SUPPORTING STATEMENT
U.S. Department of Commerce
National Oceanic & Atmospheric Administration
Data Collections to Support Comprehensive Economic and Socio-Economic Evaluations of the Fisheries in Regions of the United States Affected by Catastrophic Events
OMB Control No. 0648-0767
The National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service (NMFS or NOAA Fisheries) is requesting revisions to a currently approved information collection, which will allow NMFS to continue to collect information required to conduct the mandated economic and socio-economic evaluations of catastrophic regional fishery disasters (see SEC. 315 (c) of the Magnuson-Stevens Fishery Conservation and Management Act (MSA)). Since 1995, the Secretary of Commerce has made 100 fishery disaster determinations, of which 12 were the result of hurricanes or other severe weather events. The proposed revisions would make the following changes to the information collection:
Expand it to explicitly include a broader range of catastrophic events and all the coastal states and territories of the United States;
NMFS, in consultation with OMB, decided to develop survey instruments for fishing operations and fishing related businesses that it could use both for regional surveys, such as for a hurricane, and for national surveys, such as for the COVID-19 pandemic. NMFS intends to produce the survey instrument for a specific catastrophic event, by eliminating the questions that are not relevant for that event. For example, the questions about the physical damages to vessels, gear, facilities, and infrastructure would not be included in a national survey for COVID-19. In addition, NMFS determined that due to the similarities between the previous long-term and rapid assessment survey, it made sense to develop a survey instrument that it could use for either by again deleting the questions that are not relevant for a specific collection.
Change the title from “Assessment of the Social And Economic Impact of Hurricanes and Other Climate Related Natural Disasters On Commercial And Recreational Fishing Industries In The Eastern, Gulf Coast And Caribbean Territories of the United States” to “Data Collections to Support Comprehensive Economic and Socio-Economic Evaluations of the Fisheries in Regions of the United States Affected by Catastrophic Events”; and
Justification
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 MSA includes the following requirement and associated definition (see SEC. 315 (c) and (d)).
Within 2 months after a catastrophic regional fishery disaster the Secretary [of Commerce] shall provide the Governor of each State participating in the program a comprehensive economic and socio-economic evaluation of the affected region's fisheries to assist the Governor in assessing the current and future economic viability of affected fisheries, including the economic impact of foreign fish imports and the direct, indirect, or environmental impact of the disaster on the fishery and coastal communities.
The term ‘catastrophic regional fishery disaster’ means a natural disaster, including a hurricane or tsunami, or a regulatory closure (including regulatory closures resulting from judicial action) to protect human health or the marine environment, that—
(1) results in economic losses to coastal or fishing communities;
(2) affects more than 1 State or a major fishery managed by a Council or interstate fishery commission; and
(3) is determined by the Secretary to be a commercial fishery failure under section 312(a) of this Act or a fishery resource disaster [under] section 308(d) of the Interjurisdictional Fisheries Act of 1986.
NMFS has used the currently approved information collection to conduct the following 12 information collections in support of the mandated economic and socio-economic evaluations for five hurricanes and the COVID-19 pandemic.
Hurricane Florence: A rapid response survey of North Carolina fishermen conducted in 2018
Hurricane Florence: A rapid response survey of North Carolina fishing support businesses conducted in 2018
Hurricane Michael: A rapid response survey of Florida fishermen conducted in 2018
Hurricane Michael: A rapid response survey of Florida fishing support businesses conducted in 2018
Hurricane Irma: A one year after survey of Florida fishermen conducted in 2019
Hurricane Irma: A one year after survey of Florida fishing support businesses conducted in 2019
Hurricane Harvey: A one year after survey of Texas fishermen conducted in 2019
Hurricane Harvey: A one year after survey of Texas fishing support businesses conducted in 2019
Hurricanes Irma and Maria: A one year after survey of Puerto Rico fishermen conducted in 2019
Hurricanes Irma and Maria: A one year after survey of USVI fishermen conducted in 2019
COVI-19: A rapid response survey of NE through Gulf of Mexico fishermen and fishing related businesses in 2020
COVID-19: A rapid response survey of Puerto Rico and USVI fishermen and fishing related businesses in 2020
Appendix A contains references to presentations, reports and papers, which were prepared using the information resulting from those information collections and similar previous collections.
Like Hurricane Sandy in 2012, these five hurricanes generated so much damage, disruption and economic losses to coastal fishing communities that the Secretary of Commerce declared “catastrophic regional fishery disasters’ in Florida, North Carolina, Texas, Puerto Rico and the U.S. Virgin Islands. Restoring both the commercial and recreational fishing sectors is critical to rebuilding the economic base in affected communities. Given that coastal disasters from extreme weather events, such as major hurricanes, are increasing in frequency and severity (Melillo et al. 2014), NMFS and federal fishery managers need to be prepared to provide timely and accurate information to support the federally mandated evaluations.
In addition, to meet its mandates to monitor, explain and predict changes in the economic and social conditions of federally managed fisheries, NMFS needs to conduct comprehensive economic and socio-economic evaluations of the fisheries in the regions affected by catastrophic events, even if they do not result in the declaration of a catastrophic regional fishery disaster. Without understanding the economic and social impacts of those powerful exogenous shocks to federally managed fisheries, such as those of the COVID-19 pandemic, NMFS cannot meet the mandates for economic and social analyses, which are included in following laws, Executive Orders (EOs) and NOAA Fisheries strategies and policies.
