited in order to develop a verification process
that is less costly and cumbersome than a typical “audit” procedure. That protocol involves using an
accounting firm, agreed upon by the agency and industry, to conduct a random review of certain elements
of the data provided.40
Since some of the information requested in the surveys may not be maintained by companies and must be
calculated, it is possible that differences between the “audited” data from financial statements and survey
data may arise. In that case the person filling out the survey would be asked to show how their numbers
were derived.41 If their explanation resolves the problem, there would be no further action needed. If
questions remained, the agency would continue to work with the providers of the data. Only when an
impasse is reached would enforcement be called upon to resolve the issue. It is hoped that this system
would help to prevent abuse of the verification and enforcement authority.
In summary, members of the crab industry will be contacted and given the opportunity to explain and/or
correct any problems with the data, that are not willful and intentional attempts to mislead, before
enforcement actions are taken. Agency staff does not view enforcement of this program as they would a
quota monitoring program. Because these data are not being collected in “real” time, there is the
opportunity to resolve occasional problems as part of the data collection system. Development of a
program that collects the best information possible to conduct analyses of the crab rationalization
program, minimizes the burden on industry, and minimizes the need for enforcement actions are the goals
of the data collection initiative.
Footnotes to 14.7:
37
The intent of the program is to have enforcement actions triggered by the willful and intentional
submission of incorrect data or noncompliance with the requirements to submit data.
38
The term enforcement agency in this case may or may not include the RAM Division and the Office of
Administrative Appeals (in addition to NMFS Enforcement). Those details are still under discussion
within NOAA.
39
This “audit” could be the result of either the random review process that is contemplated or an “audit”
triggered under scenario three.
40
However, in cases of non-compliance in which enforcement has to be notified, the data verification
process is likely be more comprehensive.
41
Any time a number must be derived, the survey will provide direction on how the calculate the
information requested. This direction should help minimize differences. However, when discrepancies do
arise, the firm will be given an opportunity to show how they derived their figures and correct the
information if necessary.

Economic Data Reporting – Discussion Paper, April 2019

85

D5 Economic Data Reporting
APRIL 2019
Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management
Area (BSAI FMP)
3.7.5 Amendment 80
3.7.5.9 Economic Data Report
A socioeconomic data collection program will be implemented for the non-AFA trawl CP sector. Data
will be collected on a periodic basis. The purpose of the data collection program is to understand the
economic effects of the Amendment 80 program on vessels or entities regulated by this action, and to
inform future management actions.
3.6.2 Prohibited Species Catch Limits
3.6.2.1.6 Chinook Salmon
There is no reference to the Chinook salmon bycatch economic data collection requirements in the BSAI
FMP. The last sentence of section 3.6.2.1.6 states the following:
The process for allocating the Bering Sea Chinook salmon PSC limit among participants in the Bering
Sea pollock fishery; requirements governing the transfer and use of these allocations; and requirements
for an IPA, the performance standard, annual reporting, and other aspects of the Bering Sea Chinook
Salmon Bycatch Management Program are specified in Federal regulations implementing the FMP.
The BSAI FMP also contains the following sections that generally authorize recordkeeping and reporting
requirements necessary to implement conservation and management measures regulations needed.
3.9.1 Recordkeeping and Reporting
The Council and NMFS must have the best available biological and socioeconomic information with
which to carry out their responsibilities for conserving and managing groundfish resources, as well as
other fish resources, such as crab, halibut, and salmon, that are incidentally caught in the groundfish
fishery. This information is used for making inseason and inter-season management decisions that affect
these resources as well as the fishing industry that utilize them. This information is also used to judge the
effectiveness of regulations guiding these decisions. The Council will recommend changes to regulations
when necessary on the basis of such information.
The need for the Council and NMFS to consider the best available information is explicit in the goals and
objectives as established by the Council and contained in the FMP. They are also explicit in the
Magnuson-Stevens Act, Executive Order 12866, the Regulatory Flexibility Act, the National
Environmental Policy Act, and other applicable law. The Secretary, therefore, will require segments of
the fishing industry to keep and report certain records as necessary to provide the Council and NMFS
with the needed information to accomplish these goals and objectives. The Secretary may implement and
amend regulations at times to carry out these requirements after receiving Council recommendations to
do so, or at other times as necessary to accomplish these goals and objectives. Regulations will be
proposed and implemented in accordance with the Administrative Procedure Act, the Magnuson-Stevens
Act, and other applicable law.
Information on catch and production, effort, and price
In consultation with the Council, the Secretary may require recordkeeping that is necessary and
appropriate to determine catch, production, effort, price, and other information necessary for
conservation and management of the fisheries. Such requirements may include the use of catch and/or
product logs, product transfer logs, effort logs, or other records. The Secretary may require the industry
Economic Data Reporting – Discussion Paper, April 2019

