U.S. Department of Commerce
National Oceanic & Atmospheric Administration
U.S. Caribbean Commercial Fishermen Census
OMB Control No. 0648-0716
Abstract
This is a request for revision and extension of a currently-approved collection that intends to gather cultural, economic, and social information on small scale fishers operating in the United States Caribbean, which includes the Commonwealth of Puerto Rico and the U.S. Virgin Islands Territory. In total, the National Marine Fisheries Service (NMFS) aims to survey 1,500 fishers. The data collected will be used to support current management actions by providing up-to-date socio-economic data, which will be used: a) to develop fishery management plans and amendments (e.g., human and economic environment descriptions, development of social indicators), and b) to conduct analyses of regulatory proposals (e.g., effect analyses). The revisions are primarily due to surveying and funding setbacks caused by the adverse impact of recent hurricanes and the COVID-19 pandemic as well as minor revisions to the attitudinal questions section.
Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.
The National Marine Fisheries Service (NMFS) proposes to conduct a survey of small scale fishers operating in the United States (U.S.) Caribbean, which includes the Commonwealth of Puerto Rico and the U.S. Virgin Islands (U.S.V.I.) Territory. The proposed socio-economic study will collect information on demographics, fishing and marketing practices, capital investment on fishing vessels, gear, and equipment, and miscellaneous attitudinal questions such as perception of household financial well-being, and main socio-economic affecting the fishery including those caused by climate change, and natural hazards (e.g., hurricanes, tropical storms, earthquakes). The data collected will be used for: a) to develop fishery management plans and amendments, which need up-to-date descriptions of the human and economic environment (including the development of social indicators), and b) to conduct socio-economic analyses of regulatory proposals (e.g., effects analyses).
The paucity of up-to-date socio-economic data is a significant hurdle in the region. Trip tickets, which mainly collect landings and fishing effort (e.g., gear used, time spent fishing, etc.) data, are the only regular fishery data collection in the region. Thus, supplemental data collections are needed to collect cultural, economic, and social information for the development of amendments to fishery management plans and for the evaluation of management proposals. These data are required to support the Agency’s conservation and management goals, to strengthen and improve decision-making, and to satisfy legal mandates under the Reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), the Regulatory Flexibility Act (RFA), the Endangered Species Act (ESA), and the National Environmental Policy Act (NEPA), Executive Order 12866 (EO 12866), and other pertinent statutes. In addition, current socio-economic data is needed to support NOAA’s various strategic initiatives such as NOAA’s climate regional action plans, natural disaster assessments (e.g., hurricanes, tropical storms), etc.
The MSA mandates that conservation and management measures prevent over-fishing and obtain an optimum yield (OY) on a sustained basis. It also established new requirements to end and prevent overfishing with the use of annual catch limits (ACLs) and accountability measures (AMs). Moreover, MSA requires that conservation and management measures take into account the importance of fishery resources to fishing communities in order to: (a) provide for the sustained participation of such communities, and (b) to the extent practicable, minimize any adverse economic impacts on such communities.
The need and the authorization to collect these socio-economic data are found in the MSA, 16 U.S.C. 1801 et seq., the RFA, 5 U.S.C. 601 et seq., the NEPA, 42 U.S.C. 4372 et seq., and EO 12866. The MSA states that the collection of reliable data is essential to the effective conservation, management, and scientific understanding of the fishery resources of the United States. The nation's fisheries should be "conserved and maintained so as to provide OYs on a continuing basis". Furthermore, eight of the ten National Standards under the MSA, which provide guidance to the regional fishery management councils, have implications for economic analyses. For example, under section 303 (a) (9) of the MSA, a fishery management plan must include a Fishery Impact Statement (FIS), which assesses, specifies, and describes the likely effects of the conservation and management measures on participants in the fisheries being managed, fishing communities dependent on these fisheries, and participants in fisheries in adjacent areas.
Under the RFA, the Small Business Administration needs a determination of whether a proposed rule has a significant impact on a substantial number of small entities that are to be directly regulated. For RFA purposes, one of the criteria to determine significant economic impact involves an assessment of the change in short-term accounting profits for small entities. The NEPA requires a determination of whether Federal actions significantly affect the human environment. This requires a number of socio-economic analyses including the impact on entities that are directly regulated and those that are indirectly affected. In addition, EO 12866 mandates an economic analysis of the benefits and costs to society of each regulatory alternative considered by the fishery management councils, and a determination of whether the rule is significant.
Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.