Magnuson-Stevens Fishery Conservation and Management Act (MSA)
Marine Mammal Protection Act (MMPA)
Endangered Species Act (ESA)
EO 12866 (Regulatory Planning and Review)
EO 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations)
EO 13771 (Reducing Regulation and Controlling Regulatory Costs)
EO 13840 (Ocean Policy to Advance the Economic, Security, and Environmental Interests of the United States)
EO 13985 (Advancing Racial Equity and Support for Underserved Communities Through the Federal Government)
NOAA Fisheries Guidelines for Assessment of the Social Impact of Fishery Management Actions
NOAA Fisheries Guidelines for Economic Reviews of Regulatory Actions
NOAA Fisheries Strategic Plan 2019-2022 (Strategic Plan)
NOAA Fisheries Ecosystem-Based Fishery Management (EBFM) Road Map
Appendix B discusses their requirements for economic and social data and analyses.
In order to address mandated evaluations and analyses, the NMFS Office of Science and Technology’s Economics and Social Analysis Division seeks to conduct as-needed information collections to support both immediate and follow-up comprehensive economic and socio-economic evaluations of the fisheries in the regions affected by natural and man-made catastrophic events. The latter could include quarterly, semi-annual, and following year collections. Examples of the catastrophic events include hurricanes, tsunamis, floods, freshwater intrusions, severe harmful algal blooms (e.g., red tides), extreme temperatures, oil spills, and pandemics. Within the area affected by a catastrophic event, we will collect information from the owners or operators of commercial and for-hire fishing vessels, as well as from the owners or operators of bait and tackle shops, seafood dealers, seafood processors, and, where appropriate, aquaculture facilities. NMFS will implement a collection only as needed after one of these events and will limit it to the disaster affected regions. Due to the unknown nature and location of the next catastrophic events, we request approval for regional and national collections. Each regional collection will be for a specific affected region (e.g., all or part of a state or territory or a group of states and/or territories) and a national collection will be for all coastal states and territories. With the exception of a pandemic, we expect to conduct regional, not national, collections. It is standard procedure to send social scientists into the field to conduct non-quantitative, rapid-response, qualitative ethnographic interviews in the disaster affected regions. The requested data collection aims to supplement the qualitative insights with quantitative economic and social information, which NMFS and others will use to evaluate the impacts of and recovery from a catastrophic event.
The purpose of these evaluations is to understand how catastrophic events affect commercial and recreational fishing industries, including fishing related businesses, and the communities most dependent on those industries. NMFS will use immediate evaluation collections to identify short-term economic and social impacts for use in MSA 315 mandated evaluations that are due to the Secretary of Commerce within 60 days of a catastrophic regional fishery disaster declaration. In addition, NMFS may conduct a collection to support a following year evaluation to identify long-term impacts and impediments to recovery. Further, for an ongoing event, such as a pandemic or red tide that lingers for many months in the same region(s), NMFS may conduct collections quarterly to semi-annually as needed to evaluate the ongoing event. These data collections provide essential information on the current conditions of the fishing industries in affected states and territories that can be used both to improve future responses to disasters and in fishery management actions in the United States. They also provide a timely baseline of information to distinguish between the effects of catastrophic events and the effects of management regulations, thus improving the usefulness of subsequent fisheries economic and social impact assessments. This information will increase the agency's knowledge of the compounding effects of catastrophic events and changes in fisheries regulations in order to improve fisheries management.
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.
How will we collect the information? This will be an as-needed information collection using a structured survey administered via telephone, online, mail, and/or in-person by NMFS staff and contractors. “As-needed” refers to collecting data in three ways: 1) implementing a collection immediately following a catastrophic event to assess its immediate impacts, 2) implementing a second collection to evaluate its long-term impacts and serve as a one-year follow up to the immediate evaluation survey, and 3) for an ongoing event, such as a pandemic or red tide that lingers for many months in the same region(s), implementing quarterly and/or semi-annual collections to support the evaluation of the ongoing impacts of a catastrophic event. The survey protocols were developed based upon the results of a Hurricane Sandy following year collection (OMB Control No. 0648-0686) implemented in 2013-2014 by the NMFS Northeast Fisheries Science Center (see Colburn et al., 2015; Clay et al. 2016; Seara et al. 2016). More recently, NMFS used those protocols to efficiently conduct information collections for hurricanes Florence, Harvey, Irma, Maria and Michael (see Agar et al, 2020; McPherson & Jepson, 2018, and Jepson 2018).
From whom will we collect the information? We designed these collections to obtain information from fishing operations and other fishing related businesses in the coastal states and territories of the U.S affected by catastrophic events. Therefore, within the area affected by a catastrophic event, we will collect information from the owners or operators of commercial and for-hire fishing vessels, as well as from the owners or operators of bait and tackle shops, seafood dealers, seafood processors, and, where appropriate, aquaculture facilities.
