U.S. Department of Commerce
National Oceanic & Atmospheric Administration
Recreational Angler Survey of Sea Turtle Interactions
OMB Control No. 0648-0774
SUPPORTING STATEMENT PART A -
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 Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NOAA Fisheries) plans to implement a survey design and directly assess the extent of and factors surrounding interactions between pier and other shore-based recreational anglers and sea turtles. Each year, the Sea Turtle Stranding and Salvage Network (STSSN) documents incidentally captured sea turtles at recreational piers along the Atlantic and Gulf of Mexico coasts. Over 4,100 incidental captures have been documented by the STSSN between 2008 and 2023. However, these reports are opportunistic, likely only represent a portion of the hook, and line interactions that are occurring, and the STSSN does not collect information related to fishing practices that may influence the likelihood of capture. This collection is necessary to obtain specific information about recreational piers (defined here to include piers and other shore-based structures), the anglers that fish on piers, the nature of interactions between pier-based anglers and sea turtles, as well as to determine specific factors that may influence the rate of interactions. NOAA Fisheries can use this information to evaluate the impact this sector has on sea turtle populations and determine conservation measures (voluntary or required) that can be implemented to reduce interactions. This collection (0648-0774) was approved in 2018, however due to the Covid-19 pandemic and delayed funding, the survey was not implemented.
Collection of these data on sea turtle interactions in the shore-based recreational fishing sector is necessary to fulfill statutory requirements of the Endangered Species Act (16 U.S.C. 1531 et. seq.), complete Section 7 analyses, and inform management decisions, and will provide necessary data for the conservation and recovery of endangered and threatened sea turtle populations.
Additionally, NOAA was approved to receive funding through Deepwater Horizon Oil Spill Natural Resource Damage Assessment Restoration. A project titled, “Reducing Sea Turtle Bycatch at Recreational Fishing Sites” has been funded by the Region wide Trustee Implementation Group. The project will provide funds to implement angler surveys for up to 2 years in each of the 5 Gulf of Mexico states to better understand co-factors related to shore-based hook and line bycatch of sea turtles.
NOAA Fisheries protected species managers to evaluate the impacts of recreational fishing on sea turtle populations and identify co-factors contributing to shore-based recreational bycatch with the goal of understanding if changes to fishing practices can be implemented to reduce bycatch will use the sea turtle interaction data that will be collected via this survey collection. The survey will be administered in a maximum of ten states (Atlantic and Gulf of Mexico). The number of states and the number of surveys completed in each state will be funding dependent.
The collection “Recreational Angler Survey of Sea Turtle Interactions” has three survey forms included within it (5 documents in total if you consider the Survey Design & Instruction forms).
Form 1: Fishing Site Characterization Form
Form 2: Survey Cover Sheet
Form 3: Angler Intercept Survey
Form 1: Fishing Site Characterization Form:
Survey administrators throughout the Atlantic and Gulf of Mexico coasts will complete this form. The intention is for this form to be filled out one time only for each pier location that is included within the survey. The purpose of the form is to collect specific information on the structure and operation of the pier, including the length and shape of the pier, staffing, signage, depth of water, lighting, and other features.
Form 2: Survey Cover Sheet:
Survey administrators throughout the Atlantic and Gulf of Mexico coasts will complete this form. This form would be filled out at each pier location visited for each observation/survey session. It provides general information on the environmental conditions for that particular day, the number of anglers fishing, number of lines in the water, and the number of surveys completed for that site.
Form 3: Angler Intercept Survey:
This form will be verbally administered to anglers fishing during the survey period. The form is broken into three parts. The first part asks about angler fishing practices that day, including bait and gear type, length of time fishing, target catch, and other fishing habits. Part 2 asks for information on if the angler has observed sea turtles in the past, and while fishing at that particular site. Part 3 asks for information about the most recent sea turtle capture, if applicable. This section asks for information on the nature of the interactions - if the turtle was hooked and/or entangled, where on the body it was hooked, if the hook and line were removed, how much line was remaining on the turtle, and if it was released alive or dead. NOAA Fisheries protected species managers to better understand the factors (e.g., hook type, bait type, time of day) that may influence the rate of interactions between sea turtles and recreational fishing gear will use all of this information. The data collected will also allow us to understand the baseline number of interactions that occur.
Additionally, instructions and survey design guidance are included within the collection to assist with standardized data collection.
Analysis of the data collected from this survey will be used in agency documents, such as ESA Section 7 Biological Opinions and other regulatory documents, reports, and will be published in scientific literature as appropriate. These documents are disseminated to the public. NOAA Fisheries 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. Should NOAA Fisheries decide to disseminate the information, it will be subject to the quality control measures and pre-dissemination review pursuant to Section 515 of Public Law 106-554.
Due to the Covid-19 pandemic and delayed funding, the survey has not been implemented with the expectation of a pilot study in North Carolina in 2023 where 71 surveys were conducted at three sites. The findings from this pilot study will allow design an efficient and appropriate strategy for full implementation of the survey at 10 sites in North Carolina in the next three years.
