FR 2021-01472

The document under review is a request for public comments by the National Oceanic and Atmospheric Administration (NOAA) on proposed revisions to an ongoing information collection about the socio-economic conditions of hired captains and crew in commercial fisheries. The survey currently targets New England and Mid-Atlantic regions and is proposed to be expanded to include the South Atlantic and Gulf of Mexico. The data collected aims to provide insight into demographic characteristics, wage structures, job satisfaction, and opinions on fishery management.

General Summary

This notice serves to solicit input from the public and other federal agencies over a 60-day period before the proposal is submitted for review to the Office of Management and Budget (OMB). The survey is designed to gather data to ensure that the socio-economic impacts of fishery management policies are well understood.

Significant Issues

A key concern is the lack of clarity regarding how the data collected will be evaluated to ensure it meets its stated objectives. Without a clear plan, there is potential for inefficient use of resources, raising the issue of wasteful spending. Furthermore, the document lacks specific information on how the survey will be adapted to accommodate regional differences in fisheries, which is crucial for tailoring the survey to accurately capture diverse circumstances.

The document states there are "no estimated total annual costs to the public," yet it provides no details on how this determination was made. This absence of transparency could suggest unknown future costs might surface, catching stakeholders off guard. Additionally, the 15-minute response time and 236.5 annual hours of respondent burden are outlined without sufficient explanation. It is unclear how these figures were determined and what they imply about the effort required from respondents.

Data security is another area of concern. While comments note that personal information may become part of the public record, the document does not specify measures for securing personal data, leaving respondents potentially vulnerable to data breaches.

Impact on the Public

The survey is essentially an effort to enhance understanding of the social and economic conditions within fisheries, which could lead to more informed policy-making. However, the broader public might question the efficacy and purpose of the information collection without a clear strategy for its utilization and demonstration of benefits.

Impact on Stakeholders

For commercial fisheries, which include hired captains and crew, the outcome of this survey could have significant implications. By expanding geographic coverage, more fishers might be able to express their socio-economic realities, potentially influencing future regulatory decisions. This can lead to policies better tailored to regional needs and challenges. Conversely, insufficient adaptations to regional differences might result in misrepresentative data, potentially skewing policy impacts.

In summary, while the NOAA's effort to gather comprehensive socio-economic data is commendable, clarity and transparency in methodology, data security, and strategic objectives are vital to ensure that this information collection effectively serves its purpose for all stakeholders involved.

In the document regarding the Agency Information Collection Activities, the "Estimated Total Annual Cost to Public" is stated to be $0. This implies that the data collection exercise outlined poses no direct financial burden on the members of the public who are involved in the survey process. However, the document does not provide detailed information on how these financial conclusions were reached or what factors were considered in arriving at the zero-cost estimation.

The absence of cost to the public could be due to the voluntary nature of participation in the survey, which might mean that no payments or reimbursements are required from those who participate. Moreover, the document lacks a breakdown of potential expenses or the exact allocation of resources that support the continuation of this survey initiative without transferring costs to the public, which is a notable omission given the comprehensive scale of the study.

In considering the identified issues, one should note the potential implications if future costs arise that were not initially considered. While the document claims no cost to the public, it also fails to elaborate on the specifics of how the implementation and expansion of the survey across various regions are funded. This gap in information raises concerns about transparency and accountability, particularly if unexpected expenses were to emerge down the line.

Additionally, the inclusion of an estimated response time of 15 minutes with a cumulative annual burden of 236.5 hours suggests a modest time commitment from participants. But, without a developed understanding of how this translates financially to the administering agency—such as labor costs or technology deployment—it remains unclear exactly how budgeting aligns with these operational estimates. The document would benefit from a thorough explanation regarding the management of resources, especially in terms of ensuring the efficient use of funding.

Moreover, the lack of detailed data security measures, while not directly a financial consideration, could potentially incur costs should data privacy issues emerge. Proactively addressing these concerns could prevent future liabilities and associated expenses.

Ultimately, without a transparent breakdown of the factors informing the "no cost" assertion and how any arising costs are absorbed administratively, the document's financial references remain somewhat superficial and potentially misleading. Continued clarity around these matters would greatly enhance the robustness of the agency's financial accountability.