How will we use the information? The information will be of practical use. NMFS, Governors from affected states and territories, Congressional staff, the regional fishery management councils, the interstate marine fisheries commissions, state/territory fishery agencies, other state/territory agencies, and the public will use the information and the results of the analyses it supports to do the following:
Understand the effects of catastrophic events on fishing operations, other fishing related businesses and fishing communities;
Fulfill requirements to complete a 60-day evaluation when the Secretary of Commerce has declared a catastrophic regional fishery disaster;
Understand the long-term impacts of and recovery from such events, as well as the impediments to a recovery;
Estimate the dollar value of the damages, lost revenues, and jobs lost due to the catastrophic events;
Conduct informed deliberations regarding the disbursement of the fishery disaster relief assistance proved by Congress;
Describe the industry and estimate impacts of any future catastrophic events;
Differentiate between the changes in economic and social performance of the fisheries caused be the event, fishery regulations and other factors;
Support a well-informed fisheries management process;
Assist in meeting legal and policy requirements for fisheries economic and social impact assessments, such as those discussed in Appendix B;
Support the development of ecosystem models and community vulnerability and resilience indicators, which incorporate economic and social information; and
Increase the utility of other secondary research, completed and ongoing, by providing more accurate, primary data to support secondary data collection efforts.
The exact frequency of the use of the data is unknown at this time and is dependent on the regulatory actions required in the future as well as public use. However, since this information will be specific to a particular catastrophic event, and therefore not previously available, we expect it to have high utility.
To support the broad availability and use of the information, NMFS will disseminate it to the entities identified above. However, NMFS will retain control over the data and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for privacy and electronic information. See the response to Question 10 below for more information on privacy. NMFS designed the information collection in accordance with NOAA Information Quality Guidelines. Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.
How has NMFS used the information received from the current collection? It has used the information from current collections in the same ways it plans to use it in the future. Appendix A contains references to presentations, reports and papers, which were prepared using that information.
What information will we collect? NMFS organized the survey forms to ease the collection of the data by clearly identifying the types of data it will collect by sections. The surveys will collect responses to the following five types of questions: 1) introduction/identification questions; 2) background/demographic questions; 3) operating characteristics and disaster impact questions; 4) individual recovery, lessons learned and personal well-being questions, and 5) state and territory specific impacts and additional comment questions. These types of information are unavailable for the fishing industry from other sources. NMFS will use separate but comparable surveys for fishing operations and other fishing-related businesses, which account for differences between the characteristics of fishing operations and other fishing related businesses. The surveys provide the flexibility to identify a specific catastrophic event, the associated geographic region (e.g., state(s), territory or all coastal states and territories), the period of interest (e.g., immediately or 12 months after the event), and the nature of a specific event (e.g., is it an event that could cause physical damage to fishing vessels and infrastructure). The option to exclude irrelevant damage questions for a specific event provides additional flexibility.
Introduction Questions
This section of the fishing operations survey includes questions about the following:
whether the intended individual has been contacted
whether the respondent is the owner of a specific fishing vessel identified by vessel name and registration number or is familiar with that vessel’s status and operation and can answer on behalf of the owner
whether they have the name and number of a better person to contact
whether a specific phone number is the best number to contact this respondent
a good email address for this business
whether they are willing to help us understand the impacts of the catastrophic event and
whether they prefer to complete the survey during the first phone
call, during a later call at a more convenient time for them, by mail, online, or in-person, and the information necessary to complete the survey other than during the first phone call
This section of the fishing related businesses survey includes similar questions and one additional question about whether there is a fishing-related business at the location contacted.
Background Information Questions
Surveys directed at fishermen include questions about the following:
whether they describe themselves as full-time or part-time fishermen or other
whether commercial and/or charter fishing is the primary source of their individual income
other occupations they have to earn income
their age and years of experience
where they live/reside
how long they have lived there
their gender
whether they are Hispanic or Latino
their race
their level of education and
their total household income
Surveys directed at all other fishing-related businesses include similar questions with one exception. We changed the first question to ask them to identify their position in the business.
This background information will allow us to better understand the unique characteristics of the fishing industry participants and identify characteristics that can affect the impacts of catastrophic events. The U.S. Census does not collect or provide information at a level to be able to identify a specific sector of the fishing industry.
Operating Characteristics and Disaster Impact Questions
This section of the fishing operations survey includes questions about the following:
whether they are the vessel owner but not the captain or part of the crew, owner and operator, captain but not vessel owner, vessel manager, or other
the type of fishing operation they are engage in
the port they land most of the vessel’s catch
the vessel’s homeport
whether they change their vessels homeport or landing port even if only temporarily due to the event
whether they fish inshore and/or offshore
whether the damages were none, minor, major, or a total loss
estimated vessel damages
market value of the vessel before the event
in $s and %, the extent to which the damages were covered by insurance
percent of the physical damages to the vessel that has been repaired
whether the gear damages/losses were none, minor, major, or a total loss
estimated gear damages/losses
market value of the gear before the event
in $s and %, gear damages/losses that were covered by insurance
whether the catch/product damages/losses were none, minor, major, or a total loss
estimated catch/product damages/losses
in $s and %, catch/product damages/losses that were covered by insurance
fisheries the vessel usually operates in during a specific part of the year
how long the vessel stopped fishing
why it stopped fishing
how long it took to return to its normal level of fishing activity
vessel’s current level of fishing activity compared to before the event
reasons a vessel is still not fishing
when the vessel will be able to return to fishing
whether, how long and to which activity did it switch to other than commercial and/or for-hire fishing
current crew size
number of crew by state/territory/country
crew size change since the event
the primary reason that the crew size changed because of the event
how the number of crew by state/region/country changed
how the vessel’s revenue in the [X] months following the event compared to the same months in the previous year?
reasons for the revenue changes
how the vessel’s operating costs in the [X] months following the event compared to the same months in the previous year?
