0635 Supporting Statement Part A 080117

SUPPORTING STATEMENT

Economic Surveys of American Samoa, Guam, and the Commonwealth of the Northern Mariana Islands Small Boat-based Fisheries

OMB CONTROL NO. 0648-0635

A. JUSTIFICATION

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

This is a request for extension of a previously approved information collection.

The Magnuson-Stevens Conservation and Management Act (MSA) mandates that conservation and management measures prevent over-fishing and obtain an optimum yield on a sustained basis and the measures shall be based upon the best scientific information available. The MSA also requires that conservation and management measures take into account the importance of fishery resources to fishing communities in order to: (a) provide for the sustained participation of such communities, and (b) to the extent practicable, minimize adverse economic impacts on such communities. To promote better utilization and management of fishery resources in American Samoa, Guam, and the Commonwealth of the Northern Mariana Islands (CNMI), the National Marine Fisheries Service (NMFS) proposes the collection of fishing expenses data in these three island areas’ boat-based reef fish, bottomfish, and pelagic fisheries.

The chief domestic fishery of these three areas is a small boat, 1- to 2-day fishery. The fishery is important to the local community in terms of a fresh food source and the island culture. The fishery lands approximately 13 pounds of fresh fish per capita in CNMI and 4 pounds each of fresh fish per capita in Guam and American Samoa¹ annually. The fishing activities are usually a mix of commercial and non-commercial fishing, with slightly more than half of the fish landed being commercial landings and the rest of the fish landed, non-commercial landings (mostly for subsistence use). Given the importance of the small-boat fishery to these island areas’ communities and economies, it is critical to monitor changes among key economic indicators through economic data collection.

Fisheries in these areas are managed under the Western Pacific Region Fishery Management Council (WPRFMC). The paucity of economic data has been a significant hurdle in evaluation of economic impact and regulatory proposals in American Samoa, Guam, and the CNMI. Most of the existing economic information is limited to dockside value data. Fishing expenses data about small boat-based fisheries in these three island areas are limited and outdated (see Hospital and Beavers (2012², 2014³), Miller (2001)⁴ and Kasaoka (1989)⁵). The most recent studies by Hospital and Beavers (2012, 2014) were conducted in 2011 to update the baseline socioeconomic information of small boat fisheries in the Mariana Archipelago (targeted almost the same population in Guan and CNMI) and to explore the basic behavioral characteristics of these fisheries. However, it was a one-time study based on the 2010 to 2011 operation. The earliest economic study in the three areas by Miller (2001) and Kasaoka (1989) collected data only in a particular year with small sample size (n<=40) and nothing has been done on a routine basis. Because this dated research is inadequate to support current management actions and meet the requirements put forth by MSA, we are proposing updating our knowledge of fishing expenses in these areas.

The goal of this study is to continue to collect economic information on small boats, begun in 2015, that operate in American Samoa, Guam, and the CNMI, to support economic performance measures and improve fishery management of small boat fisheries in these areas. Establishing an economic data collection program will provide fundamental economic information for the fisheries management of these three areas. The information collected will be used to: 1) satisfy regulatory objectives and analytical requirements through the collection of economic data for these fleets, and 2) assist the WPR FMC in selecting policies that meet conservation and management goals and minimize to the extent possible any adverse economic impacts to fishery participants.

