0369 ss ren 061709 PartA rev

SUPPORTING STATEMENT
ECONOMIC SURVEYS OF U.S. COMMERCIAL FISHERIES
OMB CONTROL NO. 0648-0369

A.

JUSTIFICATION

This request is for renewal of this generic collection of information.
1. Explain the circumstances that make the collection of information necessary.
Commercial fisheries economic data collection programs implemented by National Marine
Fisheries Service (NMFS) address statutory and regulatory mandates to determine the quantity
and distribution of net benefits derived from living marine resources as well as predict the
economic impacts from proposed management options on commercial harvesters, shoreside
industries, and fishing communities. In particular, these economic data collection programs
contribute to legally mandated analyses required under the Magnuson-Stevens Fishery
Conservation and Management Act (MFCMA), the National Environmental Policy Act (NEPA),
the Regulatory Flexibility Act (RFA), Executive Order 12866 (E.O. 12866) as well as a variety
of state statutes including Florida Statute 120.54, Hawaii Revised Statute 201M-2, New Jersey
Permanent Statutes 52:14B-19, and Oregon Revised Statutes 183.335 and 183.540.
The lack of economic data in the majority of federally-managed fisheries has stymied NMFS’
ability to conduct these analyses and has led to lawsuits and regulatory challenges of fisheries
policies in the last several years, resulting in overturned rebuilding objectives, biologically
unsustainable total allowable catches, and eroded confidence in NMFS’ decision making process
and social sciences capability. Expanded commercial fisheries economic data collections will
improve the scientific foundation of the Agency’s policies and help decision makers weigh the
economic impacts of their decisions. It is important to note that a key feature of the federal
regulatory process is that NMFS cannot simply implement a regulation to achieve a conservation
goal but instead must consider a suite of management alternatives. Economic analyses can
identify the alternative that minimizes losses to stakeholders while still achieving conservation
goals, allowing NMFS to be proactive, rather than reactive, in its resource management strategy.
For these reasons, the collection of economic data in commercial fisheries has received a top
priority in the NMFS Social Science Plan, the NMFS Strategic Plan and the National Oceanic
and Atmospheric Administration (NOAA) Science Advisory Board. 1 In addition, NMFS
regional offices, commissions and councils also recognize the need for commercial fisheries
economic data, e.g., see the Pacific Fisheries Management Council’s report “West Coast
Research And Data Needs” as well as the Northeast Fisheries Science Center report “Data Needs
For Economic Analysis Of Fishery Management Regulations.” The need for commercial
fisheries economic data has also been identified by external sources, including the Kammer
report, General Accounting Office (GAO) reports and National Research Council (NRC)
reports. 2
1
Performance metrics cited within the NOAA Strategic Plan include the number of FMPs with complete economic data (variable cost, annual
operating cost and revenue) collected for commercial harvesters and the number of FMPs for which net benefits can be calculated.
2
See "An Independent Assessment of the Resource Requirements for the National Marine Fisheries Service: A Report to the Deputy Under
Secretary, NOAA and the Assistant Administrator, National Marine Fisheries Service," prepared by Ray Kammer, June 2000. In addition, recent
National Research Council publications that identify the need for commercial fisheries economic data include “Marine protected areas: tools for

1

Background
The MFCMA establishes eight Councils, each of which is charged with the preparation of a
fishery management plan and plan amendments with respect to each fishery requiring
management within its jurisdiction. Each fishery management plan (FMP) prepared by a
Council, or by the Secretary, must contain conservation and management measures that are
consistent with the national standards, and any other applicable law [MFCMA Sec.
303(a)(1)(C)], and a description of the fishery including actual and potential revenues from the
fishery [MFCMA Sec. 303(a)(2)]. Plans and plan amendments must also include a fishery
impact statement that analyzes the likely effects, if any, including the cumulative conservation,
economic, and social impacts, of the conservation and management measures on, and possible
mitigation measures [MFCMA Sec. 303(a)(9)].
Economic information needed to meet each of the MFCMA national standards identified below
(in Italics) is presented.
(2) Conservation and management measures shall be based upon the best scientific information
available.
Various sections of the MFCMA (e.g. Section 318) make it clear that scientific information
includes economic information.
(4) Conservation and management measures shall not discriminate between residents of
different States. If it becomes necessary to allocate or assign fishing privileges among various
United States fishermen, such allocation shall be (A) fair and equitable to all such fishermen;
(B) reasonably calculated to promote conservation; and (C) carried out in such manner that no
particular individual, corporation, or other entity acquires an excessive share of such privileges.
Economic information, including cost and revenue data on participants in the fishery, is required
to identify some of the effects of such allocation and is therefore useful in determining whether
such allocations are “fair and equitable.” Economic information is also useful in determining
what constitutes “an excessive share of such privileges.”
(5) Conservation and management measures shall, where practicable, consider efficiency in the
utilization of fishery resources; except that no such measure shall have economic allocation as
its sole purpose.
This standard requires appropriate descriptions of the fishery and assessments of the effects of
management actions, which are not possible without biological and economic information. For
example, cost and revenue information is necessary to evaluate the effects of proposed measures
on efficiency. Cost and revenue information is also necessary to anticipate the likely effects of
proposed measures on participants in the fishery.
sustaining ocean ecosystems” (2001); Improving the collection, management, and use of marine fisheries data” (2000); and “Sharing the fish:
toward a national policy on individual fishing quotas (1999). Recent GAO publications recognizing the importance of commercial fisheries
economic data include “Individual Fishing Quotas: Better Information Could Improve Program Management” (2003); Commercial Fisheries:
Entry of Fishermen Limits Benefits of Buyback Programs (GAO/RCED-00-120); and Fishery Management: Problems Remain With National
Marine Fisheries Service's Implementation of the Magnuson-Stevens Act (GAO/RCED-00-69).