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 angler survey will be completed using verbal responses from the public (recreational fishers). The survey administrators will fill out the forms. In some cases, the forms may be filled out electronically on-site through use of a laptop or tablet, but again, the survey administrator will fill out the form based on the verbal answers. This survey is designed so that each respondent only needs to complete the survey one time. Since the survey will be completed in person, there is no need for the survey participants to print, mail, or electronically submit any portion of this survey.
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 are not aware of any other wide-scale efforts to systematically collect data on sea turtle interactions with the pier/shore-based recreational fishing sector along the Atlantic and Gulf of Mexico coasts. Individual STSSN facilities have conducted small-scale surveys of their specific response area to gather information on pier interactions, but these efforts have been disjointed and specific to their particular need. The public reports hook and line interactions to the STSSN. The percentage of interactions that are reported is unknown. The STSSN then responds to the event. The STSSN collects data on the animal morphometries, injuries, and many responders use a standardized incidental capture form (part of OMB Control Number 0648-0496). The incidental capture form is not a duplication of the Angler Survey, but rather it is intended to complement the data collected through the Angler Survey, to allow NOAA to better determine co-factors influencing sea turtle bycatch. NOAA Fisheries is currently operating the Access-Point Angler Intercept Survey (APAIS) in the Southeast Atlantic and Gulf of Mexico, OMB Control Number 0648-0659; however, this survey only collects information on the fishing experience, including the fishing gear used and the target catch, not on interactions with sea turtles.
If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.
No small businesses will be impacted by this collection. The survey will target only individuals who recreationally fish on piers.
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.
Failure to conduct this collection will cause a continued shortfall of data regarding the interactions between sea turtles and pier/shore-based recreational anglers. These data are critical to meet NOAA Fisheries mandates under the ESA to monitor and reduce the bycatch of sea turtles. Failure to implement the data collection will delay the Agency’s effort to develop and implement the ESA Section 7 program, as well as to develop management measures to reduce bycatch in this sector.
Additionally, as mentioned above, NOAA has recently received approval to conduct a project as part of the Deepwater Horizon Oil Spill Natural Resource Damage Assessment and Restoration process. The project would provide funding for up to 2 years of angler surveys in each of the five Gulf of Mexico states. NOAA is the lead implementing Trustee for the project and will be required to complete this project and report on the findings.
Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.
The collection is consistent with OMB guidelines.
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 July 30, 2024 (89 FR 61063) solicited public comment on this collection. One comment was received. The commenter was concerned with proposed costs to taxpayers to implement the survey. We recognize this concern, however these data are critical to meet NOAA Fisheries mandates under the ESA to monitor and reduce the bycatch of sea turtles.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
This data collection will not include any incentives to prospective 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.
Participation in this survey is voluntary and no PII will be collected. The information collected will be protected and kept anonymous if released. The Privacy Act does not apply.
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.
No sensitive questions are asked.
Provide estimates of the hour burden of the collection of information.
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 |
Angler Intercept Survey |
Public |
6,667 |
1 |
6,667 |
0.16667 |
1,111 |
$31.80 |
$35,361 |
Totals |
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An hourly rate of $31.80 is based on the average wages and salaries for all civilian workers from the National Compensation Survey (https://www.bls.gov/news.release/ecec.nr0.htm; accessed November 11, 2024). There are no other costs to the respondent. A total of 1,111 annual burden hours are anticipated, resulting in a labor cost to respondents of approximately $35,362 per year.
Documents included in angler survey packet: 1) NOAA Recreational Angler Survey Instructions (does not add additional burden), 2) Shore-based Survey Design Guide (does not add additional burden), 3) Recreational Fishing Pier Characterization Form, 4) Fishing Pier Angler Survey Cover Sheet, and 5) Fishing Pier Angler Survey.
This collection of forms will be completed by approximately 20,000 public respondents and by 20 survey administrators, resulting in a total estimated burden of 1,145 hours per year. Surveys may occur simultaneously in several states in the U.S. Atlantic and Gulf of Mexico, but the survey collection protocol would be conducted only one time per state within the approval period. Two forms would be filled out solely by the survey administrator; Form 1 (pier characteristics) and Form 2 (survey cover sheet). Form 3 would be filled out by the survey administrator who will record the voluntary verbal responses from members of the public.
The expected number of respondents (200 surveys/site with 10 sites/state) is based on pier-based intercept surveys on sea turtle interactions that were conducted by private organizations in both Virginia and Mississippi.
We intend to implement the survey in a maximum of 10 states during the survey approval period. For each state, we would survey a maximum of 10 fishing sites, and up to 200 individual anglers at each site. If <160 surveys are completed in a survey “year”, additional surveys will be conducted during the following survey “year”.
Form 1: Fishing Site Characterization Form (survey administrators - 16.67 hours over 3 years, accounted for in Q14.). Document included in Angler Survey packet to be completed by survey administrator.
Completed one time per site.
Assuming 10 sites per state, and 10 states total, this form would be filled out a total of 100 times. 10 minutes for each form.