86

D5 Economic Data Reporting
APRIL 2019
to submit periodic reports or surveys of catch and fishery performance information derived from the logs
or other recordkeeping requirements.
Recordkeeping and reporting is required of operators of catcher vessels, catcher/processor vessels,
mothership processor vessels, and by responsible officers of shoreside processor plants.
3.9.1.1 Processor Reports
All processors of groundfish shall report information necessary for the management of groundfish
resources. The regulations implementing this plan specify the information to be reported and the time
schedule for reporting.
Fishery Management Plan for Groundfish of the Gulf of Alaska (GOA FMP)
There is no specific reference to economic data collection or reporting requirements in the GOA FMP.
Requirements that apply to trawl catcher vessels, catcher/processors, and processors that operate in the
GOA are implemented under the general recordkeeping and reporting authority in section 3.9 of the GOA
FMP. Therefore, amending EDR requirements for the GOA should require only regulatory amendments
and revisions to forms and instructions.
3.9 Monitoring and Reporting
The Council and NMFS must have the best available biological and socioeconomic information with
which to carry out their responsibilities for conserving and managing groundfish resources, as well as
other fish resources, such as crab, halibut, and salmon, which are incidentally caught in the groundfish
fishery. This catch monitoring and reporting information is used for making inseason and inter-season
management decisions that affect these resources as well as the fishing industry that utilize them.
Information collected from industry reports and through the Observer Program constitutes the
standardized reporting methodology for the GOA groundfish fishery. The standardized reporting
methodology means established, consistent procedures used to collect, record, and report catch and
bycatch in the fisheries. One of the purposes of industry reports and the Observer Program is to collect,
record, and report bycatch data in the fisheries that are used to assess the amount of type of bycatch
occurring in the fishery and inform the development of conservation and management measures that, to
the extent practicable, minimize bycatch and bycatch mortality.
Scientific evaluation of the information that is collected through the Observer Program is used to adjust
the sampling plan for observer and electronic monitoring deployment. Monitoring and reporting
information is also used to judge the effectiveness of regulations guiding the standardized reporting
methodology. The Council will recommend changes to regulations when necessary on the basis of such
information
3.9.1 Recordkeeping and Reporting
The Council and NMFS must have the best available biological and socioeconomic information with
which to carry out their responsibilities for conserving and managing groundfish resources, as well as
other fish resources, such as crab, halibut, and salmon, that are incidentally caught in the groundfish
fishery. This information is used for making inseason and inter-season management decisions that affect
these resources as well as the fishing industry that utilize them. This information is also used to judge the
effectiveness of regulations guiding these decisions. The Council will recommend changes to regulations
when necessary on the basis of such information.
The need for the Council and NMFS to consider the best available information is explicit in the goals and
objectives as established by the Council and contained in the FMP. They are also explicit in the

Economic Data Reporting – Discussion Paper, April 2019

87

D5 Economic Data Reporting
APRIL 2019
Magnuson Stevens Act, Executive Order 12866, the Regulatory Flexibility Act, the National
Environmental Policy Act, and other applicable law. The Secretary, therefore, will require segments of
the fishing industry to keep and report certain records as necessary to provide the Council and NMFS
with the needed information to accomplish these goals and objectives. The Secretary may implement and
amend regulations at times to carry out these requirements after receiving Council recommendations to
do so, or at other times as necessary to accomplish these goals and objectives. Regulations will be
proposed and implemented in accordance with the Administrative Procedure Act, the Magnuson-Stevens
Act, and other applicable law.
3.9.1.1 Information on catch and production, effort, and price
In consultation with the Council, the Secretary may require recordkeeping that is necessary and
appropriate to determine catch, production, effort, price, and other information necessary for
conservation and management of the fisheries. Such requirements may include the use of catch and/or
product logs, product transfer logs, effort logs, or other records. The Secretary may require the industry
to submit periodic reports or surveys of catch and fishery performance information derived from the logs
or other recordkeeping requirements.
Recordkeeping and reporting is required of operators of catcher vessels, catcher/processor vessels,
mothership processor vessels, and by responsible officers of shoreside processor plants. Such
requirements will be contained in regulations implementing this FMP.