2

(6) Conservation and management measures shall take into account and allow for variations
among, and contingencies in, fisheries, fishery resources, and catches.
The “variations among and contingencies in fisheries” can be defined in terms of both biological
and economic variables. Therefore, both types of information are required.
(7) Conservation and management measures shall, where practicable, minimize costs and avoid
unnecessary duplication.
Economic information, specifically cost information, is required to determine if this national
standard is met.
(8) Conservation and management measures shall, consistent with the conservation
requirements of this Act (including the prevention of overfishing and rebuilding of overfished
stocks), take into account the importance of fishery resources to fishing communities by utilizing
economic and social data that meet the requirements of paragraph (2), in order to (A) provide
for the sustained participation of such communities, and (B) to the extent practicable, minimize
adverse economic impacts on such communities.
There is an explicit requirement to use “economic and social data” to meet this national standard.
Specifically, economic information is required to predict the extent to which conservation and
management measures are expected to provide for the “sustained participation” and “minimize
adverse economic impacts.”
(10) Conservation and management measures shall, to the extent practicable, promote the safety
of human life at sea.
Economic information is required to determine what further improvements in safety are
practicable.
Acting under authorities provided in the MFCMA, the Councils and Secretary have implemented
47 FMPs, each of which addresses biological and socio-economic characteristics and issues
associated with the fishery. For example, the Pacific Coast groundfish FMP includes a
framework for the development and evaluation of management decisions having substantial
socio-economic implications (Section 6.2.3 of the Pacific Coast Groundfish Plan) (see
Attachment A). Where management is necessary to address socio-economic issues, the Council
must prepare a report, which addresses the achievement of goals and objectives of the FMP,
economic impacts and how the proposed action will address at least one of 15 items including:
maintaining stability in the fishery, increasing economic yield, and increasing fishing efficiency.
With respect to allocation actions, the Council must consider such factors as present participation
in and dependence on the fishery, including alternative fisheries, historical fishing practices in
and historical dependence on the fishery, as well as consistency with MFCMA national
standards. FMPs prepared by other Councils address issues comparable to those addressed in the
Pacific Coast groundfish FMP.

3

NEPA
NEPA requires federal agencies to consider the interactions of natural and human environments,
and the impacts on both systems of any changes due to governmental activities or policies. This
consideration is to be done through the use of "a systematic, interdisciplinary approach which
will ensure the integrated use of the natural and social sciences . . . in planning and in decisionmaking. . ." (NEPA Section 102(2)(A) and, further, to “identify and develop methods and
procedures, ….., which will insure that presently unquantified environmental amenities and
values may be given appropriate consideration in decision making along with economic and
technical considerations (NEPA Section 102(2)(B). In addition, NOAA’s NEPA implementation
guidelines require that the environmental impact statement (required under NEPA Section
102(2)(C)(i)) must include both economic and social consequences. 3
E.O. 12866 (currently under revision)
E.O. 12866 requires an assessment of all costs and benefits of available regulatory alternatives.
Under EO 12866, when choosing among regulatory approaches, agencies should select those
approaches that maximize net benefits. (E.O. 12866 Sec. 1(a)). In addition, E.O. 12866 states
that "Each agency shall base its decisions on the best reasonably obtainable scientific, technical,
economic and other information concerning the need for, and consequences of, the intended
regulation." (E.O. 12866 Sec. 1(b)(7)).
This executive order, combined with the MFCMA national standard on use of best scientific
information available, obligate NMFS to seek clearance for the collection of the information
necessary to meet decision standards set out in the national policies outlined above. Regardless
of what action the Council and Secretary take with respect to management of federal fisheries for
2003 and beyond (including no action alternatives), economic information is needed to meet the
requirements listed above.
RFA
The RFA requires federal agencies to fully analyze the effects of regulations to determine
whether an action will "have a significant economic impact on a substantial number of small
entities" [NMFS "Operational Guidelines Fishery Management Plan Process”]. At a minimum,
sufficient information is necessary to allow a determination of whether the impacts will be
"significant." Determination of the significance of impacts requires cost and revenue information
for the specific activity in question (fish harvest and processing) as well as some level of general
information on the full range of income producing activities in which firms are engaged.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
Information will be collected using a series of surveys of the industry conducted by NMFS,
NMFS’ contractor(s) or by NMFS in conjunction with the marine fisheries commissions (Pacific
States Marine Fisheries Commission, Gulf States Marine Fisheries Commission and the Atlantic
States Marine Fisheries Commission). Data collections will focus each year on a different
component of the United States (U.S.) commercial fisheries, with only limited data collected in
3
For NOAA’s NEPA implementation guidelines see, NOAA Administrative Order (NAO) 216-6, "Environmental Review Procedures for
Implementing the National Environmental Policy Act," May 20, 1999.