reasons for the operating costs changes
what have they done because of the event], even if only temporarily
numbers of vessels owned currently and before the event
whether they own or lease buildings or other facilities related to their fishing operations
whether the damages to those buildings or other facilities were none, minor, major, or a total loss
estimated damages
whether the damages were minimal, minor, major, or a total loss
market value of the buildings or facilities before the event
extent to which the damages were covered by insurance
whether a vessel owner who also has a dealer permit had any physical assets, beyond the vessels, related to the business of being a seafood dealer
total damages to physical assets of their dealer business
whether there were other types of damages due to the event that were not addressed above, the amount of the damages and the amount covered by insurance
the current availability of cash on hand for your fishing operations
whether they have missed any fishing related scheduled payments due to the event
the three event factors that have had the largest impact on their fishing business
whether there were any other ways they have changed or adapted their business practices since Month X, 202X due to event] that are not covered above
whether there were any other catastrophic events or economic factors that affected their fishing activities and revenues in either a positive or a negative way and what they were and
whether the event had any positive impacts on the fisheries and what they were
For the types of catastrophic events that do not result in damage to gear, vessels or structure, the surveys will not include the irrelevant damage questions.
Surveys directed at other fishing related businesses contain many similar questions as well as some additional questions. They include questions about the following:
primary service the business provides
other fishing-related business services the business provides
where they market their product
whether their fishing related business was affected and/or damaged by the event
amount of damages for each of four categories of damages
whether the damages by category were none, minor, major, or a total loss
market value of the of each category of assets
by category and in $s and %, the part of the damage was covered by insurance
whether there were other types of damages due to the event that were not addressed above, the amount of the damages and the amount covered by insurance
what percent of the overall damage has been repaired
various ways their normal business operations as a seafood dealer or processor were affected compared to this same time period last year even if only temporarily
how long the business was closed due to the event
how soon did the business return to a normal level of operations
level this business is operating at in comparison to a specific month in the previous year
how long until they will be able to reopen their business
how their revenue in a specific month or set of month compare to the same month(s) in the previous year
reason their revenue was affected
how their operating costs in a specific month or set of month compare to the same month(s) in the previous year
reason their operating costs were affected
three factors that had the largest impact on their fishing related business
current availability of cash on hand for their business
whether their business had missed any scheduled payments due to the event,
whether there were any other catastrophic events or economic factors that affected their business activities and revenues in either a positive or a negative way
what any such events were
number of employees their business currently has on site
how the number of full-time/part-time on-site employees changed because of the event
primary reason the number of employees changed
what have they done because of the event, even if only temporarily
other ways they have changed or adapted their business practices since [month], 202X due to the event that were not covered above and
whether the event had any positive impacts on the fisheries and what they were
For the types of catastrophic events that do not result in damage to piers or docks, buildings and other infrastructure, seafood and bait products, or equipment and other merchandise, the surveys will not include the irrelevant damage questions.
Individual Recovery, Lessons Learned and Personal Well-Being Questions
The first part of this section of the surveys for fishing operations and other fishing related businesses includes questions about the following:
the resources they used to rebuild after the event
what helped them cope with the effects of the event
what has been the most helpful in coping with the effects of the event
what, if any, different measures will they take in the future to prepare for disasters such as the event and
whether there is anything NOAA Fisheries could do to help them prepare for and recover from future catastrophic events
The second part of this section of the surveys was adapted from Marshall and Marshall (2007) and addresses how people feel about their current business situation. Using a Likert scale, questions are intended to capture the ability of the participant to be prepared for and cope with change in general and in relation to catastrophic events.
State and Territory Specific Impacts and Additional Comments Questions
Questions in this section of the surveys focus on the impacts the event had on a specific state or territory. In addition, we ask the respondents if they have any additional comments they would like to share.
Frequency: For a rapid event, such as a hurricane, which is followed by a recovery period, NMFS is requesting approval to conduct four collections as needed after each such catastrophic event in a specific region. The four collections would consist of an immediate evaluation collection for fishing vessel, a following year evaluation collection for fishing vessels, an immediate evaluation collection for fishing related businesses, and a following year evaluation collection for other fishing related businesses. Alternatively, for an ongoing event, such as a pandemic or red tide, which lingers for many months in the same region(s), NMFS is requesting approval also to conduct collections quarterly and/or semi-annually as needed to evaluate the ongoing event. Given that coastal fishery disasters from extreme weather events, such as major hurricanes, are increasing in frequency and severity, NMFS is requesting approval to conduct an average of 12 collections per year or 36 collections during the three-year approval period for this information collection. Where NMFS could use each collection to support an immediate or follow-up evaluation for fishing vessels or other fishing related businesses.
Data sharing: NMFS will share summaries of the data and the results of its use with other organizations inside or outside the Department of Commerce or the government. NMFS will not share data from individual respondents unless it determines that there are adequate mechanisms and agreements to protect the confidentiality of the data from individual respondents.
Multiple options for providing the information: As noted above, the potential respondents typically will be able to provide the requested information with at least two of the following options: telephone or video interview, online, mail, and in-person interview.
Collection requirement changes over time: The overall collection requirements have not changed. However, some of the external factors that affect the economic and social performance and impacts federally managed fisheries have changed. For example, the COVID-19 pandemic was a large exogenous shock to many fisheries in 2020. To respond to this and other unforeseen types of catastrophic events that affect the fishing industries and communities in coastal states and U.S. territories, the proposed revisions to this information collection would expand the types of catastrophic events and regions for which NMFS can collect information and conduct evaluations.
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.