In addition to the need and the authorization to collect these economic data are found in the MSA (16 U.S.C. 1801 et seq.), 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 EPA Executive Order (EO) 12866 also apply. The MSA notes that collection of reliable data is essential to the effective conservation, management, and scientific understanding of the fishery resources of the United States. The nation's fisheries should be "conserved and maintained so as to provide optimum yields on a continuing basis". Furthermore, eight of the ten National Standards under the MSA, which provide guidance to the regional fishery management councils, have implications for economic analyses. For example, under section 303 (a) (9) of the MSA, a fishery management plan must include a Fishery Impact Statement (FIS), which assesses, specifies, and describes the likely effects of the conservation and management measures on participants in the fisheries being managed, fishing communities dependent on these fisheries, and participants in fisheries in adjacent areas. Under the RFA, the Small Business Administration needs a determination of whether a proposed rule has a significant impact on a substantial number of small entities that are to be directly regulated. For RFA purposes, one of the criteria to determine significant economic impact involves an assessment of the change in short-term accounting profits for small entities. The NEPA requires a determination of whether Federal actions significantly affect the human environment. This requires a number of 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 proposed economic data collection intends to collect fishing expenses data including the actual fishing trip expenses, input usage, and input prices in boat-based reef fish, bottomfish, and pelagic fisheries in American Samoa, Guam, and CNMI. Specifically, the surveys intend to collect information on: gallons of fuel used for the fishing trip, price per gallon of fuel, cost of ice used, cost of bait & chum used, cost of fishing gear lost, and the engine type of the boat. These economic data are collected through an add-on to the boat-based creel survey initiated by the local fisheries agencies in American Samoa, Guam, and CNMI to collect fisheries-dependent data. These agencies partner with the Western Pacific Fisheries Information Network (WPacFIN), a NMFS program for technical support. The boat-based creel survey utilizes a systematic random sampling protocol around the islands and at their major boat ramp/port areas. The local staff conducts in-person boat-based surveys on randomly chosen days (usually eight days) a month. The boat-based creel survey mainly collects fishing effort, catch information, and species composition of the catch for the trip about which the fisherman is interviewed as he returns to the boat ramp/port areas.

The economic add-on provides valuable longitudinal fishing expenses data as opposed to previous one-time data collections. The information sought is used by the NMFS economists and WPRFMC staff to perform economic analysis of fisheries in the three island areas. So far, from the current information collection, two annual reports and one Stock Assessment and Fishery Evaluation (SAFE) report were produced and provided to the Western Pacific Fishery Management Council. The reports included the descriptive statistics and analysis of fishing expenses by gear type for each of the island areas. The descriptive statistics and analysis of fishing expenses showed an increase in the fishing costs due to the increase of fuel prices. Also, the data collected showed that different gears showed significantly different fishing costs. These reports provide valuable information to the council for management purposes, in the case of a future specific policy affecting a particular fishing gear, e.g. banning of scuba spearfishing.

The reports also estimated the net trip revenue, because the trip revenue can be derived given catch data collected by creel survey and pricing information collected by WPacFIN. For the commercial fishery, fishing trips are made as long as the net trip revenue is expected to be positive, as the trip will generate additional revenue to cover part of the long run costs like loan payment and boat insurance. The net trip revenue affects fishing effort; therefore, it is a very important indicator of the dynamic of the fishing effort in short run and fishing industry development in long run. It can also be used to examine any significant short-term economic impact from conservation and management measures.

Although this has not yet been done, the expenditure data collected can be used to develop regional economic models for fisheries in these three areas, such as Input-Output (I-O) models (theoretical framework of I-O model was developed by Wassily Leontief).⁶ The economic data collected can be applied to the I-O model so that the fishery sector’s economic contribution, linkages, and impacts to the overall economy can be assessed. I-O model analyses can also assess how fishery sector and local economy will be impacted by any conservation and management measures. Results from I-O analyses will not only provide indicators of social-economic benefits of the marine ecosystem, a performance measure in the NMFS Strategic Operating Plans, but also be used to assess how fishermen and the economy will be impacted by and respond to regulations likely to be considered by fishery managers. Two studies about the impacts of Hawaii’s longline fishing regulations using the I-O model, by Cai, Leung, Pan, and Pooley (2005)^7,8 are good examples of the use of economic data to quantify the impacts of regulations to the fishery sector and the rest of economy.