4

previously surveyed components of these fisheries. These surveys will be administered to
different strata of the harvesting and processing industry over the next three years. It is
anticipated that one or two surveys will be conducted in each NMFS region each calendar year.
All information collected in the survey will be used to provide information on potential impacts
of management decisions on the fishing industry. In general, analysis of cost and revenue
information for harvesting and processing and other activities of the vessel or plant will allow
analysts to estimate:
Net economic value to the nation
Economic health of the fishery
Effects on business efficiency
Community economic impacts
Firms’ economic dependence on the fishery
Economic impacts of proposed regulations, including area closures, gear restrictions, catch
restrictions, etc.
Distribution of economic impacts from proposed regulations and, in particular, the
significance of impacts on small businesses
Likelihood of bankruptcies
Effects on international competitiveness.
It is anticipated that the information collected will be disseminated to the public or used to
support publicly disseminated information. As explained in the preceding paragraphs, the
information gathered has utility. NMFS or a designated marine fisheries commission will retain
control over the information and safeguard it from improper access, modification, and
destruction, consistent with NOAA standards for confidentiality, privacy, and electronic
information. See response to Question 10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed to yield data that meet all
applicable information quality guidelines. Prior to dissemination, the information will be
subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of
Public Law 106-554.
Two economic surveys (one focused strictly on operating expenses and characteristics, the other
requesting more detailed information on operations) used in past data collection exercises are
included as Attachments B and C. Final survey instruments will be provided with each data
collection clearance request initiated under this PRA approval.
In addition to the sample surveys, Attachments D through G are lists of potential questions for
each of the four industry types, catcher and charter vessels, shoreside processors, motherships
and catcher/processors. These lists comprise a source for questions for future surveys. The
following is a summary of the need for each type of question.
Catcher & Charter Boat Surveys - Attachment D
Question 1. Vessel Characteristics: Information on United States Coast Guard (USCG)
identifier, state identifiers, etc., is necessary to help identify specific vessels. While much of the
information on physical descriptors such as hull type, tonnages, length, etc. exists in other
sources, this data is often outdated, missing or conflicting. Information on such items as engines,
5

fuel capacity, electronics and the difficulty in switching gears provides analysts data to model the
likelihood of harvesters switching fisheries given changes in regulations.
Question 2. Ownership: Questions regarding ownership are useful in terms of social interest.
However, evaluation of owner participation also plays a role in predicting whether marginal
vessels will stay in business. For example, the owner of a vessel with zero or slightly negative
net profits may decide to remain in the fishery if the owner is deriving a wage from personally
operating a vessel. On the other hand, an owner who hires a skipper may be more likely to
choose to exit the fishery under a similar circumstance.
Question 3. Capital Costs: This series of questions is designed to estimate market value and
replacement costs of major existing assets, including limited entry permits, and the economic life
of these major assets. These values are used to calculate economic opportunity costs of capital
goods that in turn are used to calculate net economic benefits to the nation of industry
participation as well as for conducting financial analyses as required by the Regulatory
Flexibility Act.
Question 4. Annual Operating Costs: These are expenses that generally do not vary with the
level of production. They are fixed over the short-term but some of them may be forgone if a
vessel owner decided not to engage in any fishing activity for a period of time. The fixed
expenses of participation must be allocated between alternative fishing activities and must be
partially deducted from revenues as a step in determining net economic value. The information
is also needed for the model that assesses community income impacts.
Question 5. Operating Costs: This information is necessary to estimate the net value of
participation in the fishery; calculate producer surplus and short-run economic and financial
profit measures; assess the change in net benefits caused by proposed management actions; and
is used in the Fishery Economic Assessment Model and Illegal, Unreported, and Unregulated
(IUU) IMpact analysis for PLANning (IMPLAN) Model to estimate economic impacts. The
capital costs and operating costs are of value for (1) allocating fixed costs between different
activities; (2) estimating the income impacts if a projection is made that a vessel might stop
operating entirely or be relocated in the absence of an opportunity to participate in a particular
fishery (i.e., if fixed operating expenses are not covered) and (3) assessing, in combination with
catch and revenue information, the relative importance and dependence of the vessel on
harvesting versus other income producing activities of the vessel.
Question 6. Effort/Gear Descriptors: These questions are useful in helping the analyst describe
and quantify effort on the fishing grounds in terms of gear deployed. This information could be
used in developing models of efficient fleet size to support such activities as fleet reduction
programs, as well as provide information on the level of capitalization within the various sectors
of a fishery.
Question 7. Catch/Revenue: Revenue information, in conjunction with cost information, is
necessary to derive net economic value. Additionally, revenue information from all activities is
needed in a method used to allocate fixed costs between different activities and as part of the
assessment of relative dependence on the fishery.