We will administer a structured survey via telephone, online, mail, and/or in-person. However, the exact methods of information collection will depend on the type and extent of the catastrophic event. For example, if telephone and internet services are functioning, we will place an emphasis on administering the survey through those means. If these modes are compromised, then we will place an emphasis on in-person intercept surveys. No technology will be used or provided to complete the in-person intercept surveys. In the case of surveys administered over the telephone, interviewers will use a computer or some other technological device to enter the information collected electronically. The fillable on-line survey will require a computer and internet access. The results of the information in the form of a NMFS fact sheets, preliminary and provisional reports, and technical memorandum will be made available over the internet. See Appendix A for examples of such reports.
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
NMFS staff consulted with the NMFS Science Centers and Regional Offices, the Councils, interstate marine fisheries commissions, academics, community-based organizations, industry groups, and other parties interested in this type of information. We are not aware of any duplicative efforts designed to collect the information NMFS will need to conduct the required evaluations of the fishing industry and community impacts of catastrophic events, including a catastrophic regional fishery disaster.
Since the purpose of these collections is to support the evaluation of the immediate and longer term impacts from catastrophic events, including hurricanes, tsunamis, floods, freshwater intrusions, severe harmful algal blooms (e.g., red tides), extreme temperatures, oil spills, and pandemics, these collections will be implemented as needed after one of these events. Due to the unknown location of the next such event, which could occur in any coastal state or territory, it is difficult to predict where duplication of effort might occur. However, NMFS will work closely with other federal agencies (e.g., FEMA and SBA), state fish and wild life agencies, and academics (e.g., local Sea Grant Extension agents) to ensure there is no duplication of effort and that the NMFS collections to support immediate and follow-up evaluations will complement other data collection efforts. Although there are instances where individual agencies or states also collect disaster-related data, if they are not the kind of data NMFS needs or if they are not collected uniformly across the multiple states or territories impacted by the catastrophic event, they are not adequate to support the mandated evaluations.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
This request includes the collection of data on individuals and those who may be linked to or represent small businesses. NMFS will use the following methods to minimize burden.
We designed the survey instruments to request only the minimum data required for the purpose of the collection.
Prior to contacting these respondents, we will gather any publicly available answers to our questions and will only ask those questions that cannot be reliably answered that way or for which the answers may change with the perspective of the respondent.
Participation in data collection will be voluntary and the collection will only be conducted as needed.
To minimize the language barrier and burden on non-English speaking intended respondents, NMFS will provide interviewers who can speak the languages the intended respondents are comfortable with and provide translated versions of the mail or online surveys.
When possible, we will provide intended respondents the broadest possible range of options to complete a survey, where the options include providing the survey information by a telephone or video call interview, a mail or internet survey, or an in-person interview.
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.
NMFS will only conduct these collections as needed. Not conducting these collections or conducting them less frequently would prevent NMFS from preparing the economic and socio-economic evaluation required by the MSA within 2 months of the declaration of a catastrophic regional fishery disaster. In addition, it would have the following adverse cascading effects. It would decrease the ability of NMFS and the Councils to effectively monitor, explain, and predict changes in the economic and social conditions of federally managed fisheries. That would prevent more than cursory efforts to comply with or support a variety of laws, Executive Orders and NOAA Fisheries strategies and policies, which require economic and social analyses. That would limit their use of a well-informed, science-based approach to the conservation and management of living marine resources and marine habitat in federally managed fisheries.
Not collecting this information will mean the loss of a vital baseline for information needed to evaluate the impacts of catastrophic events. In the absence of timely information, NMFS will be unable to portray accurately the current conditions of fishing industry and communities in these areas. It will not be possible to separate out the effects of such events from the effects of management regulations, thus reducing the usefulness of subsequent economic and social impact assessments. Further, loss of a current baseline—while initial recovery is still in progress and details are still recalled—will make it impossible to evaluate fully the social, economic, and cumulative impacts as required under NEPA and the MSA (see response to Question 1).
A significant concern related to the quality of these analyses is the risk of being vulnerable to litigation for not fulfilling the mandates and executive orders described under Question 1. Not collecting this information may lead to incomplete representation of the necessary economic and social data for good science. This could hamper the decision-making process and negatively affect the individuals and communities subject to the decisions.
There are no technical or legal obstacles to reducing the information collection burden.
Explain any special circumstances that would cause an information collection to be conducted in a manner that is inconsistent with OMB guidelines.
This information collection is voluntary. Therefore, it does not require respondents to: 1) report information to the agency; 2) prepare a written response; 3) submit any document; 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 NMFS designed to produce valid and reliable results that it can generalize 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 published on March 2, 2021 (86 FR 12174) solicited public comments. We received no comments, which pertained to the PRA requirements of the information collection.
The success of similar surveys previously conducted under OMB Control Numbers 0648-0686 and 0648-0767, as well as consultation with fishermen and others familiar with the fishing industries, indicate that there should be no issues regarding the availability of data, frequency of collection, the clarity of instructions and reporting format, or the requested data elements.
We consulted Council, NMFS Regional Office, NMFS Science Center, inter states marine fisheries commissions, and state fish and wildlife agency staff, members of the Councils’ committees and teams regarding the availability of data for the survey population. Outside of this survey, we cannot identify data we can use to assess the economic and social impacts of catastrophic events on the U.S. commercial and recreational fishing industries, including fishing related businesses, and the communities most dependent on those industries.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
There are no plans to provide any payments or gifts 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.