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NOAA, National Marine 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 subjected 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 of fishing expenses data is conducted through a voluntary, in-person intercept interview methodology, the same method that is used by the boat-based interview of the creel survey. The data are collected in conjunction with the catch and effort data that are already being collected in the Boat-based Creel Survey in the three island areas. The Boat-based Creel Survey includes two studies: 1) a Boat-based Participation Count to collect participation data around the island, and 2) a Boat-based Access Point Survey. The Boat-based Access Point Survey collects two types of data during a randomly selected survey date at the selected port, including a Boat-based Boat Log that logs all the boats going out and coming back and a Boat-based Interview that intercepts fishermen after their fishing trip about the catch and effort information, the species composition, the percentage of catch that is sold. The data collected are then expanded to estimate total landings by gear type for these three areas. The boat-based interview is voluntary and in-person. Our proposed economic survey is an add-on to the Boat-based Interview Form. Given the long history of the creel survey program, the collection of the trip expenses data is also voluntary and in-person. The data collection does not involve any use of automated, electronic, mechanical, or other technological techniques or other forms of information technology. The economic data collection is an add-on to the boat-based in-person interviews and the data are recorded manually on the paper survey, so it is not possible to submit the data electronically unless it is inputted into the computer. As the fishing expenses data is for that particular fishing trip, it is better to obtain the fishing expenses at the same time with the boat-based in-person interview. Interviewers will not use laptops or other computers to directly enter the answers being provided because the interview location is usually near the water.

We do plan to make copies of the OMB approved survey instrument available online on Pacific Island Fisheries Science Center (PIFSC)’s website for outreach and information purposes. The data collected will not be available to the public over the internet given its confidential nature. However, a report summarizing the salient, aggregated results will be available online once the data collection and analysis are completed.

4. Describe efforts to identify duplication.

We contacted the local agencies that support the Boat-based Creel Survey programs in American Samoa, Guam, and CNMI to inquire about their upcoming data collection efforts; none of them planned data collection initiatives dealing with fishing expenses of boat-based fisheries in the upcoming years. The Boat-based Creel Survey programs are organized by the local agencies in partnership with the WPacFIN, which is housed within the PIFSC. The participating agencies include: American Samoa Department of Marine and Wildlife Resources (DMWR), Guam Department of Agriculture’s Division of Aquatic and Wildlife Resources (DAWR), and CNMI government Department of Lands and Natural Resources’ Division of Fish & Wildlife (DFW).

A literature review was conducted to find studies that collect boat-based fishing expenses data in the three island areas. Information collected by Miller (2001) and Kasaoka (1989) is outdated, and based on one-time surveys with small sample sizes. The most recent studies by Hospital and Beavers (2012, 2014) at PFISC targeted almost the same population (Guam, CNMI, but not American Samoa) but it was also a one-time study to collect the baseline socioeconomic information of the Marianas small boat fisheries.

The above studies are one-time, comprehensive surveys, and they are different from the current study that is: 1) a continuous, long-term data collection project, 2) focused only on a few major trip expense items, and 3) concurrent with the data collected from the creel survey. This generates economies of scale, as the cost to administrate two separate surveys is much higher than the making the proposed survey separate (see response in Question 14 for cost). This also allows the linkage of trip expenses data with trip efforts and trip revenues data collected in the creel survey and therefore enhances the use of information and economic analyses as mentioned in Question 2.

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

Fishermen censuses suggest that most commercial fishing operations are owner or family operated small businesses. Steps to minimize the burden to these small businesses include: 1) following the same sampling method as the Boat-based Interview portion of the creel survey, interviews are conducted only on the randomly selected sample dates when fishermen finish their fishing trip, 2) the participation in the survey is completely voluntary (interviewers are trained to request permission to do a survey. If a fisherman refuse to do the survey or if the interviewers sense a fisherman does not want to provide data, the interviewers will terminate the interview immediately and thank the fisherman for his/her time), 3) only five major trip expense items and one question about engine type are asked, with the actual time to complete the questions be between 5 to 10 minutes.

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

If this information were not collected (or collected less frequently), then the legal requirements put forth by the MSA, NEPA, RFA, and EO 12866 would not be adequately satisfied. These mandates require regional fishery management councils to establish conservation and management measures which take into account the importance of fishery resources to fishing communities in order to provide sustained fishing community participation and to minimize, to the extent possible, adverse economic impacts on such communities. Particularly, RFA requires a determination of any proposed rule that has a significant economic impact to small businesses. Furthermore, these requirements also mandate that regional fishery management councils establish conservation and management measures using the best available information.

