1625-0089 Supporting_Statement_Part_A_NRBSS_20250312

SUPPORTING STATEMENT OUTLINE

NATIONAL RECREATIONAL BOATING SAFETY SURVEY
OMB Control No.: 1625-0089

SUPPORTING STATEMENT – PART A

A. JUSTIFICATION

1. Need for the Information Collection
   
   

The objective of the U.S. Coast Guard’s (USCG) National Recreational Boating Safety (NRBS) program is to ensure that on-water law enforcement and public has a safe, secure, and enjoyable recreational boating experience by implementing programs that minimize loss of life, personal injury, and property damage while supplementing national security efforts. As part of the NRBS program, the National Recreational Boating Survey enables the USCG to better identify safety priorities, coordinate, and focus research efforts, and encourage consistency in the information that is collected as well as the applied analysis methods. In light of the USCG’s security and safety-oriented mission, we are proposing a name change of this survey to the National Recreational Boating Safety Survey (NRBSS).

An NRBSS program requirement as set forth in Title 46, United States Code, § 13102, is to “encourage greater State participation and uniformity in boating safety efforts, and particularly to permit the States to assume the greater share of boating safety education, assistance, and law enforcement activities”. As coordinator of the NRBS program, the USCG provides support for safety initiatives in every jurisdiction (States and Territories) by making available timely, relevant information on boating activities that occur in each respective jurisdiction. Working in partnership with State Boating Law Administrators (BLAs), the boating information provided by the USCG enables each State law enforcement agency to tailor and implement safety and security initiatives that address the needs of boaters in each respective jurisdiction.

The U.S. Coast Guard has partnered with the National Opinion Research Center (NORC) at the University of Chicago, a nonprofit organization, through a cooperative agreement to administer the next National Recreational Boating Safety Survey (NRBSS). A cooperative agreement is distinguished from a grant through substantial involvement. NORC’s substantial involvement includes helping the Coast Guard develop survey questionnaires, a sampling plan, conducting data collection and quality control, writing final reports and preparing final datasets.

This survey aims to estimate the total population of boaters in the United States and by state and collects attitudinal data on public safety interventions such as safety equipment and boating safety courses. The survey also estimates the total boat population of paddlecraft (canoes, kayaks, standup paddleboards) most of which are not required to be registered with a state authority like a Department of Motor Vehicles, a national security gap in knowledge. Since the 2018 NRBSS was conducted, canoe and kayak fatalities have risen from 21% to 26% of total fatal incidents, accounting for nearly 150 deaths in 2023 (USCG, 2023). The 2018 NRBSS was conducted with a Paperwork Reduction Act Exemption granted by the Department of Homeland Security Office of Chief Counsel.

Addressing OIRA Terms of Clearance:

In its next submission to revise or extend this collection request, DHS shall provide evidence to OIRA on its efforts to share the results of the survey with states and examples of how states use the data. DHS shall also include response rates from the last collection of the surveys as well as the results of the nonresponse bias analysis.

The USCG has provided efforts to share the results of the survey with states in Section 8, Consultation and Public Comments. The USCG has listed examples of how states use survey data in Section 2, Use of the Information. The response rates from the 2018 Exposure Survey was 21.9% while the Participation Survey was 14.9% (Duffy, et al, 2018). Nonresponse bias analysis results are included in Section 6.3 of the 2018 NRBSS Methodology Report. These are included as Appendix 3.

2. Use of the Information

The information derived from this collection directly supports the 2022 – 2026 Strategic Plan of the National Recreational Boating Safety Program by providing actionable data on the number of boaters the Program directly affects. The plan seeks to influence boater behavior, recreational boat and accessory manufacturers by leveraging data to affect change. Currently, the Program is charged with collection of boating accident statistics under 33 CFR 173 from 56 states and territories. Survey results act as the denominator so the program can calculate relative risk by state and to the nation. It allows the Coast Guard to target its outreach and interventions in higher risk areas where fatality and injury boat accidents occur.

Data derived from the survey directly contributes to the Federal-State partnership in regulation of boating safety. The survey provides more than 30 metrics that a state can utilize in their management of recreational boating safety. In a poll taken by the National Association of State Boating Law Administrators, it is estimated that nearly 60% of their membership stakeholders polled utilized survey findings (NASBLA, 2023). Respondents stated various reasons for utilizing the NRBSS including facilitating discussions with state legislatures, determining courses and seminars to teach to the boating public within their respective states, for various grant proposals, and to normalize state-collected accident data.