6

For deliveries made onshore, questions about revenue are important to capture end-of-year
settlements or in-kind payments not reflected in the fish tickets. For vessels delivering to
motherships, these questions are particularly important because there are no fish ticket records
for at-sea landings. Information on revenue from other fisheries is needed because of similar
deficiencies in fish ticket records, and lack of access to confidential information for fisheries in
some states.
In addition, if the respondents calculate their net income based on their other answers and the
result is out-of-line with their experience, they may stop to consider whether they have answered
the preceding questions on costs and revenue correctly and entirely. Further, if respondents
provide previously calculated net income without checking for consistency, or analysts compare
the reported values with fish ticket revenue information where available, analysts may derive a
result different from the survey responses alerting them to some degree of incompleteness in
either the survey or the responses to the questions.
Question 8. Opportunity Cost: These economic values are used to calculate net economic
benefits to the nation of industry participation.
Question 9. Regional Impact: One assumption generally made in assessing impacts on coastal
communities is that all employees live in the coastal area of the vessels homeport and,
consequently, crew share is spent in the vessel homeport. Similarly, current models assume all
impacts occur in the port of landing or in a homeport (for vessels delivering to motherships).
This information is particularly important in assigning community impacts for vessels delivering
to motherships but is also useful when the vessel is active in multiple ports. While this
simplifying assumption was useful in the early development of the models used in West Coast
fisheries income impact assessments, more recent versions of this model allow analysts to relax
this assumption. The information solicited by these questions is necessary to make use of this
ability to more accurately estimate the distribution of effects. These questions are intended to
address the issue with better quality information that is more evenly distributed across sectors.
Question 10. Labor/Employee/Family: This information is of interest in terms of effect on the
fishing community and general community employment. Income-related questions will allow a
systematic assessment of the degree to which individuals are engaged and dependent on fishingrelated activities while questions on age, ethnicity, language and education will give social
scientists a better grasp of issues related the socio-cultural background and specifically highlight
potential Environmental Justice issues, such as vulnerability and marginalization.
Question 11. Other: Business strategy, distribution and marketing questions are needed to
assess the bargaining and buying/selling strategies at various levels of the distribution chain.
Understanding these factors greatly aids in the interpretation of changes in prices and costs.
Shoreside Processor Surveys - Attachment E
Question 1. Plant Characteristics: Little information currently exists on shoreside processing
plants such as freezer capacities, processing equipment available, etc. This information is useful
in assessing the ability and desire of plants to process fish and to make general decisions about
which fish/shellfish to process and to formulate decisions of which fish and shellfish to process
in the case of conflicting seasons.
7

Question 2. Ownership: Questions regarding ownership are necessary to provide linkages
between seemingly independent plants. Often, individual plants are treated as separate entities
when in reality they are part of a larger company. Uncovering these linkages is useful to analysts
in modeling the behavior of these companies and plants. In addition, information on the
company ownership of harvesting vessels plays a role in assessing the likely decisions of
marginal plants to stay in business. Finally, plants with a wider species and product base, or
plants that are part of a larger company may be more capable of weathering a fishery downturn
than one that produces a smaller suite of products.
Question 3. Capital Costs and Land Costs: This series of questions is designed to estimate
market values and replacement costs of major existing assets, and economic life of these major
assets. These economic values are used to calculate economic opportunity costs of capital goods,
which in turn are used to calculate net economic benefits to the nation of industry participation.
Question 4 Annual Operating Costs: These are expenses that generally do not vary with the
level of production. They are fixed over the short-term but some of them may be forgone if a
plant owner decides not to engage in any processing activity for a period of time. The fixed
expenses of participation must be allocated between alternative processing activities and must be
partially deducted from revenues as a step in determining net economic value. The information
is also needed for the model that assesses community income impacts.
Question 5. Operating Costs: This information is necessary to estimate the net value of
participation in the fishery; assess the change in net benefits caused by proposed management
actions; and is used in the Fishery Economic Assessment Model and IMPLAN® economic
impact model to estimate income, sales and employment impacts. The capital costs and
operating costs are of value for (1) allocating fixed costs between different activities and
(2) estimating the income impacts if a projection is made that a plant might stop operating
entirely or be relocated in the absence of an opportunity to participate in a particular fishery (i.e.,
if fixed operating expenses are not covered). This information is useful in allocating annual
operating costs across activities in order to assess the marginal net economic value of
participation in the fishery over the long term. Questions regarding operating costs are also
important to capture end-of-year settlements or in-kind payments not captured by the fish ticket
data.
Question 6. Effort: These questions are useful in helping the analyst describe and quantify
effort in terms of length of activity as well as forecast processing costs and employment.
Question 7. Revenue: Revenue information, when combined with cost information, can be used
to derive net economic value. Revenue information is also needed from all activities in a method
used to allocate fixed costs between different activities and as part of the assessment of relative
dependence on the fishery. In addition, if the respondents calculate their net income based on
their other answers and the result is out-of-line with their experience, they may stop to consider
whether they have answered the preceding questions on costs and revenue correctly and entirely.
Further, if respondents provide previously calculated net income without checking for
consistency, or analysts compare the reported values with fish ticket revenue information where
available, analysts may derive a result different from the survey responses alerting them to some
degree of incompleteness in either the survey or the responses to the questions.
8