Economic Data Reporting – Discussion Paper, April 2019

88

D5 Economic Data Reporting
APRIL 2019

Appendix B – Statement of Work

Pacific States Marine Fisheries Commission
Statement of Work: Bering Sea Aleutian Islands Crab
Rationalization Economic Data Report Data Validation
Aldrich CPAs + Advisors LLP
$28,000 expires February 28, 2019

Description
Under regulations promulgated by the United States Secretary of Commerce, fishing and seafood
processing businesses and associated participants in the Bering Sea and Aleutian Islands Crab
Rationalization (CR), American Fisheries Act (AFA), and Amendment 80 (A80) fishery management
programs, and groundfish trawl fisheries in the Gulf of Alaska (GOA Trawl), are subject to mandatory
annual economic data collection censuses, referred to as Economic Data Reports (EDR). As developed by
the North Pacific Fishery Management Council (Council) and implemented by National Marine Fisheries
Service (NMFS), EDR requirements for regulated participants in these fisheries are specified under 50
CFR 680.6, 679.65, 679.94, and 679.110, respectively. EDRs are intended to provide employment, cost,
sales and other business data to inform the Council’s oversight of fishery management through
improved analyses of economic performance of affected harvesters and processors participating in
these Alaska fisheries, and social and economic effects on associated communities. The Council placed a
high priority on data quality assurance (QA) in design of EDR programs. Compliance with EDR submission
requirements is mandatory for all subject entities as a condition of federal fishery permit issuance and
renewal, and failure to submit required EDR forms in a timely manner is grounds for enforcement action
by NMFS Office of Law Enforcement. In addition to these and other data QA elements, the Council
specified EDR regulations to include data verification audits of EDR records, to be performed by a
qualified financial auditor contracted and authorized to solicit and review financial and other supporting
company records from EDR submitters, assess reported data values against supporting records, and
verify accurate values.
Data collection and management of EDR programs for Alaska fisheries is administered by the Pacific
State Marine Fisheries Commission (PSMFC), under a grant from National Marine Fisheries Service
(NMFS) and in collaboration with NMFS Alaska Fisheries Science Center (AFSC). For each distinct
category of participant in the respective fisheries, EDR questionnaire forms have been designed to
collect quantitative financial and administrative information about business operations with respect to
the previous calendar year. Submission due dates are July 31 for the Crab EDR, and June 1 for all other
EDR forms. Primary data validation is conducted by PSMFC during the course of data collection and
employs automated database processes to identify gross and/or logical reporting errors and obtain
submitter corrections where possible. Following completion of primary validation and error correction,
the EDR database is further analyzed to identify a subset of records from the most recent 1-2 years of
EDR submissions for verification audit, to be conducted by a contracted CPA firm according to protocols
described below.
PSMFC subcontracting with Aldrich CPAs + Advisors LLP to implement and complete the third-party
verification audit protocols as specified below for EDR forms submitted for calendar year 2017.

Economic Data Reporting – Discussion Paper, April 2019

89

D5 Economic Data Reporting
APRIL 2019

Specifications
The data verification audit will be conducted on selected data values reported in individual 2017
calendar year EDR forms submitted during 2018. The total set of EDR submissions is comprised of annual
EDR forms collected from each participating entity in the respective fishery management program,
including each vessel and processor in the BSAI crab program. An entity that operates two or more
vessels or processing facilities subject to EDR requirements is required to submit a separate form for
each vessel and/or plant. Distinct EDR forms are used for each of the industry sectors in the respective
EDR programs, with questions/data items specifically addressing the nature of production and sales
within the sector.40
EDR forms are generally comprised of a certification section, containing identifying information for the
entity and a signature statement certifying the reported information as accurate and complete, and a
data section containing a series of tabular reporting grids which specify operational, employment, cost,
and earnings information to be reported. Validation audits are conducted only on information from the
data section. Most data items are reported as annual, calendar year quantity (e.g., hours, pounds, etc)
and/or monetary value totals, categorized by one or more stratifying factors (e.g., fishery season, cost
category, product type, etc.). A smaller set of data items in EDR records are categorical responses (e.g.,
yes/no) or annual average rates (e.g., price per pound or gallons per hour). The number of individual,
non-zero/non-null data entries reported in a submitted EDR form is variable, depending on the type of
form submitted and the number of applicable data items and/or strata. On average, crab catcher vessel
EDR submissions report approximately 70 distinct data entries across 16 data items, crab processor EDRs
report approximately 280 distinct entries across 18 data items, crab catcher-processor EDRs report
approximately 310 distinct entries across 26 data items (Table).
Table 1: Counts of submitted EDR forms and estimated data elements subject to potential selection for
verification audit
2017
EDR type

Data items

EDRs

Data entries

Crab EDR Total

60

91

5460

Catcher/Processor

26

2

52

Shoreside Processor

18

19

342

Catcher Vessel

16

70

1,120

Only a subset of EDR records and data entries are selected for audit verification. All audit selection
procedures will be performed by PSMFC/ AFSC41 based on three sets of criteria:

40

The current EDR forms are available for download at http://www.psmfc.org/alaska_crab/ for the BSAI crab EDR
program Online web application versions of each EDR form are hosted on PSMFC's website, which support more
streamlined data entry steps for the submitting entity as well as automatically generating electronic data records;
these are used by a majority of submitters, but completed paper forms may be delivered to PSMFC by mail/fax at
the option of the submitter.
41
In prior RFPs and contracts for EDR verification audits, the procedure for random audit selection was included in
the scope of work to be performed by the contractor. The random sampling procedure previously specified a
sampling formula and minimum sampling rate designed to support statistical inferences of audit results from the
respective audit samples to the associated populations of EDR records. This RFP revises the audit selection process,
which will be performed entirely by PSMFC/ASFC.

Economic Data Reporting – Discussion Paper, April 2019

90

D5 Economic Data Reporting
APRIL 2019
1.) Random selection: for a predefined set of data items, a subset of EDR records will be
randomly selected for verification of reported values;
2.) Outlier selection: targeted selection of individual data values reported in specific EDR
records that fail primary and/or statistical validation tests performed by PSMFC/AFSC and are
thus identified as likely reporting errors; and
3.) For-cause selection: EDR records submitted by entities that have failed to meet minimum
standards for timeliness and/or accuracy in current or recent EDR submissions.
EDR records selected for audit will be provided to the contractor in an electronic database file
containing the EDR record number, contact information for the submitting entity, and a table of
corresponding data items and reported values to be verified, as described in more detail below. Based
on EDR audits conducted to date and revised sampling procedures to be employed, it is anticipated that
the total number of individual EDR records, distinct data items, and distinct data values selected for
audit will be as follows:
Table 2: Estimated counts of EDR records selected for audit verification for 2017 EDRs
Estimated audit selections per year
EDR Program
EDRs Data items
Data entries
Crab EDR total for 2017 16

14

71

Crab EDRs are due to PSMFC on July 31st of each year. Time required to complete primary validation,
finalization of electronic EDR records, and outlier detection/selection may require up to six weeks.
Although there is some uncertainty regarding the date by which EDR records will be finalized and
selected for audit, usually all EDR data records subject to verification audit will be available to the
contractor by September 30th.

Scope of Work
The general protocol for validating EDR data values is the following:
PSMFC/NMFS will select EDR records for audit based on criteria outlined above. In all cases, the
verification procedures for a selected data entry are largely the same. The subset of data items
(variables) selected for audit varies each year, but typically comprises a set of 5-25 distinct items from
each of the respective EDR forms. PSMFC will compile a single tabular data report listing all selected
data entries (total data entries shown in Table 2 above) by EDR record number (booklet_id), providing
an abbreviated description of the variable, the data entry value reported by the submitter, three fields
for recording verification results, and a description of the reason for selection (see Table 3 below). This
tabular report is to be used by the auditor as the primary vehicle for recording final verification results
for each selected entry and delivery to PSMFC (see Deliverables: Audit results database below). The
integrity of information represented in the tabular data report is critical to satisfactory performance of
the contract; auditors must ensure that the verification results are represented accurately, according to
all protocols detailed below, and that the tabular structure is carefully maintained to prevent corruption
of data contained therein. In separate tables, PSMFC will also provide a listing of contact information for
the associated EDR submitters, and a set of EDR variable descriptions corresponding to each distinct
variable included in the audit selection, formatted for use in written communication with EDR
submitters, and an archive of the complete EDR record for each respective EDR booklet included in the
audit selection.