Survey information has most recently been utilized in a Government Accountability Office (GAO) Audit entitled Recreational Boating: How Vessel Users Contribute to and Benefit from a Federal Trust Fund (GAO-23-105729) which heavily utilized estimates from the 2018 National Recreational Boating Safety Survey to derive insight into the boat population that is not registered with a state, territory or commonwealth nation’s requisite registration authority. GAO cited that the number of nonmotorized vessels used in the U.S. has grown in recent years through its analysis (GAO, 2022).

Washington State utilized the 2018 NRBSS results for a deep dive into looking at non-motorized boating fatalities. The Evans Policy Innovation Collaborative through the University of Washington convened stakeholder sessions with state officials, programs and industry experts to understand the policy landscape around non-motorized boating fatalities in Washington State. Researchers utilized the NRBSS to normalize their data (EPIC, 2022).

3. Use of Information Technology
   
   

The NRBSS includes two complementary questionnaires to collect information at the boat level, boat trip level, and recreational boating participant level. These questionnaires include a telephone and web survey for the Participation Survey and telephone, web, and paper versions of the Exposure Survey.

NRBSS will use advanced technology to reduce respondent burden and make data processing and reporting more timely and efficient. All participants will be given the choice of completing each survey online with a personal device or by telephone with a trained telephone interviewer. NORC’s survey software system supports both Computer Assisted Telephone Interviewing (CATI) and Computer Assisted Web Interviewing (CAWI), providing an integrated sample management and data collection platform. The survey software system provides the opportunity to participate in a web-mode using smartphones; for these respondents, the web-based system renders an optimized presentation of the questions. This smartphone-optimized web survey also allows for easy survey completion when sending the survey link to respondents via text message. The respondent can simply tap the survey link in the text message leading them directly to the mobile-optimized web survey reducing respondent burden. For all participants completing the survey online or over the phone, the survey technology includes tailored skip patterns and text fills, which allows respondents to move through the questions more easily and minimizes respondent burden. Lastly, for the Participation Survey, by using the pre-selected AmeriSpeak panelists for a longitudinal study, costs and respondent burden associated with locating and contacting respondents are kept to a minimum.

The USCG and NORC have also conducted usability testing to determine if the survey questionnaire associated with this collection used plain language. Eight participants that participated in recreational boating were recruited to participate in a usability test utilizing a “think aloud” method. NORC found that respondents understood the Instructions and Survey and provided feedback on wording of questions. NORC and USCG have made changes to the survey questionnaire based off these interviews.

4. Non-duplication
   
   

The USCG did an extensive search of available information on boats, boaters, and boating activities to determine if the critical need for recent boating information could be met. No comprehensive national boating data source was identified. Since our most recent information collection (which took place in 2018), no information collections have been conducted from which the USCG could obtain reliable up-to-date estimates on the number of recreational boats, boating households, boaters, or activities at the national and state levels. Sensor data such as Automatic Identification System (AIS) are not reliable for recreational boats as there is no carriage requirement for AIS systems by a recreational boater. These data would not represent the population that is being targeted in this information collection.

5. Burden on Small Business

The NRBSS is a voluntary, social survey primarily designed to collect data from individual recreational boating participants. Because the study focuses on the residential population, the data collection effort will not place an undue response burden on small businesses or similar entities.

6. Less Frequent Collection

The last collection of data was conducted in 2018. Since 2018, there have been major banner events that have shaped recreational boating safety. During the global COVID-19 pandemic, the United States saw its highest recreational boating fatality and injury number in at least a decade due to increased boater and recreational participation in 2020. This also resulted in unprecedented sales for recreational boats. Access to purchase a recreational boat has been simplified by retail stores leading to a raise in paddlesports (canoes and kayaks) fatalities. If the Coast Guard were to collect these data less frequently, then we will not be responsive to changes in the boating industry and data would not be able to capture these banner events.

The National Boating Safety Advisory Committee,is a Federal Advisory Committee made up of state officials, recreational vessel and associated equipment manufacturers, and members of the general public or national recreational boating organizations. This Committee has recommended to the Coast Guard that this Survey should be carried out a minimum of every five years and recognizes the importance of work to ensure the establishment of reliable estimates of exposure hours, the estimated population of non-registered boats in the United States, to gather critical information related to the goals and measures within the 2022 – 2026 Strategic Plan of the National Recreational Boating Safety Program.