One-time, voluntary surveys will be used to collect socio-economic information from U.S. Caribbean small-scale fishers. This will be a collaborative effort with local fishery agencies, namely Puerto Rico’s Department of Natural and Environmental Resources (PR DNER) and U.S.V.I.’s Department of Planning and Natural Resources (U.S.V.I. DPNR Division of Fish and Wildlife).
We anticipate that interviews will be mainly conducted in-person depending on the local COVID-19 conditions. If it’s not possible, we will conduct them over the telephone as needed to minimize health risks and other burdens to fishers. The proposed survey will collect socio-economic data which otherwise would be unavailable. NMFS and the Caribbean Fishery Management Council (CFMC) will use this information to monitor, explain and predict changes in the socio-economic performance commercial fisheries. This will increase their ability to meet the requirements for socio-economic analyses, and to allow better-informed conservation and management decisions on the use of living marine resources and marine habitat in federally managed waters.
The proposed socio-economic survey will collect information on the following: 1) demographic background, 2) fishing and marketing practices, 3) capital description and investment in vessels, gear, and fishing equipment, and 4) miscellaneous attitudinal questions. The surveys will be available in English and Spanish to minimize the burden on local respondents.
The ‘demographic background’ section elicits miscellaneous demographic information such as fisherman’s age, number of dependents, and formal education achievement. This information is useful to characterize the fisher populations. This type of data is often missing in our databases.
The ‘fishing and marketing practices’ section probes about the fisherman’s role in the fishing operation (captain vs. crew), fishing experience, participation level (e.g., full-time vs. part-time), main gear types used, main species targeted, time spent on fishing and fishing related activities (e.g., fixing gear, marketing), crew size, participation in fishing cooperatives, main launching sites, and type of fishing license held. It also asks about the main markets. NMFS uses this information to understand the impact of regulatory actions on fishing communities, since fishing business and the household dynamics in small-scale fishery are often intricately entwined.
The ‘capital description and investment in vessels, gear, and fishing equipment’ section inquires about vessel ownership, vessel characteristics (e.g., length, age, type of hull, number of engines and horsepower), electronics and fishing equipment owned (e.g., GPS, fish finders, winches), counts and description of various gear types (e.g., nets, hook and line, pots and traps) and approximate value of the capital invested in the fishing operation. NMFS uses these values to calculate the economic opportunity costs of capital goods and other assets that it in turn uses to calculate net economic benefits to the nation of industry participation. NMFS also uses them for conducting financial analyses as required by the RFA.
The ‘miscellaneous attitudinal questions’ section gathers information on their perceptions about the state of the resource and coral reefs, easiness to find employment outside fishing, household financial well-being and main socio-economic affecting the fishery including the impact of climate change and climatic (e.g., hurricanes) and non-climatic stressors (e.g., COVID-19). These types of questions are needed to understand the general business climate in which these small-scale fleets operate. Additionally, they provide a context that helps to distinguish between impacts associated with fisheries management from those of the general economy and/from environmental shocks.
The overall collection requirements have not changed; however, additional questions have been added to better understand the impact of external shocks such as climate change.
The information collected will be disseminated to the public and used to support publicly disseminated information. NOAA Fisheries Service will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy. The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subject to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.
Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.
The socio-economic data needed will be primarily collected by means of in-person interviews (and/or telephone interviews in cases where it is easier for respondents) because they are more versatile and less burdensome than mail surveys. We do not anticipate using online questionnaires because of the limited access to internet in some parts of the U.S. Caribbean.
Nonetheless, we plan to require the contractor (to be determined) to use tablets or other electronic devices connected to an online platform, which will allow interviewers to complete and securely upload the surveys to a cloud server. Where Wi-Fi is available, survey results will be uploaded to an online platform in real time; otherwise, survey results were saved on the tablet and uploaded once internet access became available. The use of the online programs has been shown to be helpful in reducing set-up and administration costs, reducing transcription errors, and providing ready access to the data.
Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Question 2
We contacted the CFMC to inform them about our intention to collect socio-economic data and to inquire about other on-going or prospective data collections in the area. The Council noted that they were not planning nor they were aware about any current or planned data collections that targeted small-scale fishers other than the recent COVID-19 assessment efforts. The last small-scale fisher census conducted in U.S.V.I. was done in 2016 (Kojis et al. 2017) and the last one conducted in Puerto Rico was done 2018/19 (no reports are presently available).1 NMFS strives to update their fisher censuses every 5 years; however, may try to conduct them more frequently if severe shocks (such as hurricanes) affect local fisheries.