Question 8. Opportunity Cost: These economic values are used to calculate net economic
benefits to the nation of industry participation, to determine alternative uses of capital under the
existing regulatory environment and to determine potential new uses of capital in light of
regulatory change.
Question 9. Regional Impact: One assumption generally made in assessing impacts on coastal
communities is that all employees live in the coastal area of the plant and, consequently, all
wages are assumed to be spent in there. Similarly, current models assume all economic impacts
occur in the plant port. However, given ownership of multiple plants in different ports by a
single entity, these simplifying assumptions may be erroneous. The additional information
solicited in these questions is necessary to provide the ability to more accurately estimate the
distribution of effects. These questions are intended to address the issue with better quality
information more evenly distributed across sectors.
Question 10. Labor/Employee/Family: This information is of interest in terms of effect on the
fishing community and general community employment. Income-related questions will allow a
systematic assessment of the degree to which individuals are engaged and dependent on fishingrelated activities while questions on age, ethnicity, language and education will give social
scientists a better grasp of issues related the socio-cultural background and specifically highlight
potential Environmental Justice issues, such as vulnerability and marginalization.
Question 11. Other: Business strategy, distribution and marketing questions are needed to
assess the bargaining and buying/selling strategies at various levels of the distribution chain.
Understanding these factors greatly aids interpretation of changes in prices and costs.
Mothership Processor Surveys - Attachment F
Question 1. Vessel Characteristics: Information on USCG identifier, state identifiers, etc., is
necessary to help identify specific vessels. While much of the information on physical
descriptors such as hull type, tonnages, length, etc. exists in other sources, this data is often
outdated, missing or conflicting. Information on such items as engines, fuel capacity, electronics
and the difficulty in switching gears provides analysts data to model the likelihood of harvesters
switching fisheries given changes in regulations.
Little information currently exists on at-sea processing vessels such as freezer capacities,
processing equipment available, etc. This information is useful in assessing the ability and desire
of vessels to process fish and to make general decisions about which fish/shellfish to process and
to formulate decisions of which fish and shellfish to process in the case of conflicting seasons.
Question 2. Ownership: Questions regarding ownership are necessary to provide linkages
between seemingly independent operations. Often, individual operations are treated as separate
entities when in reality they are part of a larger company. Uncovering these linkages is useful to
analysts in modeling the behavior of these companies and vessels. Also, operations with a wider
species and product base, or operations that are part of a larger company may be more capable of
weathering a fishery downturn than one that produces a smaller suite of products.