The absence of detailed economic information would prevent the identification of communities that are engaged and dependent on fishing and the estimation of adverse economic impacts on these communities. Management proposals would continue to be debated without sound information. Another consequence of not having the appropriate economic data could be court challenges on the grounds of inadequate analysis. Last, the collection of detailed economic data will allow fishery managers to make timely and better-informed decisions by having the best scientific information available. If the collection were conducted less frequently, the economic analysis would become less reliable.

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

None.

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 April 7, 2017 (82FR 16999) solicited public comment. No comments were received.

We consulted with the three creel survey data managers in each of the island areas, to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, on the data elements to be recorded and on the accuracy of the burden estimates. All managers gave very positive responses to the current on-going program. Because no public report on the data has produced, no comments about the disclosure or reporting format were sought.

For Guam, the main organizer of the creel survey Brent Tibbatts was contacted by email and he replied on March 30, 2017. For American Samoa, the creel data manager Tepora Toliniu Lavata’i was contacted by email and she replied on April 10, 2017. For CNMI, the creel data manager David Benavente was contacted by email and he replied on April 10, 2017. The table below records the managers’ specific responses.

	Brent Tibbatts (Guam)	Tepora Toliniu Lavata’i (American Samoa)	David Benavente (CNMI)
Q1. Do you think the economic data in the survey are readily available?	For the most part, yes. Since the survey is voluntary, some refused to answer.	Yes.	Most fishermen were able to answer economic information that was asked of them.
Q2. For the frequency of collection, do you think it is adequate?	Yes.	Yes.	In general boat based surveys if conducted correctly did yield adequate data, however surveyor error has been the major cause for lack of economic data.
Q3. Do you think the fishermen had clear instructions to answer the survey?	Not always. I think a reason is there was not clear instruction to DAWR staff about the purpose of the questions.*	Yes.	Fishery Data Staff (FDS) would often forget or mistakenly omit asking about economic information if their shift was short staffed or if they had large quantities of fish to record.
Q4. The estimated interviewing time per respondent is 10 minutes. Do you think it is reasonable? If not, what do you think is the actual interviewing time per respondent?	The interview time is actually less. I think it's adequate.	Ten minutes is a reasonable time.	Most interviews could be completed in under ten minutes. However this is dependent on the amount of fish caught by each respondent.
Q5. What do you think on the recordkeeping of the surveys?	(No answer).	I don’t have access to previous records unless it’s through DIAS so it’s great to have Digital Image Archive System (DIAS) in place.	This aspect could greatly be improved, but the change would have to come from within the agency.**
Q6. What do you think on the data elements to be recorded?	I don’t think price of fuel is useful (in a short term). Everyone pays the same, whatever the current rate is on Guam.	I think it is sufficient data and all that information should be reflected in the data system.	I think that the data elements recorded are adequate and the information obtained is useful if it’s being collected consistently.

*See in B.3 that a brochure will be developed for the fishermen, showing the purpose and the data. This will be socialized with visits to all three sites.

** Clarification: CNMI department could do a better job of maintaining records of the surveys. Response: With the continuous overturn of managers in the CNMI creel survey program, there really hasn't been any continuity in how the surveys are managed over the last couple years of years. We hope to get a permanent manager soon, but there is no ETA for that. Note that the survey in the CNMI is not managed directly by NOAA, but by the CNMI government Department of Lands and Natural Resources’ Division of Fish & Wildlife (DFW).

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 respondents.

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

Survey respondents are being advised that any information provided will be considered private. It is the Agency’s policy not to release personally and business identifiable data, other than in aggregate form, as the NMFS protects such 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.

We will follow PIFCS’s policy of data aggregation: Any fishery-wide aggregations of data shall include information from three or more individual vessels. Effort information, including just the presence of fishing, can be just as sensitive as the actual catch itself. All data analysis programs should include a procedure for calculating the number of vessels within the aggregate. Wherever possible, aggregations should be large enough to include more, rather than fewer, vessels.