7. Paperwork Reduction Act Guidelines

The information collection activities discussed in this ICR comply with all Paperwork Reduction Act regulatory guidelines. No special circumstances are anticipated in this collection of information.

8. Consultation and Public Comments

Since 2018, the Coast Guard has worked extensively with its stakeholder groups to update survey instruments and information collection. The Coast Guard regularly consults with the National Association of State Boating Law Administrators (NASBLA) via its Engineering, Research and Analysis Committee on survey methodology and data. We have worked with NASBLA to provide multiple stakeholder informational webinars throughout 2022 with nearly 50 participants as well as stakeholder engagement sessions to work on the next NRBSS in 2023. Recordings of these webinars can be accessed at https://www.nasbla.org/nasblamain/lighthouse/get-equipped/boating-survey.
The Coast Guard also works with the National Boating Safety Advisory Committee (NBSAC) and its Prevention Through People Subcommittee as well as membership at large to collaborate over the NRBSS. NBSAC members have been afforded numerous opportunities to propose survey questions, provide feedback and give direct comments to the Coast Guard. Coast Guard representatives have presented at numerous on-the-record NBSAC Committee meetings on the NRBSS including results from the last survey and efforts for a future survey.

Six comments were received during the 60-Day comment period, and all comments were in support of the NRBSS. The American Canoe Association, the National Association of State Boating Law Administrators (NASBLA), the Marine Retailers Association of the Americas, the American Boat and Yacht Council, and National Safe Boating Council all expressed the importance of NRBSS data in their own work to improve boating safety policies and programs.

              NASBLA encouraged including technological improvements in the methodology. The proposed 2026 methodology incorporates technological advancements not used in the 2018 methodology, including the use of text messaging as part of the Exposure and Participation survey methodologies. Text messages can help improve response rates with minimal respondent burden. Allowing respondents to click on a survey link in the text and providing a mobile-optimized web survey that respondents can complete on their phone will help reduce respondent burden.

9. Gifts or Payment

Nonresponse impacts data quality and the effectiveness of sample sizes, so all options to reduce bias should be incorporated into research designs, including the use of incentives. Incentives can be prepaid (these are the most effective in terms of per-dollar impact on response (Dillman et al., 2014)) or postpaid. Research and best practices are conclusive in that incentives significantly increase response rates, which in turn can help reduce the number of people invited to the survey, increase data quality and limit concerns for bias (Dillman et al., 2014; Stanley et al., 2020).

Exposure Survey Incentives

Sampled boat owners and ABS addresses will receive a $1 pre-incentive in the first letter inviting them to participate in the survey. They will also receive a $10 electronic gift card as a thank you for completing the survey. Incentives were paid similarly in both the 2018 NRBSS and 2022 FHWAR.

Participation Survey Incentives

AmeriSpeak panelists will be offered the AmeriPoints (the metric in which panelists are paid incentives) equivalent of $5 as an incentive for completing up to three Participation Survey requests. Panelists receive incentives for all surveys they complete, and the incentive for this study will be slightly larger than a normal AmeriSpeak survey to further encourage cooperation and limit the number of respondents invited to do the survey.

10. Confidentiality

When an assurance of confidentiality is provided, the respondent is being asked to submit proprietary, trade secret, or confidential information to the agency. In turn the agency is assuring the respondent that it has instituted procedures to protect the confidentiality of the information to the extent permitted by law. Some laws governing confidentiality carry large penalties for the agency if the information is not protected properly. In addition, collections including an assurance of confidentiality must be supported by an authority established in statute or regulation.

Individuals contacted will be assured of the confidentiality of their responses under 5 U.S.C. 552a (Privacy Act of 1974) applied to the National Recreational Boating Survey. This survey is covered by an existing SORN: DHS/ALL-002-Department of Homeland Security (DHS) Mailing and Other Lists System November 25, 2008, 73 FR 71659 as well as a Privacy Threshold Analysis.

Survey invitations will display OMB approval numbers, statements assuring confidentiality, and contact information so that a knowledgeable member of the project team can answer a respondent’s questions. The questionnaire will also include consent language explaining that the survey is voluntary, they can skip questions, the results will be deidentified, and the length of the survey. A completed questionnaire will imply consent.