9

Question 3. Capital Costs: This series of questions is designed to estimate market value and
replacement costs of major existing assets, and the economic life of these major assets. These
values are used to calculate economic opportunity costs of capital goods, which in turn are used
to calculate net economic benefits to the nation of industry participation.
Question 4 Annual Operating Costs: These are expenses that generally do not vary with the
level of production. They are fixed over the short-term but some of them may be forgone if a
vessel owner decided not to engage in any fishing activity for a period of time. The fixed
expenses of participation must be allocated between alternative processing activities and must be
partially deducted from revenues as a step in determining net economic value. The information
is also needed for the model that assesses community income impacts.
Question 5 Operating Costs: This information is necessary to estimate the net value of
participation in the fishery; assess the change in net benefits caused by proposed management
actions; and is used in the Fishery Economic Assessment Model and IMPLAN Model to estimate
income impacts. The capital costs and operating costs are of value for (1) allocating fixed costs
between different activities; (2) estimating the income impacts if a projection is made that a
vessel might stop operating entirely or be relocated in the absence of an opportunity to
participate in a particular fishery (i.e., if fixed operating expenses are not covered). This
information is useful in allocating annual operating costs across activities in order to assess the
marginal net economic value of participation in the fishery over the long term. Questions
regarding operating costs are also important to capture end-of-year settlements or in-kind
payments not captured by the fish ticket data when they are available.
Question 6 Effort/Crew Descriptors: These questions are useful in helping the analyst describe
and quantify effort in terms of length of activity as well as forecast processing costs and
employment.
Question 7 Catch/Revenue: Revenue information, in conjunction with cost information, is
necessary to derive net economic value. Additionally, revenue information from all activities is
needed in a method used to allocate fixed costs between different activities and as part of the
assessment of relative dependence on the fishery.
In addition, if the respondents calculate their net income based on their other answers and the
result is out-of-line with their experience, they may stop to consider whether they have answered
the preceding questions on costs and revenue correctly and entirely. Further, if respondents
provide previously calculated net income without checking for consistency, or analysts compare
the reported values with fish ticket revenue information where available, analysts may derive a
result different from the survey responses alerting them to some degree of incompleteness in
either the survey or the responses to the questions.
Question 8 Opportunity Cost: These economic values are used to calculate net economic
benefits to the nation of industry participation, to determine alternative uses of capital under the
existing regulatory environment and to determine potential new uses of capital in light of
regulatory change.
Question 9 Regional Impact: One assumption generally made in assessing impacts on coastal
communities is that all employees live in the coastal area of the vessels homeport and,
10

consequently, crew payment is spent in the vessel homeport. Similarly, current models assume
all impacts occur in the port of landing or in a homeport. This information is particularly
important in assigning community impacts for vessels active in multiple fisheries, for example,
West Coast whiting and Bering Sea pollock. While this simplifying assumption was useful in
the early development of the models used in West Coast fisheries income impact assessments,
more recent versions of this model allow analysts to relax this assumption. The information
solicited by these questions is necessary to make use of this ability to more accurately estimate
the distribution of effects. These questions are intended to address the issue with better quality
information that is more evenly distributed across sectors.
Question 10 Labor/Employee/Family: This information is of interest in terms of effect on the
fishing community and general community employment. Income-related questions will allow a
systematic assessment of the degree to which individuals are engaged and dependent on fishingrelated activities while questions on age, ethnicity, language and education will give social
scientists a better grasp of issues related the socio-cultural background and specifically highlight
potential Environmental Justice issues, such as vulnerability and marginalization.
Question 11 Other: Business strategy, distribution and marketing questions are needed to assess
the bargaining and buying/selling strategies at various levels of the distribution chain.
Understanding these factors greatly aids in the interpretation of changes in prices and costs.
Catcher/Processor Surveys - Attachment G
Question 1 Vessel Characteristics: Information on USCG identifier, state identifiers, etc., is
necessary to help identify specific vessels. While much of the information on physical
descriptors such as hull type, tonnages, length, etc. exists in other sources, this data is often
outdated, missing or conflicting. Information on such items as engines, fuel capacity,
electronics, and the difficulty in switching gears provides analysts data to model the likelihood of
harvesters switching fisheries given changes in regulations.
Little information currently exists on at-sea processing vessels such as freezer capacities,
processing equipment available, etc. This information is useful in assessing the ability and desire
of vessels to process fish and to make general decisions about which fish/shellfish to process and
to formulate decisions of which fish and shellfish to process in the case of conflicting seasons.
Question 2 Ownership: Questions regarding ownership are necessary to provide linkages
between seemingly independent operations. Often, individual operations are treated as separate
entities when in reality they are part of a larger company. Uncovering these linkages is useful to
analysts in modeling the behavior of these companies and vessels. Also, operations with a wider
species and product base, or operations that are part of a larger company may be more capable of
weathering a fishery downturn than one that produces a smaller suite of products.
Question 3 Capital Costs: This series of questions is designed to estimate market value and
replacement costs of major existing assets, including limited entry permits, and the economic life
of these major assets. These values are used to calculate economic opportunity costs of capital
goods, which in turn are used to calculate net economic benefits to the nation of industry
participation.
11