If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.
Most commercial fishing operations in the U.S. Caribbean are small businesses, many family owned. We have taken several steps to minimize the burden on these small businesses. First, the surveys will be voluntary. Second, surveys will be available in English and Spanish to reduce the burden on non-English speakers. We will make instruct the contractor (to be determined) to hire bilingual interviewers (Spanish and English). Third, the interviews will be conducted at times and places that are most convenient to fishers to minimize potential disruptions to their fishing operations.
Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.
If the proposed information were not collected (or collected less frequently), then NOAA and the CFMC would not be able to adequately satisfy the legal requirements put forth by the MSA, NEPA, and EO 12898. These mandates require regional fishery management councils to establish conservation and management measures that provide sustained fishing community participation and to minimize, to the extent possible, adverse economic impacts on such communities (i.e., National Standard 8 of the MSA). Furthermore, these requirements also mandate regional fishery management councils to establish conservation and management measures using the best scientific information available.
The absence of up-to-date socio-economic information would limit the Agency’s ability to describe the human and economic environment in fishery management plans and amendments, to estimate the socio-economic impacts of management proposals, and to examine the performance of existing regulations. Hence, the benefits and costs of regulatory proposals would continue to be debated without sound data. Current information would also reduce the likelihood of unforeseen adverse consequences. In addition, the availability of current information would minimize the likelihood of court challenges on the grounds of deficient analysis. Last, the collection of detailed socioeconomic data will allow fishery managers to make timely and better-informed decisions by having the best scientific information available.
Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.
There are no special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.
The information collection is voluntary. Therefore, it does not require respondents to: 1) report information to the Agency more often than quarterly; 2) prepare a written response; 3) submit any documentation; 4) retain any records; or 5) submit proprietary trade secret, or other confidential information.
NMFS has demonstrated that it has instituted procedures to protect information confidentiality to the extent permitted by law. This information collection is in connection with a statistical survey that is designed to produce valid and reliable results that can be generalized to the universe of study. This information collection uses statistical data classifications reviewed and approved by OMB. This information collection includes a pledge of confidentiality supported by disclosure and data security policies, which are consistent with the pledge and which do not unnecessarily impede sharing of data with other agencies for compatible confidential use.
If applicable, provide a copy and identify the date and page number of publications in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
A Federal Register notice soliciting public comment on the proposed data collection was published on February 23, 2021 (86 FR 10939). No public comments were received.
We consulted with CFMC about the availability of socio-economic data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. They reported no issues regarding the availability of data, frequency of collection, the clarity of instructions and reporting format, or the requested data elements. Moreover, they stressed the importance of continuously updating previous fisher census since it’s the only regular fisheries-related socio-economic data collection in the region. These censuses have taken place every 5-7 years depending on ground and funding conditions.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
No payments or gifts will be provided to respondents.
Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.
As stated on the survey instruments, respondents will be advised that any information provided will be considered private and will be treated as confidential in accordance with NOAA Administrative Order 216-100, Confidential Fisheries Statistics and section 402(b) of the MSA (16 U.S.C. 1881, et seq.).
The survey forms will contain the following language:
“We appreciate the confidential nature of the data being collected by this survey. NMFS will handle individual survey data as confidential business information and a form of protected personal information and will maintain the confidentiality of the information consistent with legal authorities available to it, including but not limited to the Privacy Act (5 U.S.C. Section
552a) and the Trade Secrets Act (18 U.S.C. Section 1905). NMFS will protect individual survey data from public disclosure to the extent permitted by law and it has instituted procedures to provide that protection. DEPARTMENT OF COMMERCE/NOAA Privacy Act Systems of Records 6 and 19, Fishermen’s Statistical Data and Permits and Registrations for United States Federally Regulated Fisheries, respectively, cover the information collected for these fisheries.”
Neither a SORN nor a PIA will be required.
Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.
With
exception of race/ethnicity questions, survey does not inquire about
sexual behavior and attitudes, religious beliefs, disability status,
or other similar matters of a personal and sensitive nature.
The inclusion of race/ethnicity questions is required to identify vulnerable communities that could be impacted by regulatory alternatives and issues related to socio-cultural background, particularly in commercial fisheries with diverse backgrounds. Hence, race may be useful when analyzing economic impact on communities due to conservation and management measures as required under National Standard 8 of the MSA [MSA Section 301(a)(8))]. Information collections involving a question on race follow the OMB Standards for the Classification of Federal Data on Race and Ethnicity.