Economic Data Reporting – Discussion Paper, April 2019

91

D5 Economic Data Reporting
APRIL 2019
The auditor will review the EDR records and communicate with the submitters to request supporting
records for the specific items to be verified. The auditor may request and review copies of additional
data or records provided by the EDR submitter, including but not limited to: previously audited or
reviewed financial statements, worksheets, tax returns, invoices, receipts, and other original documents
substantiating the data. It is not possible to define the exact nature of the supporting information an
auditor may be provided with when conducting an audit because each company has their own style of
financial recordkeeping. Some follow-up communication may be necessary to identify and receive the
necessary records.
Using the supporting records supplied by the EDR submitter, the auditor will validate the reported
values. Validation includes evaluating the quality of supporting documentation supplied as the basis for
verification of reported EDR values; identification and classification of reporting errors; and, where
possible, identifying a correction and quantifying the amount of reporting error for each audited data
value. Some of the information collected in EDRs is not maintained in submitter records exactly as
described in the EDR form, requiring the submitter to derive or approximate the value to report (e.g. by
pro rata distribution). In these instances, the method of approximation and any calculations must be
documented by the submitter to be validated. The auditor will review and evaluate the methods used
for consistency with standard accounting practices, validate calculations, and where appropriate,
quantify the error and identify a correction. Criteria for validation and classification of supporting
records and reporting errors are described below.
Validation results for each audited data entry will be recorded by auditors in a database that is
appropriately structured for import into a relational database by PSMFC. Conformance to database
standards and attention to data integrity in recording and conveyance of audit result data to PSMFC is a
critical element in the proposal evaluation. In addition, the auditor will provide a document summarizing
the methods and results, including any additional quantitative and/or qualitative findings not captured
in the audit results database.
The Auditor shall not complete and/or submit Economic Data Reports (EDR) as the designated
representative of an EDR submitter while under contract for this work. In the event that the Auditor
knowingly provides information for a client for the express purpose of reporting in an EDR, the Auditor
must disclose this fact when samples are being selected for this audit.

Selection of audits and data preparation:
•
•
•

NMFS will analyze the EDR data submitted for outliers and other data anomalies and select
records on this basis for audit verification (outlier selection).
PSMFC will identify for-cause audit selections.
Conditional on the number and range of outlier and for-cause selection, NMFS will select EDR
data items from each respective EDR form and generate a random selection of corresponding
EDR records to supplement the outlier and for-cause sets.
o Use of randomized audit selection is discretionary.
o Entities that received a “fail” audit letter for the previous year may be subject to forcause selection for audit, with consideration given to mitigating circumstances.
o All audit selections will include a description of the reason for selection (e.g., “outlier:
value is global outlier for variable, 10x greater than next highest reported value for
2017”, “for-cause: fail determination in 2016”, etc.). For selected entries where original
value is reported as 0, nonnumeric (“N/A”), or null (blank), this will include guidance re:

Economic Data Reporting – Discussion Paper, April 2019

92

D5 Economic Data Reporting
APRIL 2019

•

•
•

•
•

logically valid entries for original and/or corrected value and corresponding validation
codes, e.g.:
▪ Is 0 or N/A a plausible value for the variable
▪ For “N/A” or blank entries, if validation confirms the original entry, should
corrected value be recorded as 0 (Validation code =1T), or “N/A” (Validation
code = 10).
The complete set of audit selections will be limited to between 4 and 15 items from each EDR
form, for a total of no more than 40 distinct data items across all three sectors, and 75 to 800
total data entries selected.
PSMFC will compile the selected EDR records into a tabular data report to be used by the
Auditor to record validation results for each record.
PSMFC will prepare an archive of the complete EDR record for each submitter included in the
audit selection, provide contact information for all EDR submitters selected, and assist with
making arrangements between the Auditor and EDR submitters as needed.
PSMFC/NMFS will provide letter templates for auditor to use in preparing formal notices for
mailing to EDR submitters (i.e., initial audit notices and submitter feedback letters).
PSMFC and NMFS will consult with the Auditor to determine the appropriate types of
documentation and degree of supporting records detail that are sufficient and appropriate basis
the verify selected EDR variables.

Data verification and analysis:
•

•

•

•
•

The Auditor will coordinate preparation and mailing of written audit notices (using templates
provided) to solicit supporting information from the selected EDR submitters for selected data
entries.
The Auditor will monitor submitter response to audit notices, organize and manage all materials
and information received from submitters (including documentary materials and information
conveyed verbally), and conduct additional correspondence with the submitters as needed to
obtain additional records and information sufficient to complete the verification process.
The Auditor will analyze the records and other supporting information provided by submitters
and apply generally accepted accounting principles to evaluate the quality of supporting
information according and verify the accuracy of reported values. For each data value selected
for audit, data verification procedures are the following:
o Evaluate the quality of supporting records and other documentation supplied as the
basis for data verification;
o Evaluate accounting/recordkeeping methods, calculations, logical considerations,
and/or other factors used by the submitter to derive or approximate the reported value
from supporting documentation;
o Evaluate the accuracy of the original reported value;
o Where the original value cannot be verified and/or is determined to be inaccurate,
consult with the submitter to obtain corrections, additional records and other
information as needed to identify the accurate (verified) value, as confirmed by the
submitter.
The Auditor will record the evaluation and verification results for each value audited in the Audit
results database, using the Support analysis codes framework (specified in Table 4 below).
The Auditor will prepare a final project report for public distribution, summarizing audit
procedures and administrative procedures, summary of results, a general discussion of notable
issues identified during the course of the audit including problems encountered by submitters

Economic Data Reporting – Discussion Paper, April 2019

93

D5 Economic Data Reporting
APRIL 2019

•

with EDR forms and supporting records, audit procedures under the SOW, and
recommendations for modifications of EDR data collection and audit procedures for the future.
The Auditor will coordinate preparation and mailing of Submitter Feedback Letters (following
consultation with PSMFC and NMFS and using templates provided) to notify audited EDR
submitters of audit results for their selected data, including summary audit finding (Wellsupported/Semi-supported/Fail), by-item verification results for their selected data, suggestions
for improved EDR reporting and record keeping, and notice of any failure of the submitter to
comply with verification audit requirements.