Question 4 Annual Operating Costs: These are expenses that generally do not vary with the
level of production. They are fixed over the short-term but some of them may be forgone if a
vessel owner decided not to engage in any fishing activity for a period of time. The fixed
expenses of participation must be allocated between alternative processing activities and must be
partially deducted from revenues as a step in determining net economic value. The information
is also needed for the model that assesses community income impacts.
Question 5 Operating Costs: This information is necessary to estimate the net value of
participation in the fishery; assess the change in net benefits caused by proposed management
actions; and is used in the Fishery Economic Assessment Model and IMPLAN model to estimate
income impacts. The capital costs and operating costs are of value for (1) allocating fixed costs
between different activities; (2) estimating the income impacts if a projection is made that a
vessel might stop operating entirely or be relocated in the absence of an opportunity to
participate in a particular fishery (i.e., if fixed operating expenses are not covered). This
information is useful in allocating annual operating costs across activities in order to assess the
marginal net economic value of participation in the fishery over the long term. Questions
regarding operating costs are also important to capture end-of-year settlements or in-kind
payments not captured by the fish ticket data when they are available.
Question 6 Effort: These questions are useful in helping the analyst describe and quantify effort
in terms of length of activity as well as forecast processing costs and employment.
Question 7 Catch/Revenue: Revenue information, in conjunction with cost information, is
necessary to derive net economic value. Additionally, revenue information from all activities is
needed in a method used to allocate fixed costs between different activities and as part of the
assessment of relative dependence on the fishery.
In addition, if the respondents calculate their net income based on their other answers and the
result is out-of-line with their experience, they may stop to consider whether they have answered
the preceding questions on costs and revenue correctly and entirely. Further, if respondents
provide previously calculated net income without checking for consistency, or analysts compare
the reported values with fish ticket revenue information where available, analysts may derive a
result different from the survey responses alerting them to some degree of incompleteness in
either the survey or the responses to the questions.
Question 8 Opportunity Cost: These economic values are used to calculate net economic
benefits to the nation of industry participation, to determine alternative uses of capital under the
existing regulatory environment and to determine potential new uses of capital in light of
regulatory change.
Question 9 Regional Impact: One assumption generally made in assessing impacts on coastal
communities is that all employees live in the coastal area of the vessels homeport and,
consequently, crew payment is spent in the vessel homeport. Similarly, current models assume
all impacts occur in the port of landing or in a homeport. This information is particularly
important in assigning community impacts for vessels active in multiple fisheries, for example,
West Coast whiting and Bering Sea pollock. While this simplifying assumption was useful in
the early development of the models used in West Coast fisheries income impact assessments,
more recent versions of this model allow analysts to relax this assumption. The information
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solicited by these questions is necessary to make use of this ability to more accurately estimate
the distribution of effects. These questions are intended to address the issue with better quality
information that is more evenly distributed across sectors.
Question 10 Labor/Employee/Family: This information is of interest in terms of effect on the
fishing community and general community employment. Income-related questions will allow a
systematic assessment of the degree to which individuals are engaged and dependent on fishingrelated activities while questions on age, ethnicity, language and education will give social
scientists a better grasp of issues related the socio-cultural background and specifically highlight
potential Environmental Justice issues, such as vulnerability and marginalization.
Question 11 Other: Business strategy, distribution and marketing questions are needed to assess
the bargaining and buying/selling strategies at various levels of the distribution chain.
Understanding these factors greatly aids in the interpretation of changes in prices and costs.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
To help reduce burden on the public, the surveys will be available on the web for viewing,
downloading and, to the extent practicable, completion online. In addition, for mail surveys,
respondents will have an option of sending completed surveys via mail or by facsimile machine.
Lastly, the appropriate electronic mail addresses or telephone numbers will be supplied with
surveys mailed to fishing industry members.
4. Describe efforts to identify duplication.
In the development of each survey, every attempt will be made to identify whether other surveys
are currently collecting similar data from a population that includes some potential respondents
for the proposed data collection. Since NMFS economists will develop or oversee the
development of the sampling frame for each survey, a cross-check with all other economic
survey sample frames will be done prior to finalizing a survey’s sample frame can be easily
accomplished. A potential respondent already providing comparable information under a similar
survey may be excluded from the survey’s sample frame.
In addition, in developing the survey instrument, a NMFS economist will either
a) verify that a question does not duplicate a question on an existing survey instrument; or
b) certify why the information collected under the existing data collection is inadequate,
e.g., confidentiality restrictions.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
The vast majority of catcher vessels and processors affected by this information request are
considered small business. The burden will be the same for all businesses, regardless of size,
and has been minimized to collect only that information essential to regulatory analysis and
modeling. Respondents should be able to derive the requested information from past income tax
records, payroll records and fish management reporting records (including fish tickets and
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logbooks). No additional data aggregation by the respondents should be necessary to respond to
these surveys.
Another area where the burden on the industry can be reduced is in regards to the vessel or plant
characteristics questions. Some of these questions request an update of data that has been
collected in the past. Where available, the survey instrument will provide the information as it is
currently available and ask the respondent to submit corrections as necessary.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
The standards for making substantial changes in the management of a fishery require a clear
demonstration that benefits will increase as a result of the change in allocation. In the absence of
adequate information, failure to demonstrate a substantial improvement in benefits does not
necessarily mean that such a change would not generate those benefits; it simply means that the
information was not available to demonstrate change. Alternatively, partially specified
indicators of benefits, such as reliance on gross revenues rather than net revenues, could lead to a
change which would decrease, rather than increase, net benefits to the nation. Therefore, not
collecting this information could prevent or misdirect decisions.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
These information collections are consistent with Office of Management and Budget (OMB)
guidelines.
8. Provide information on the PRA Federal Register Notice that solicited public comments
on the information collection prior to this submission. Summarize the public comments
received in response to that notice and describe the actions taken by the agency in response
to those comments. Describe the efforts to consult with persons outside the agency to
obtain their views on the availability of data, frequency of collection, the clarity of
instructions and recordkeeping, disclosure, or reporting format (if any), and on the data
elements to be recorded, disclosed, or reported.
A Federal Register Notice published on February 10, 2009 (74 FR 6576) solicited public
comment on this collection.
A comment was received from representatives of the Alaska fishing industry. Their concerns
included a) whether information could be included in a Freedom of Information Act (FOIA)
request; b) whether the burden hours were underestimated; c) the “rotating” survey schedule
across different segments of the industry; and d) the use of automated techniques. The lead
economist at the NMFS Alaska Fisheries Science Center, Ron Felthoven, has responded to those
concerns, including explaining the measures taken to protect confidentiality; the need to limit the
burden hours in a voluntary survey (the industry representatives had suggested a 60-80 burden
hour, which clearly exceeds what can reasonably be asked in a voluntary survey), how the
surveys would be rotated among different components of the fishing industry in a region, and
how automated techniques have been used in other regions. Through this discussion, it became
clear that the industry representatives thought the Federal Register Notice was announcing a new
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series of surveys in their region and were unaware that it was for a generic clearance (no specific
survey was approved) and that this was the fourth renewal of this generic clearance.
Nevertheless, an item to address industry’s concerns has been added to the next North Pacific
Fisheries Management Council agenda.
A number of people, both within agencies and the industry were consulted on the types of data
elements necessary and available, recordkeeping disclosures, confidentiality of the data and
timing of data collection exercises. Section B, Question Number 5 of this information collection
request has a partial list of Agency contacts.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
There are no plans to provide any payment or gift to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
The survey forms will contain the following language:
The data collected will be kept confidential as required by section 402(b) of the MagnusonStevens Act as amended in 2007 (16 U.S.C. 1881a, et seq.) and NOAA Administrative Order
216-100, Confidentiality of Fisheries Statistics, and will not be released for public use except in
aggregate statistical form without identification as to its source.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
The only potentially sensitive questions included in the generic list of questions are religion and
household income. These questions will be collected directly from each individual -- not via the
individual's employer.
Religion is an important variable because it may affect days when fishing is considered
appropriate or inappropriate, requirements for using specific living marine resources in festivals,
solidarity of social connections and support networks based on religious affiliation or
membership in a particular congregation, among other things.
Household income can be an important indicator of household economic resiliency and can be an
important factor to consider when evaluating regulatory alternatives. For example, all else equal,
a regulation that disproportionately affects low-income households may be less preferred than
one that more widely distributes economic impacts. In addition, combining respondents’
household income information with home address data can be used to construct an indicator on
community economic resilience, which may be useful when analyzing economic impact on
communities as required under National Standard 8 of the MFCMA [MFCMA Section
301(a)(8))].