Provide estimates of the hour burden of the collection of information.
For this one-time voluntary survey, we estimated that the number of respondents will be 1,500 and the time per response will be about 1/2 hour. Hence, we are requesting 750 burden hours under a full funding scenario. We also present a contingent scenario were we only receive 50% funding which would only require 375 burden hours (Table 1). The 30 minute burden per response includes the time reading of instructions, reviewing the questions, and completing the survey. This estimate is based on the type of questions asked, length of the survey instrument, and the Agency’s experience conducting similar surveys. The 30 minute burden estimate is consistent with previous fisher census efforts (e.g., Matos-Caraballo and Agar, 2011; Kojis et al., 2017)2.
Table 1 shows estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. For the hourly wage rate for respondents, we used the average of the US national hourly mean wage rates for 1) Captains, Mates, and Pilots of Water Vessels ($42.03, occ_code 53-5021) and 2) Farming, Fishing, and Forestry Occupations ($15.07, occ_code 45-0000) at https://www.bls.gov/oes/current/oes_nat.htm for 2019. We used the average for those two occupation codes for several reasons. First, there is not an occupation code specifically for the captains of fishing vessels. Second, the equivalent of an hourly wage rate varies among fisheries and captains. Third, we believe that the average of the two hourly mean wage rates is a reasonable proxy for the captains of fishing vessels. Finally, that average hourly wage of $28.55 is roughly consistent with the $25.25 US national hourly mean wage rates for First-Line Supervisors of Farming, Fishing, and Forestry Workers (occ_code 45-1011).
Table 1: Estimates of the Number of Respondents and Burden.
Information Collection |
Type of Respondent (e.g., Occupational Title) |
#
of Respondents/year |
Annual
# of Responses / Respondent |
Total
# of Annual Responses |
Burden
Hrs / Response |
Total
Annual Burden Hrs |
Hourly
Wage Rate (for Type of Respondent) |
Total
Annual Wage Burden Costs |
Full funding scenario (100%) |
||||||||
USVI Census |
Captains and Fishers |
260 |
1 |
260 |
0.5 |
130 |
$28.55 |
$3,712 |
Puerto Rico Census |
Captains and Fishers |
1,240 |
1 |
1,240 |
0.5 |
620 |
$28.55 |
$17,701 |
Totals |
|
|
|
1,500 |
|
750 |
|
$21,413
|
Partial funding scenario (50%) |
||||||||
USVI Census (St. Thomas) |
Captains and Fishers |
113 |
1 |
113 |
0.5 |
57 |
$28.55 |
$807 |
USVI Census (St. John) |
Captains and Fishers |
6 |
1 |
6 |
0.5 |
3 |
$28.55 |
$43 |
USVI Census (St. Croix) |
Captains and Fishers |
141 |
1 |
141 |
0.5 |
71 |
$28.55 |
$1,006 |
Puerto Rico Census (East coast) |
Captains and Fishers |
251 |
1 |
251 |
0.5 |
126 |
$28.55 |
$1,792 |
Puerto Rico Census (East coast) |
Captains and Fishers |
317 |
|
317 |
0.5 |
159 |
$28.55 |
$2,263 |
Puerto Rico Census (East coast) |
Captains and Fishers |
242 |
|
242 |
0.5 |
121 |
$28.55 |
$1,727 |
Puerto Rico Census (East coast) |
Captains and Fishers |
430 |
|
430 |
0.5 |
215 |
$28.55 |
$3,069 |
Totals |
|
|
|
750 |
|
375 |
$7,623 |
$10,706 |
Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).
There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection under both the full and partial funding scenarios (Table 2).
Table 2: Estimates of Capital/Start-Up or Ongoing Operation/Maintenance Costs.
Information Collection |
# of Respondents / Year |
Annual # of Responses / Respondent |
Total # of Annual Responses |
Cost Burden / Respondent |
Total Annual Cost Burden |
(a) |
(b) |
(c) = (a) x (b) |
(h) |
(i) = (c) x (h) |
|
USVI Census |
260 |
1 |
260 |
0 |
0 |
Puerto Rico Census |
1,240 |
1 |
1,240 |
0 |
0 |
TOTALS |
1,500 |
|
1,500 |
|
0 |
Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.
We anticipate that the contractor cost for both data collections and analyses will be around $140,000 assuming 750 burden hours and about $70,000 for 375 burden hours (Table 3). This estimate covers the expenditures for the following activities: training of interviewers, purchase of tablets, travel, data collection, data entry and quality control, and report writing.