Name, address and phone number of potential respondents will be assembled for the immediate evaluation collections from existing sources including federal and state agencies, fishing businesses, and fishing organization membership lists. The contact lists used in the immediate evaluation collection will be stored for use in the follow-up collections. We will use this information to select the sample population. Information collected is protected under the Privacy Act of 1974 (5 USC 552a), which prohibits disclosing information without the written consent of the subject individual, unless disclosure is pursuant to one of twelve statutory exceptions. The information in the contact lists is covered under the Privacy Act System of Records COMMERCE/NOAA-11, Contact Information for Members of the Public Requesting and Providing Information Related to NOAA’s Mission.
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.
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.
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.
Household income and race are the potentially sensitive question in these collections. Household income can be an important indicator of household economic resiliency and is useful in determining if a catastrophic event had disproportionate impacts on low income communities. NMFS can use race to determine if a catastrophic event has disproportionate impacts on underserved communities. The 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.
We do not know when, where or how many catastrophic events will occur during the next three years. Historically, most such events affect all or part of a specific state or territory. Therefore, with the exception of a pandemic, it is highly unlikely that a given event would affect all coastal states and territories. To address both this uncertainty and the MSA requirements for the evaluations, which the proposed collections will support, NMFS is requesting approval to conduct an average of eight regional and four national collections per year. Each regional collection will be for a specific affected region (e.g., all or part of a state or territory or a group of states and/or territories) and each regional or national collection could be to support an immediate or follow-up evaluation for either fishing operations or other fishing-related businesses in a specific affected region.
To estimate the number of responses for the proposed collections, NMFS used information from the 11 regional collections it conducted to evaluate the impacts of hurricanes and the two multi-regional collections it conducted to assess the impacts of the COVID-19 pandemic on fishing operations and fishing related businesses for the Northeast through the Gulf States and for Puerto Rico and the USVI. Table A1 presents the average number of responses per collection from fishing operation (382) and from fishing related businesses (60) for the hurricane collections. NMFS calculated those two averages using the response data in Table B1.
Table A1. Number of Responses for Previous State/Territory/Regional and
Multi-Region Collections.
Average number of responses per hurricane information collection |
Number of responses for the multi-region COVID-19 information collections |
||
Fishing operations |
Fishing related businesses |
Fishing operations |
Fishing related businesses |
382 |
60 |
1,942 |
374 |
Given those averages and its request to conduct on average four regional collections per year for each of these two groups, NMFS estimates that, on average, there will be 1,528 responses per year from fishing operations and 240 responses per year from other fishing related businesses for the regional collections (see Table A2).
Table A1 also presents the total number of responses from fishing operations (1,942) and from other fishing related businesses (374) for the COVID-19 collections, which NMFS calculated using response data in Table B3. NMFS is requesting authority to conduct on average two national collections per year for each of these two groups and it expects that the numbers of responses for a national collection will be 50 percent greater than for the COVID-19 collections for the Northeast through the Caribbean. That increase in responses is to account for the additional fishing operations and other fishing related businesses in the Alaska, West Coast and Pacific Islands Regions and to allow the inclusion of bait and tackles shops in all regions. Therefore, NMFS estimates that, on average for the national collections, there will be 5,826 responses per year from fishing operations and 1,122 responses per year from other fishing related businesses (see Table A2).
Based on the numbers of responses per respondent for the hurricane and COVID-19 collections, NMFS expects one response per respondent for the regional collections and 1.2 responses and 2 responses per fishing operation and other fishing related business respondent, respectively, for the national collections.
Based on the number of questions per collection type and input from those who have assessed the questions or answered them, we estimate the burden per response will average 30 minutes for the regional collections and 20 minutes for the national collections. The estimate for the latter is less because those surveys typically will include fewer questions about physical damages. For each type of collection and for those who had little or no effects from the catastrophic event, the burden per response will be well below the estimated average. However, for fishing operations with several affected fishing vessels, it will be well above the estimated average. Using those averages, NMFS estimates that the average annual burden hours will be 884 hours for the regional collections and 2,316 hours for the national survey, for a total of 3,200 hours for all the collections (see Table A2).
Table A2. Estimated Average Annual Number of Responses and Burden Hours by Type of Survey.
Type of Collection |
Responses/ survey |
Surveys/ year |
Responses/ year |
Burden hours/ year |
Regional surveys of fishing operations |
382 |
4 |
1,528 |
764 |
Regional surveys of other fishing related businesses |
60 |
4 |
240 |
120 |
National surveys of fishing operations |
2,913 |
2 |
5,826 |
1,942 |
National surveys of other fishing related businesses |
561 |
2 |
1,122 |
374 |
Total |
|
12 |
8,716 |
3,200 |
To calculate the annual wage burden costs, we used Bureau of Labor Statistics hourly wage rate estimates for May 2019 at https://www.bls.gov/oes/current/oes_nat.htm for 2019. For fishermen, we used $42.03, which is the mean hourly wage rate for Captains, Mates, and Pilots of Water Vessels (occ_code 53-5021). For fishing related business respondents, we used $76.18, which is the average of 1) $59.15, the mean hourly wage rate for General and Operations Managers (occ_code 11-1021) and 2) $93.20, the mean hourly wage rate for Chief Executives (occ_code 11-1011). With those wages and the above burden hour estimates, the estimated total annual wage burden costs are $151,366 (see Table A3).
Table A3. Estimates of the Total Annual Wage Burden Costs by Information Collection.