10 sites x 10 states = 100 sites total = 100 site characterization forms
100 x 10 minutes = 1,000 minutes / (60 minutes/hr) = 16.67 hours (annualized to 5.56 hours per year)
Form 2: Survey Cover Sheet (survey administrators - 83.33 hours over 3 years, accounted for in Q14). Document included in Angler Survey packet to be completed by survey administrator.
Completed one time per site visit. 5 minutes for each form.
Assuming 10 sites per state (10 states) and 200 angler surveys per site. We estimate that approximately 20 angler surveys can be completed during each site visit, resulting in approximately 10 site visits per site (200 surveys / 20 angler surveys per visit = 10 site visits).
10 sites x 200 angler surveys = 2000 angler surveys
2,000 angler surveys / 20 angler surveys per site visit = 100 site visits per state
100 site visits per state x 10 states = 1,000 site visits = 1,000 cover sheets
1,000 cover sheet x 5 minutes = 5,000 minutes
5,000 minutes / (60 minutes/hr) = 83.33 hours (annualized to 27.78 hours per year)
Form 3: Angler Intercept Survey (public - 3,333.33 hours over 3 years)
To be completed for each angler intercept survey. 10 minutes per form.
Assuming 10 sites per state (10 states), and 200 angler surveys per site.
10 sites x 200 surveys = 2,000 total angler surveys per state
2,000 surveys x 10 states = 20,000 total surveys over the 3-year period
20,000 x 10 minutes = 200,000 minutes / (60 minutes/hr) = 3,333.33 hours (annualized to 1,111.11 hours per year)
Total annualized burden to the public, based solely on Form 3: 6,667 respondents and responses per year, and 1,111 hours per year.
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. These data collections will incur no cost burden on respondents beyond the costs of response time.
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.
Cost Descriptions |
Grade/Step |
Loaded Salary /Cost |
% of Effort |
Fringe (if Applicable) |
Total Cost to Government |
Federal Oversight |
GS-13 |
$100/hr |
25% (5% per state) |
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50,000 ($10,000 per state for 5 states) |
Other Federal Positions |
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Contractor Cost |
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Travel |
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Other Costs: |
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TOTAL |
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50,000 |
As mentioned above, the implementation of this survey is funding dependent. In September 2021, NOAA was approved to receive funding through Deepwater Horizon Oil Spill Natural Resource Damage Assessment Restoration. A project titled, the Region wide Trustee Implementation Group has funded “Reducing Sea Turtle Bycatch at Recreational Fishing Sites”. The project will provide funds to implement angler surveys for up to 2 years in each of the 5 Gulf of Mexico states to better understand co-factors related to shore-based hook and line bycatch of sea turtles.
If surveys were implemented outside the DWH Restoration program, NOAA would minimize costs where possible and collaborate with local organizations that may be able to cost share for the implementation.
The Federal cost per state would be the hiring of two survey administrators per state. Survey administrators would be part-time contractors that together would be the equivalent of one full time contractor. Therefore, the cost of implementation of this survey would be approximately one full time contractor per state. Estimated at $40,000 per state. The Federal Oversight costs would include approximately 5% of a GS-13 equivalent salary per state where the survey is implemented. This is estimated at $10,000 per state. The Federal Oversight for the DWH-funded surveys in five of the 10 states will be covered as part of project costs with non-appropriated funds and is not considered a cost to the government.
Explain the reasons for any program changes or adjustments reported in ROCIS.
Information Collection |
Respondents |
Responses |
Burden Hours |
Reason for change or adjustment |
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Current Renewal / Revision |
Previous Renewal / Revision |
Current Renewal / Revision |
Previous Renewal / Revision |
Current Renewal / Revision |
Previous Renewal / Revision |
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Angler Intercept Survey |
6,667 |
6,667 |
6,667 |
6,667 |
1,111 |
1,111 |
No changes. |
Sea Turtle Incidental Capture Intake Form |
0 |
500 |
0 |
500 |
0 |
42 |
IC was removed from this collection. Now located in collection 0648-0496. |
Total for Collection |
6,667 |
7,167 |
6,667 |
7,167 |
1,111 |
1,153 |
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Difference |
-500 |
-500 |
-42 |
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This collection (0648-0774) was approved in 2018, however due to the Covid-19 pandemic and delayed funding; the survey was not implemented with the exception of a pilot study in North Carolina in 2023 where 71 surveys were conducted at three sites. The collection previously included a Sea Turtle Incidental Capture Form. This form has been removed from this collection and is now included in the National Sea Turtle Stranding & Salvage Network Stranding & Gear Interaction Data Collection (0648-0496). However, removal of this form did not change any costs associated with the collection, nor did it change the number of respondents, responses, or burden hours, as the public did not complete this form.
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.
The data will be used to develop agency documents as noted above. For the 5 states in the Gulf of Mexico for which implementation will be supported by DWH Restoration funds, annual reports will be developed for project activities completed during project duration (2023-2028). We anticipate the angler survey component of the project will be completed in the years 2025 and 2026. If appropriate, peer-reviewed publications in scientific literature are anticipated to be made public approximately 2 years after the completion of the project.
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 agency plans to display the expiration date for OMB approval of the information collection on all instruments.
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).
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| File Modified | 0000-00-00 |
| File Created | 0000-00-00 |