In addition to contractor expenses, federal costs include NMFS staff time and travel. The NMFS staff will be responsible for developing and administering the contract, monitoring performance and reviewing the final report. We estimate that the cost of NFMS supervision will be about $49,052/year plus $6,000 for travel. Thus, the total annualized cost to the federal government would be $195,052 under a full funding scenario and $125,052 under a partial (50%) funding scenario (Table 3).
Table 3: Federal Government Cost Estimates.
SEFSC \Cost Descriptions |
Grade/ Step |
Loaded Salary Cost |
% of Effort |
Fringe (if Applicable) |
Total Cost to Government |
Federal Oversight |
ZP-4 |
$210,219 |
7% |
|
$14,015 |
Data collection/analysis |
ZP-4 |
$210,219 |
14% |
|
$29,431 |
Administrative |
ZP-4 |
$210,219 |
3% |
|
$5,606 |
Some other duty |
|
|
|
|
$0 |
|
|
|
|
|
|
Contractor Cost (full funding) |
|
|
|
|
$140,000 |
Contractor Cost (partial funding, 50%) |
|
|
|
|
$70,000 |
|
|
|
|
|
|
SE Region |
|
|
|
|
|
Travel |
|
|
|
|
$6,000 |
Other Costs: |
|
|
|
|
|
Printing/Postage |
|||||
|
|
|
|
|
|
TOTAL (full funding) |
|
|
|
|
$195,052 |
TOTAL (partial funding) |
|
|
|
|
$125,052 |
Explain the reasons for any program changes or adjustments reported in ROCIS.
There are no changes to the information collection since the last OMB approval other than minor revisions to the attitudinal questions section.
Information Collection |
Respondents |
Responses |
Burden Hours |
Reason for change or adjustment |
|||
Current Renewal / Revision |
Previous Renewal / Revision |
Current Renewal / Revision |
Previous Renewal / Revision |
Current Renewal / Revision |
Previous Renewal / Revision |
||
Puerto Rico Census |
1,240 |
1,500 |
1,240 |
1,500 |
620 |
750 |
No change in overall collection burden, changes reflect an administrative action to give additional granularity into the two areas where the survey will be conducted. No new requirement is reflected. |
USVI Census |
260 |
NA |
260 |
NA |
130 |
NA |
No change in overall collection burden, changes reflect an administrative action to give additional granularity into the two areas where the survey will be conducted. No new requirement is reflected. |
Total for Collection |
1,500 |
1,500 |
1,500 |
1,500 |
750 |
750 |
|
Difference |
0 |
0 |
0 |
|
|||
Information Collection |
Labor Costs |
Miscellaneous Costs |
Reason for change or adjustment |
||
Current |
Previous |
Current |
Previous |
||
Puerto Rico Census |
$3,712 |
NA |
0 |
0 |
Labor costs not previously calculated |
USVI Census |
$17,701 |
NA |
0 |
NA |
Labor costs not previously calculated |
Total for Collection |
$21,413
|
NA |
0 |
0 |
|
Difference |
$21,413 |
0 |
|
||
For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.
We anticipate that the information collected will be disseminated to the public or used to support publicly disseminated information. NMFS designed the information collection to yield data that meet all applicable information quality guidelines. Information in tabulation form will be disseminated to the public in a NOAA Technical Memoranda similar to Kojis et al. (2017). Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554. When writing final reports and publishing the findings of this research, tabulations of individual responses will occur at a high enough level of aggregation so that data for no single individual can be identified. These Technical Memoranda will be shared online with internal and external partners.
The anticipated timeline for the data collection (contingent on funding) as follows.
Data collection period for USVI census: Sept. 2022-Nov. 2022.
Technical Memoranda creation: Completed June. 2023.
Data collection period for Puerto Rico: Sept. 2023-Nov. 2023.
Technical Memoranda creation: Completed June. 2024.
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
The OMB control number and expiration date will be displayed on survey forms.
Explain each exception to the certification statement.
The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
1 Kojis, B., N. Quinn, and J. Agar 2017. Census of licensed commercial fishers of the U.S. Virgin Islands (2016). NOAA Technical Memorandum NMFS-SEFSC-715, 160 p. doi:10.7289/V5/TM-SEFSC-715
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Sarah Brabson |
| File Modified | 0000-00-00 |
| File Created | 2021-05-31 |