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 |
|
|
(a) |
(b) |
(c) = (a) x (b) |
(d) |
(e) = (c) x (d) |
(f) |
(g) = (e) x (f) |
Regional surveys of fishing operations |
Commercial and for-hire fishing vessel owners and operators |
1,528 |
1 |
1,528 |
0.50 |
764 |
$42.03 |
$32,111 |
Regional surveys of other fishing related businesses |
Owners and managers fishing related businesses |
240 |
1 |
240 |
0.50 |
120 |
$76.18 |
$9,142 |
National surveys of fishing operations |
Commercial and for-hire fishing vessel owners and operators |
4,855 |
1.2 |
5,826 |
0.33 |
1,942 |
$42.03 |
$81,622 |
National surveys of other fishing related businesses |
Owners and managers fishing related businesses |
561 |
2 |
1,122 |
0.33 |
374 |
$76.18 |
$28,491 |
Totals |
|
7,184 |
|
8,716 |
|
3,200 |
|
$151,366 |
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 (see Table A4). Respondents will use envelopes with prepaid postage for any information collected by mail.
Tab A4. Estimates of the Total Annual Cost Burden by Information Collection
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) |
|
Regional surveys of fishing operations |
1,528 |
1 |
1,528 |
0 |
0 |
Regional surveys of other fishing related businesses |
240 |
1 |
240 |
0 |
0 |
National surveys of fishing operations |
4,855 |
1.2 |
5,826 |
0 |
0 |
National surveys of other fishing related businesses |
561 |
2 |
1,122 |
0 |
0 |
TOTALS |
7,184 |
|
8,716 |
|
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.
NMFS will conduct collections as needed after each relevant catastrophic event. Therefore, the number of such events during the next three years and the geographic ranges of the events will determine the actual cost per year to the Federal government. The following estimates are for an average of 12 collections per year. That is the number of collections per year for which NMFS is requesting approval. Each collection would support an immediate or follow-up evaluation for either fishing operations or other fishing-related businesses in a specific affected region or. In the case of a pandemic, the affected region could include all coastal states and U.S. territories. We expect the 12 collections per year typically will include four national and eight regional collections.
NMFS staff with assistance from contractors will conduct the collections and be responsible for collecting the data, entering them into a database and preparing the reports. In addition, NMFS will incur travel costs, and there will be costs for printing and mailing the surveys and for supplies. Table A5 provides the cost estimates by category. The estimated total annual cost of 12 collections per year is $1,467,332.
Table A5. Estimates of Average Annual Federal Government Costs.
Science Centers Cost Descriptions |
Grade/ Step |
Loaded Salary /Cost |
% of Effort |
Fringe (if Applicable) |
Total Cost to Government |
Federal Oversight |
ZP-4 |
$212,321 |
90% |
|
$191,089 |
Data collection/analysis/ report preparation |
ZP-4 |
$212,321 |
90% |
|
$191,089 |
Administrative |
|
|
|
|
$0 |
Some other duty |
|
|
|
|
$0 |
Contractor Cost |
|
|
|
|
$947,922 |
Travel (NMFS staff) |
|
|
|
|
$90,000 |
Other Costs: |
|
|
|
|
$6,000 |
Printing/supplies/postage |
|||||
Sub Total for Science Centers |
|
|
|
|
$1,426,100 |
Table A5 (Continued)
Office of Science and Technology (OST) Cost Descriptions |
Grade/ Step |
Loaded Salary Cost |
% of Effort |
Fringe (if Applicable) |
Total Cost to Government |
Federal Oversight |
ZP-4 |
$212,321 |
10% |
|
$21,232 |
Data collection/analysis |
|
|
|
|
|
Administrative |
|
|
|
|
|
Some other duty |
|
|
|
|
|
Contractor Cost Per Year |
|
|
|
|
$20,000 |
Travel |
|
|
|
|
|
Other Costs: |
|
|
|
|
|
Printing/postage |
|||||
Sub Total for OST |
|
|
|
|
$41,232 |
Total |
|
|
|
|
$1,467,332 |
Explain the reasons for any program changes or adjustments reported in ROCIS.
Table A6 includes the changes in the numbers of respondents and responses, the burden hours, labor costs, and miscellaneous costs; and explains the reasons for these changes. With respect to those changes, the effects of increasing the burden hours per response and expanding the collection to include more types of catastrophic events and all coastal states and U.S. territories were more than offset by large decreases in the estimated numbers of respondents and response. Two things contributed to those decreases. First, we used data on recent collections instead of the more speculative projections used previously. That included using the response rates from recent collections as opposed to the higher response rate projections used previously. The reduction in the response rate was greater for other fishing related businesses; therefore, the percentage decreases in the numbers of respondents and responses were greater for that sector. Second and based on the recent collection, we decreased the scope of the other fishing related business by excluding marinas, boat repair yards and marine supply businesses. The reduction in labor costs is also explained by decreasing the estimated hourly wages from $64.61 for fishermen, $90 for processors and $100 for the rest of the other fishing related businesses to $42.03 for fishermen and $76.18 for all fishing related businesses.
