0631 SS 120115 Part A

SUPPORTING STATEMENT

ECONOMIC EXPENDITURE SURVEY OF GOLDEN CRAB FISHERMEN IN THE

U.S. SOUTH ATLANTIC REGION

OMB CONTROL NO. 0648-0631

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.

The National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service (NMFS) proposes to reinstate an annual data collection of economic information for the South Atlantic golden crab fishery. The golden crab (chaceon fenneri) dwells on the continental shelf along the Southeast coast and the west coast of Florida. There is presently a small commercial fishery (six or fewer participants for the past decade) under the jurisdiction of the South Atlantic Fishery Management Council (SAFMC). Although the Council capped the number of issued permits at 11, the sensitive nature of the habitat where fishermen lay crab pots (alongside deepwater coral reefs) poses ecological risks if the fishery is not carefully managed.

Economic data was last collected by NOAA on this fishery in 2011, under OMB Control No 0648-0631. We are planning at this point to continue to collect this information every five years.

The Magnuson-Stevens Fishery Conservation and Management Act as amended in 2006 (MSA) (16 U.S.C. 1853a et seq.) states that collection of reliable and current data is essential to the effective conservation, management, and scientific understanding of the fishery resources of the United States. The nation's fisheries should be "conserved and maintained so as to provide optimal yield (OY) on a continuing basis". Furthermore, the MSA requires that fishery management plans include a Fishery Impact Statement (FIS), which assesses, specifies, and describes the likely effects of the conservation and management measures on participants in the fisheries being managed, fishing communities dependent on these fisheries, and participants in fisheries in adjacent areas.

In addition to the needs of the MSA, the Regulatory Flexibility Act (RFA, 5 U.S.C. 601 et seq.), the National Environmental Policy Act (NEPA, 42 U.S.C. 4372 et seq.), and Executive Order (EO) 12866 aalso require socio-economic data collections. Under the RFA, the Small Business Administration needs a determination of whether a proposed rule has a significant impact on a substantial number of small entities that are to be directly regulated. For RFA purposes, one of the criteria to determine significant economic impact involves an assessment of the change in short-term accounting profits for small entities. The NEPA requires a determination of whether Federal actions significantly affect the human environment. This requires a number of economic analyses including the impact on entities that are directly regulated and those that are indirectly affected. Lastly, EO 12866 mandates an economic analysis of the benefits and costs to society of each regulatory alternative considered by the fishery management councils, and a determination of whether the rule is significant.

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.

The survey data will be incorporated into economic expenditure and economic impact models of the golden crab fishery. Information from those models may appear in regulatory amendments of the SAFMC, NOAA technical memorandums, and academic research projects.

Questions #1 through #3 ask participants in the fishery to provide information on the means by which the captain and crew are paid. This is necessary to separate out the portion of landings revenues that are retained as owner profits versus those that are paid as wages.

Questions #4 through #7 ask for information on trip expenses, which is necessary to build economic models that can estimate the impact of regulations on profitability, and are standard on most fishing expenditure survey.

Questions #8 through #12 ask for annual boat maintenance costs, which will be used to build a more complete economic model of the crab fishing sector.

Questions #13 through #17 ask for information on the most common gears and technologies used on golden crab fishing boats. As fishermen replace this equipment, it has an impact on their per-trip productivity and (in the case of refrigerated seawater) on the final sale price of the product.

Questions #18 through #20 ask for the opinions on the potential impact of the a catch-share system in the fishery, which is currently under consideration by the South Atlantic Fishery Management Council. Information on this subject is currently lacking and will be useful for estimating the impact of shifting to this new and very different regulatory regime.

NOAA Fisheries Service will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy. The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subject to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.

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.

The proposed data collection will utilize both voluntary, self-administered mail surveys and follow-up in-person interviews (if necessary). Because the population of active fishermen is extremely small, it is essential to make a complete census of the golden crab participants. Self-administered mail surveys will be the initial instrument, but telephone or in-person interviews will used if necessary to complete the data collection or to clarify answers.