Deliverables:
Progress reports and invoices
• The Auditor will submit verbal or written updates to PSMFC and NMFS every two to three weeks
to validate work and resolve questions or issues encountered.
• Progress reports will act as intermittent deliverables to ensure quality of work and to address
any problems that may arise throughout the project.
• Charges for expenditures should be listed on the invoice as a separate line item.
• Final invoice should be marked “Final”.
Audit results database
• Upon completion of all audit validation procedures, validation results will be delivered to PSMFC
in an electronic database table, consolidating results for all EDR types (CP, CV, and shoreside
processor) in one table, listing each EDR entry selected for audit by booklet_id, table name,
variable name, cause for selection, and original reported value (all columns populated in the
table of audit selections provided by PSMFC), with Original Support Analysis Code, Validated
Value, and Validated Support Analysis Code based on Auditors findings.
o Table below is an example of the tabular format of audit results data to be provided to
PSMFC by the Auditor.
o Depending on database software available to the Auditor (Microsoft Access, Excel, etc.),
PSMFC will work with the Auditor to provide a file structure and format for recording
audit results to ensure data integrity
Table 3: Format of tabular audit results data
BookletID Table name Variable
Cause for Original Original Validated Validated
name
selection Value
Support Value
Support
Analysis
Analysis (Code
(Code
0,1,5,7,9 or
0-10)
10)
2010V4000A

5.2 Capital
Total_
High
250,456 6
254,005 5
Expenditures expenditure global
outlier
o PSMFC will provide the contact information, BookletID, Table name, Variable name
(description of data item as it is listed in the EDR and referenced in the EDR database),
and Original Value of each variable to be audited.
o The Auditor will provide the coded “Original Support Analysis” (codes 0-10), “Validated
Value” identified by auditors (equaling either the original value or a corrected value) and
confirmed by the submitter, and the coded “Validated Support Analysis” (codes
0,1,5,7,9 or 10).
o Support analysis classification codes are shown in Table below.

Economic Data Reporting – Discussion Paper, April 2019

94

D5 Economic Data Reporting
APRIL 2019
Table 4: Support analysis codes
Audit
codes

Documented
support for
Verified Value

Validation result

Measurement
error effect type

Correction

0*

Documented
support for
Original
Value
No

No

None

No

1*

Yes

Yes (same as
original)

None

No

1T*

Yes

None

No

2

Yes

Respondent

Yes

2T

Yes

Observable typographic error on the respondent’s part

Respondent

Yes

3

Yes

Misinterpretation of question

Yes

5*

Yes

Yes (same as
original)

Questionnaire wording
Questionnaire specification +
Respondent
Questionnaire specification

Yes

4

Yes (same as
original)
Yes (same as
original)
Yes (same as
original)
Yes (same as
original)
Yes (same as
original)

Respondent did not respond to audit request for supporting records;
represents noncompliance.
No error; reported value is clearly substantiated by compete records.
[Zero handling: Original value is “0”: Correct value = 0 (no correction).
Original and corrected code = 1.]
Original value is blank or ‘N/A’: Correct value = 0 (not counted as error
for fail letters)
Calculation error

6

Yes

Yes (updated)

Yes

7*

No

No

8

No

Yes (new)

9*

No

No

Questionnaire specification
Questionnaire specification +
Respondent
Questionnaire specification +
Respondent error
Respondent

Estimate is based on original documentation but flawed
assumptions/logic
Data cannot be reported precisely as specified in EDR form and must
be estimated; estimate is based on appropriate documentation and
sound assumptions/logic and is considered validated
Original value was reported correctly based on original documentation,
but corrected based on updated documentation
Original value is unsubstantiated, and no validated value can be
substantiated based on available records; original value is confirmed as
representing good faith "best guess"
Original value is unsubstantiated; correction is based on new
documentation
Original value is blank (missing data); available information
contraindicates 0 or N/A and no validated value can be confirmed
based on available records. If applied to Validated Support Analysis,
this indicates a submitter’s good faith inability to resolve a nonresponse to a verified value. Otherwise, apply Code 0.