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12. Provide an estimate in hours of the burden of the collection of information.
The total burden hours are projected to be 7,000 hours per year. An estimate of the annual
number of expected responses and burden hours for the economic surveys are shown below.
Fleet
Catcher & For-Hire Operating Costs only
Catcher, For-Hire Operating, Fixed Costs, Limited
Demographic & Firm Characteristics
Fixed Cost, Limited Demographics & Firm Characteristics
West Coast & Alaska Processors
East Coast & Gulf Coast Processors
Total

Expected # Hours per Burden
Responses Response hours
25
minutes
1402
3365
2750
685
75
125

7000

1.5
1
8
1.5

4125
685
600
188
7000

13. Provide an estimate of the total annual recordkeeping/reporting cost burden to the
respondents resulting from the collection (excluding the value of the burden hours in
Question 12 above).
There are no recordkeeping/reporting costs.
14. Provide estimates of annualized cost to the Federal government.
No additional NMFS staff will be utilized other than those regularly assigned to support this
collection of information mandated by law. In addition, no special or new equipment will be
procured for the special purpose of conducting this information collection. In the Northeast,
Alaska, and Northwest Regions, the annualized cost for NMFS to implement its economic
surveys is estimated to be $150,000 - $200,000 per region. In the Southeast, Southwest and
Pacific Island Regions, the annualized cost for NMFS to implement its economic surveys is
estimated to be $75,000 per region.
15. Explain the reasons for any program changes or adjustments.
There are no changes.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The results from the proposed data collection are not planned for statistical publication. Data
will be used as empirical input in descriptions of current economic performance in the
commercial snapper-grouper and mackerel fisheries, and in evaluations of proposed regulations
in the fisheries. Descriptive and analytical reports will include summaries of the data (totals and
averages only) and will not release or reveal confidential information.

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17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
NA.
18. Explain each exception to the certification statement.
NA.

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