Initially, all respondents will be contacted via an introductory letter to inform them about the upcoming data collection. Subsequently, fishermen will be provided with the self-administered survey instrument, and asked to return it completed using an enclosed postage pre-paid envelope. If no response is received, then the fishermen will be contacted by phone and urged to return the completed survey, followed by a site visit if necessary. All data will be entered into a desktop computer.

The data collected will not be available to the public over the internet given its confidential nature. However, analytical results of studies based on this data will be disseminated to management agencies and peer-reviewed publications. Some of these studies will likely be available online.

4. Describe efforts to identify duplication.

We have investigated to find whether there are any federal or state efforts to collect similar socio-economic information from the golden crab fishery. The state of Florida is not planning any such survey, and at a recent meeting of the North American Association of Fisheries Economists (NAAFE), informal talks discovered no other efforts directed towards this fishery. Dr. Crosson has attended meetings of the SAFMC Golden Crab Advisory Panel, and none of the fishermen there were aware of any efforts by academic or state researchers to collect economic data from the participants.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

Many commercial fishing operations are owner- or family-operated small businesses, including all six (6) members of this fishery. We have taken several steps to minimize the burden to these small businesses. First, we designed the survey instrument so that only the minimum data requirements for present and future management needs are collected. This will minimize any potential disruption to fishers’ fishing practices. Last, fishers who receive the self-administered survey will be provided with postage-paid return envelopes

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

If these data were collected less frequently or not at all, then the legal requirements set forth by the MSA, NEPA, and EO 12898 would not be met. For example, the MSA requires a formal and detailed review 5 years after the implementation of the IFQ program. The review to be conducted by the SAFMC and Secretary of Commerce must determine whether the program is satisfying the stated goals in the FMP. If current and accurate data are not available then economic assessments of management actions will be potentially inaccurate, thereby leading the SAFMC and NMFS to make poor management decisions. The MSA requires the establishment conservation and management measures to protect the resource, increase social and economic benefits and increase safety using the best available information.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

There are no special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

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 Wednesday, September 23, 2015 (Vol. 80, No. 184) solicited public comments. No comments were received.

Results of consultations with persons outside the agency: The original questionnaire was reviewed by outside fisheries economists and was accepted as part of the methodology in a peer-reviewed journal article.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts will be provided to questionnaire respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

Survey respondents will be advised that any information provided will be considered private and will be treated as confidential in accordance with NOAA Administrative Order 216-100, Confidential Fisheries Statistics and section 402(b) of the MSA (16 U.S.C. 1801, et seq.).

It is NMFS’ policy not to release confidential data, other than in aggregate form, as the MSA protects (in perpetuity) the confidentiality of those submitting data. Whenever data are requested, the Agency will ensure that information identifying the pecuniary business activity of a particular individual is not identified. Only group averages or group totals will be presented in any reports, publications, or oral presentations of the study's results.

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.

No questions will be asked about sexual behavior and attitudes, religious beliefs, or other similar matters of a personal and sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.

It is estimated that the number of respondents will be six and the time per response is about one half hour, for a total annual burden of three hours. The one half hour per response burden includes the time for reading the instructions, reviewing the questions, and completing (and mailing, if necessary) the survey instrument.

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).

There will be no financial cost to the public to participate in this study.

14. Provide estimates of annualized cost to the Federal government.

The costs of administering this survey will be absolutely minimal. The NMFS staff will be responsible for developing and administering the survey, but as stated the number of participants is no more than ten and will likely be no more than five. The cost of NMFS staff time is estimated at $2,000. Mailing costs will be incidental.

15. Explain the reasons for any program changes or adjustments.

The program change is for the collection of new socio-economic data.

16. For collections whose results will be published, outline the plans for tabulation and publication.

Data collected will be used to assess the economics of the golden crab fishery, and if necessary the performance of the golden crab IFQ program implemented by Amendment Five. Descriptive and analytical reports will include summaries of data. These reports will not release or reveal confidential information. Depending on the availability of funds, we anticipate that reports will be available January 2017. These reports will likely be available in pdf format on the NMFS Southeast Fisheries Science Center’s web site.

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.

Not Applicable.

18. Explain each exception to the certification statement.

Not Applicable.

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