In the previously approved collection, there were the following four surveys:
Long-term business survey
Long-term recreational and commercial fishing survey
Rapid assessment business survey
Rapid assessment recreational and commercial fishing survey
The revisions to the current information collection include expanding it to explicitly allow for national collections for catastrophic events that affect all coastal states and U.S. territories. NMFS, in consultation with OMB, decided to develop survey instruments for fishing operations and fishing related businesses that it could use both for regional surveys, such as for a hurricane, and for national surveys, such as for the COVID-19 pandemic. NMFS intends to produce the survey instrument for a specific catastrophic event, by eliminating the questions that are not relevant for that event. For example, the questions about the physical damages to vessels, gear, facilities, and infrastructure would not be included in a national survey for COVID-19. In addition, NMFS determined that due to the similarities between the previous long-term and rapid assessment survey, it made sense to develop a survey instrument that it could use for either by again deleting the questions that are not relevant for a specific collection. Basically, NMFS revised the survey instruments to make them more useful and applicable. The revised collection includes the following two surveys, which were based on the previously approved survey instruments and improved using the lessons learned from conducting the approved collections.
Survey of fishing-related business impacts & recovery
Survey of fishing-operations impacts & recovery
Table A6. Estimated Changes In the Numbers of Respondents, Numbers of Responses, Burden Hours, Wage Costs, and Miscellaneous Costs Per Year by Information Collection.
Information Collection |
Respondents/Year |
Responses/Year |
Burden Hours/Year |
Reason for change or adjustment |
|||
Current Renewal / Revision |
Previous Renewal / Revision |
Current Renewal / Revision |
Previous Renewal / Revision |
Current Renewal / Revision |
Previous Renewal / Revision |
||
Regional surveys |
1,768 |
18746 |
1768 |
28119 |
884 |
9373 |
Updated to reflect proposed expansion of the scope of the collections, an increase in the burden per response and a reduced number of responses per collection. Previous IC "Rapid and longterm assessments" split into two ICs for increased transparency into the collection. |
National surveys |
5416 |
0 |
6948 |
0 |
2316 |
0 |
New collection |
Total for Collection |
7,184 |
18746 |
8,716 |
28,119 |
3,200 |
9,373 |
|
Difference |
-11,562 |
-19,404 |
-6,173 |
|
Table A6 (Continued)
Information Collection |
Labor Costs |
Miscellaneous Costs |
Reason for change or adjustment |
||
Current |
Previous |
Current |
Previous |
||
Regional Surveys |
$41,253 |
$744,376 |
0 |
0 |
Updated to reflect proposed expansion of the scope of the collections, an increase in the burden per response, a reduced number of responses per collection, and revised hourly wage rates |
National Surveys |
$110,113 |
0 |
0 |
0 |
New collection |
Total for Collection |
$151,366 |
$744,376 |
0 |
0 |
|
Difference |
($593,010) |
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.
Survey numerical and textual information will be a product of these information collections. Textual information will be numerically coded and used for categorical analysis. Survey data will be analyzed using standard quantitative data analysis methods. We anticipate 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 reports, fact sheets, NOAA Technical Memoranda, and publications similar to those listed in Appendix A. In addition, the data gathered will be used to address a wide range of issues important to the NMFS Regional Offices and Science Centers, the regional fishery management councils, the interstate marine fisheries commissions, state fish and wildlife agencies, state governors, and Congress.
Prior to dissemination, NMFS will subject the information 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 research based on these information collections, tabulations of individual responses will occur at a high enough level of aggregation so that data for no single individual can be identified. Typically, final reports and other relevant portions of the research process will be posted on http://www.akfsc.noaa.gov/, http://www.nefsc.noaa.gov, http://www.nwfsc.noaa.gov/, http://www.pifsc.noaa.gov/, http://www.sefsc.noaa.gov/, http://www.swfsc.noaa.gov/and http://www.st.nmfs.noaa.gov/index. Where relevant, NMFS will publish studies in their entirety as internal reports and will submit them in part for publication in peer-reviewed journals to encourage additional analysis and review of data collected through this process, as well as to disseminate findings. For example, NMFS published the results of the long-term Hurricane Sandy evaluation as NOAA Technical Memorandum NMFS-F/SPO-157 (Colburn et al., 2015) and as two peer-reviewed articles in Marine Policy and Global Environmental Change (Clay et al. 2016; Seara et al. 2016). More recently, damage assessments for Hurricanes Harvey and Irma were published (see Jepson, 2018 and McPherson & Jepson, 2018).
The time schedule for immediate response collections is set by the MSA requirement for a comprehensive economic and socio-economic evaluation of the affected region's fisheries within two months after the Secretary of Commerce declares a catastrophic regional fishery disaster. For those collections, the time-schedule is as follows, where the weeks are in reference to the date of the disaster declaration:
Weeks 1-2: Select Sample
Weeks 2-5: Conduct Survey and Enter Data
Weeks 5-6: Data Analyses
Weeks 6-7: Report Preparation
Week 8: Final 60-Day Report Completed
Weeks 9-52: Preparation of Additional Reports/Publications
Weeks 13-75: Additional Reports/Publications Completed0
The time schedule for the as needed follow-up collections will be as follows, where the weeks are in reference to approximately three month to one year after the immediate evaluation collection:
Weeks 1-2: Select Sample
Weeks 3-6: Conduct Survey and Enter Data
Weeks 7-9: Data Analyses
Weeks 10-13: Report Preparation
Week 14: Initial Report Completed
Weeks 15-52: Preparation of Additional Reports/Publications
Weeks 18-75: Additional Reports/Publications Completed
If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.
Each form will display the OMB control number and expiration date.
Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions."
The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
File Modified | 0000-00-00 |
File Created | 2021-06-08 |