Economic Data Reporting – Discussion Paper, April 2019

95

Yes

No

No

Yes

No. Auditor leaves corrected
value blank and enters 9 for
Validated Support Analysis
**PSMFC enters -9 values in
database UR notes to indicate
known item nonresponse.

D5 Economic Data Reporting
APRIL 2019
Audit
codes

10*

Document

Documented
support for
Original
Value
No

Documented
support for
Verified Value

Validation result

Measurement
error effect type

Correction

No

Item "Not Applicable" to vessel

None

Yes

Yes (same as
original)

Respondent

No **PSMFC enters -7 values in
database UR notes to indicate
non-applicability of the data
element.
Yes

Administrative

Yes

Primary key error is defined as an error in the categorization of the
reported value by a stratifying variable (e.g., fishery code, location
code, product code, etc.), rather than an error in the reported value
itself. For example, a submitter accidentally records EAG fishery activity
in the row for the WAG fishery.
DocuYes
Yes (same as
Administrative errors should be documented in such a way that PSMFC
ment
original)
can identify where corrections to the database need to be made; and
NMFS can identify the respondent’s original reported value as distinct
from any error introduced by the administrative data entry process.
*denotes audit codes that should be used to classify corrected values

Regarding “blank” (missing), “0”, and “N/A” responses:
In cases where a null (blank), “0”, or “N/A” original value is selected for audit, the validation objective is to distinguish and resolve cases where the respondent intended to
indicate a 0 or N/A response (which are attributed to incomplete instructions in the questionnaire, and coded 1T and 10, respectively), and cases of respondent error where a
non-null/nonzero response can be validated. In such cases, audit codes 2,3,4,6, or 8 should be used to characterize the type of response error indicated for the original (null)
value, and an appropriate audit code applied to the verified value. If the respondent is responsive to the audit request but is unable to resolve the null value (e.g., due to loss
of accounting records) to confirm a verified value, code 9 should be applied to both original and verified support code. If no response to an audit request is provided
regarding a null original value, code 9 should be entered as the original support code, validated value left blank, and code 0 entered as the validated support code to indicate
audit noncompliance.

Economic Data Reporting – Discussion Paper, April 2019

96

D5 Economic Data Reporting
APRIL 2019
Final project report
The Final Project Report to be prepared by the Auditor provides a brief summary of verification audit
methods, results, and general findings, and is intended for public distribution for PSMFC. The following
outlines the organization of the report contents:
•
•

A summary of background, description of verification audit methods and procedures
Summary of audit results, organized by EDR type, providing
o Tabulated summaries of audit results for each selected variable (aggregated to protect
confidential submitter information) and general description of findings regarding quality
of records provided for support reported values (e.g., 3rd party documentation vs.
informal description of data source or estimation). Figure 1 below is an example of
presentation of summary audit results for one EDR data item (variable) in the final audit
report document
Figure 1: Example of summary audit results for one EDR data item (variable)

o

•

•

•

Summary or feedback by submitters regarding time required to 1) complete and submit
the EDR form, and 2) comply with verification audit requirements (i.e., collect and
deliver requested records, communicate with auditors by phone, confirm verified data
values).
A general discussion of notable issues identified during the course of the audit, including:
o General compliance with audit procedures (were submitters forthcoming timely
response to all requests for information, were multiple contacts required to obtain an
initial response or to obtain supplementary information)
o General patterns in validation errors, e.g. directional bias in original values (consistently
higher/lower than verified value), or general inconsistency of common recordkeeping
practices with auditor expectations
o Difficulty with particular questions in the EDR (e.g. interpretation or understanding of
the information to be reported, ability to identify an accurate value based on available
records)
Discussion of any significant difficulties encountered with audit procedures as specified in the
SOW, and recommendations for modifications of EDR data collection and audit
procedures/SOW for the future
Examples of the most recent final reports are located at:
o http://www.psmfc.org/alaska_crab/documents/2015_2016_audit_results.pdf
o

http://www.psmfc.org/am80edr/documents/2015_2016_audits.pdf

Economic Data Reporting – Discussion Paper, April 2019

97

D5 Economic Data Reporting
APRIL 2019
Submitter feedback letters
In conference with PSMFS & NMFS, the results of the audit will be reviewed and NMFS will determine he
number or errors and types of errors that signify where the break lies to determine who receives a Wellsupported/Semi-supported/Fail letter.
•
•
•

Well-supported/Semi-supported/Fail letters will be reviewed and updated by NMFS if needed.
Well-supported/Semi-supported/Fail letters include the audited results for each company’s EDR
in a % error format so as not to release confidential data.
The auditors will then mail letters with audit results to the audited companies and provide
PSMFC with an electronic copy of letter they were mailed (well supported, semi supported,
failed audit) for the record and for future possible enforcement action.