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 sensitive questions will be asked.

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

We estimate the annual number of respondents, number of responses per respondent, and total responses in each area, based on the average responses of economic surveys in Guam (2013-2015), CNMI (2011-2015), and American Samoa (2011-2015). The number of respondents in each area is estimated based on the average number of unique boats interviewed in economic surveys in each island areas. The number of responses per participant is derived from the average number of interviews conducted at different trips during different times of the year. We anticipate 600 economic surveys annually and each survey takes about 10 minutes. The total burden hours are estimated to be 100. Table 1 below shows the details.

Table 1. Burden Hours Per Year

	Guam	CNMI	American Samoa	Total
Number of respondents (boats)	125	100	20	245
Number of responses per respondent (number of trips per boat)	2	1.5	10	-
Total responses (trips)	250	150	200	600
Average response time per response (minutes)	10 min.	10 min.	10 min.
Total Burden (hours)	41.67	25	33.33	100

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).

Other than 100 burden hours listed in question 12, the survey does not impose any burden (costs) to the respondents resulting from the data collection. This voluntary, in-person survey will be conducted at times and places that are convenient to fishermen.

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

The cost for each location is estimated at $8,000 a year, and therefore $24,000 for three areas in total. Some of the costs are to support NMFS supervision, data processing, quality control, data entry, and some is to support local creel survey staff. If we were to start a new economic survey program without adding on the economic data collection to the creel survey, it would cost at least

$10,000 more per year per area because of the new hire of part-time personnel and administrative cost. The add-on economic surveys would be a cost savings of at least $30,000 annually.

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

Burden is slightly increased based on recent respondent numbers.

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

Summary of the collected data will be published on the PIFSC website, in an annual basis. As described in question 2, the collected data are used for economic analyses and two annual reports and one Stock Assessment and Fishery Evaluation (SAFE) report were submitted to the Western Pacific Fishery Council. Additionally, economic impact analysis will be conducted and the results will be published as a PIFSC report and this will be available on PIFSC website.

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.

The expiration date will be displayed on the survey form.

18. Explain each exception to the certification statement.

There are no exceptions to the certification statement.

1 Fresh fish per capita in American Samoa was based on data in 1994 before the large longline fishery was developed.

2 Hospital, J., and C. Beavers. 2012. Economic and Social Characteristics of Guam’s Small Boat Fisheries. Pacific Islands Fish. Sci. Cent., Natl. Mar. Fish. Serv., NOAA, Honolulu, HI 96822-2396. Pacific Islands Fish. Sci. Cent. Admin. Rep. H-12-06, 60 p. + Appendices.

3 Hospital, J., and C. Beavers. 2014. Economic and Social Characteristics of Small Boat Fishing in the Commonwealth of the Northern Marina Islands. Pacific Islands Fish. Sci. Cent., Natl. Mar. Fish. Serv., NOAA, Honolulu, HI 96818-5007. Pacific Islands Fish. Sci. Cent. Admin. Rep. H-14-02, 58 p. + Appendices.

4 Miller, Scott A. 2001. Economic Assessment of the Domestic Fisheries Development Potential of the Commonwealth of the Northern Mariana Islands. Prepared for NMFS, NOAA, Saltonstall-Kennedy Grant Number: NA 96FD0471.

5 Kasaoka, Laurel D. 1989. Summary of Small Boat Economic Surveys from American Samoa, Guam, and the Northern Mariana Islands. Western Pacific Regional Fishery Management Council. Administrative Report H-89-4C.

6 Leontief, Wassily. Input-Output Economics. 2^nd ed. New York: Oxford University Press, 1986.

7 Cai, J., P.S. Leung, M. Pan, and S. Pooley. 2005. Economic Linkage Impacts of Hawaii's Longline Fishing Regulations. Fisheries Research, 74(1-3) 232-242.

8 Cai, J., P.S. Leung, M. Pan, and S. Pooley. 2005. Linkage of Fisheries Sectors to Hawaii's Economy and Economic Impacts of Longline Fishing Regulations. SOEST 05-01, JIMAR Contribution 05-355.