Records management of submitter-provided documents
After the data validation is concluded, all supporting documents provided to Auditor will delivered by
secure carrier to PSMFC for archiving.

Hours & Expenses
Below is the estimated hours to bill to PSMFC for conducting this work.
Table 5: Time and Cost for BSAI Crab EDR Audits
Professional
Andy Maffia

Title and
Rate
Partner
$400/hr

Responsibilities
•
•
•
•
•

Signs Contract
Develops audit methodology and work plan
Supervises and reviews all audit work and analysis
Serves as liason/contact and participates in meetings
with PSMFC
Reviews and directs writing of all reports

Estimated
Hours (%)
15 (15%)

Kristen Guzman

Manager
$300/hr

•
•
•

Oversees and assists in individual audits
Audits information received and answers direct questions
Reviews work performed by staff

32 (31.5%)

Jonathan Hu

Staff
$145/hr

•
•

Develops request for information
Contacts submitters (outlier and random) to solicit
information
Audits information received based upon developed work
program
Travels as necessary to validate data

54(53.5%)

•
•

Total hours for each year’s audits 101
Blended Rate $276.92
Total for 2017 BSAI Crab EDR audits $28,000
Payment for services shall not exceed $28,000 to begin work on the audit on 2017 BSAI Crab EDRs.
Invoices should include number of hours charged to project broken out by staff hours for recordkeeping
and budgeting purposes.

Economic Data Reporting – Discussion Paper, April 2019

98

D5 Economic Data Reporting
APRIL 2019
Out-of-pocket expenses will be billed separately based upon actual costs incurred. These costs include:
•

Travel costs to attend meetings with Commission personnel based on federal guidelines
for mileage.
• Travel costs to audit selected vessels, if applicable, including airfare or other travel
costs, rental car, hotel and per diem for days out-of-town. If possible, we could
coordinate this travel with travel for other clients, sharing the applicable costs.
• Postage, as applicable.
Aldrich CPAs + Advisors LLP will work closely with PSMFC to determine the appropriateness and need to
travel to individual data submitters to audit the information collected on the EDR. The auditor expects
to minimize these costs when possible and to use fax, scan, email, and other forms of communication to
validate the data.

Timeline
•

•

August/September
o Initial planning meeting & contracts put in place (letter of intent)
NMFS (in consultation with PSMFC) determines outlier, for-cause, and random audit selections
from the population of EDR submissions.
o PSMFC provides auditor with outlier and random audit contact information.
o PSMFC & NMFS compiles data from selected EDRs into a report that auditor will audit
(Excel format).
October-November
o Auditor prepares audit notification letters for each entity that explains the process and has
the list of variables (both random and outlier) selected.
o Auditor sends letters to audit entities notifying them of selection and requesting supporting
documentation of selected variables.
o Outlier variables may be different from random audit variables, so additional information
may be requested of random audit entities.
o The owner or leaseholder must respond to inquiries by the auditors within 20 days of the
date of issuance of the inquiry so notifications should be made via certified return receipt
mail.
o Random and For Cause Audit supporting documentation due
o Auditor follows up with entities who do not respond or provide inadequate documentation
o Auditor reviews and verifies selected variables based on supporting information provided
o Auditor follows up with submitters on missing, inaccurate, and unsupported original entries
to validate and confirm a corrected value;
▪ If the submitter is uncertain re: how to calculate or estimate a value correctly, the
auditor can provide suggestions based on methods used by comparable submitters.
▪ The auditor should probe to determine if the correction of an invalidated original
value potentially requires correction of one or more associated entry(ies) in the
submitter’s EDR form, the auditor should request additional supporting records as
needed and add corresponding rows to the Audit results database.

Economic Data Reporting – Discussion Paper, April 2019

99

D5 Economic Data Reporting
APRIL 2019
o

•

Auditor informs PSMFC of any companies that have not complied with the audit request and
may need NMFS enforcement action.
December
o Analysis completed
o Data analysis, process report and audit participant feedback letter drafts due to NMFS and
PSMFC for Random and Outlier audits
o Final data analysis and report drafts due to NMFS and PSMFC
o Conference call to discuss results and pass/fail letters that will go out.
o Auditor sends feedback letter for participation to all vessels.
o Auditor to update the Supported/Unsupported categories with PSMFC &NMFS by end of
month if needed

Economic Data Reporting – Discussion Paper, April 2019

100