Precautions also are taken in how the data are handled to prevent a breach of confidentiality. Survey data and all identifying information about respondents will be handled in ways that prevent unauthorized access at any point during the study. Data will be housed on a secure server. Access to mail information will be limited and on a need-to-know basis. If reports or tabular data are submitted, the data will be reviewed to determine if the subject(s) can be identified when small cell counts occur. If there is the potential for the identification of these subject(s), the data in these cells will be removed. We will adhere to the rules and standards including, but not limited to, the following regulations and policies:

• Federal Information Processing Standard (FIPS) Publication (PUB) 199, Standards for Security Categorization of Federal Information and Information Systems

• FIPS Pub 200, Minimum Security Requirements for Federal Information and Information Systems

• NIST SP 800-53 Revision 5, Recommended Security Controls for Federal Information Systems
  
  

11. Sensitive Questions

No sensitive information will be collected.

12. Respondent Burden, and its Labor Costs

1. Estimation of Respondent Burden

Estimates of Total Burden Hours to Respondents

The NRBSS is a study of boating activity and participation. State-supplied boat registration data will be used as one of the sampling frames for selecting boating households. However, the content of State boat registration databases is limited to recreational vessels that owners are required by law to register, which are typically power boats or boats of a certain size. It is also anticipated that state confidentiality laws will prevent some states from providing their registration data to the USCG for the NRBSS. Consequently, NORC will use an ABS sample and nonprobability online panel to provide coverage of the portion of the boating population not included in the State’s boat registration databases. In states that provide boat registration data, only households that do not own any registered or documented recreational vessel will be eligible for inclusion in the ABS sample. To do this, ABS sampled addresses also on a registration list will be removed from the ABS sample. In states for which boat registration data are not available, all boating households will be eligible for selection in the sample. The Participation Survey will survey AmeriSpeak panelists.

Adding AmeriSpeak and nonprobability panels to the 2026 NRBSS approach has the added benefit of collecting data from panelists who have already volunteered to do surveys and are accustomed to taking surveys. By gathering data from the panels, fewer list and ABS respondents need be contacted reducing respondent burden overall.

Table 1 illustrates the burden hours by sample source for the 2026 NRBSS. These hours were calculated by applying response and eligibility rates to the respective sample sizes to determine the expected number of completes per sample source or survey. The total number of completes were then multiplied by the 1-minute duration time for those who were deemed not eligible for the Exposure Survey after completing a few screening questions (Completed Screeners minus Completed Surveys), 14-minutes for those who completed the Exposure Survey (Completed Surveys) and 30 minutes over the course of the three waves for the Participation Survey (Completed Surveys). Overall, survey participants will spend about 15,151 hours filling out the different questionnaires for the 2026 NRBSS.

Table 1: Burden Hours by Sample Source

	Exposure Survey			Participation Survey	TOTAL
	Registration Lists	ABS Sample	Nonprobability Panels	AmeriSpeak Panel
Initial Contacts	128,066	154,276	NA	10,667	293,009
Response Rate	27%	13%	NA	75%
Completed Screeners	34,578	19,285	64,000	8,000	125,863
Eligibility Rate	87%	24%	12%	100%
Completed Surveys	30,000	4,600	7,800	8,000	50,400
Survey Duration (min)	Screeners Only: 1; Completed Survey:14. Total: 15			30
Annual Burden (hrs)	7,076	1,318	2,757	4,000	15,151

2. Labor Cost of Respondent Burden

Using the 2024 U.S. minimum wage rate of $12 an hour, the time needed to complete the survey is expected to cost $181,812 across all respondents.

13. Respondent Costs Other Than Burden Hour Costs

There are no costs to respondents for participating in this survey other than their time.

14. Cost to the Federal Government

Under Section 13106(c) of 46 U.S.C., funding is made available for payment of expenses of the USCG for activities directly related to coordinating and carrying out national recreational boating safety programs. In September 2023, Cooperative Agreement 70Z02323MO0001688 was awarded to NORC, enabling them to conduct the 2026 surveys. The estimated cost for the five-year contract as set forth in the solicitation was $7,500,00, resulting in an average annual cost of $1,500,000.

15. Reasons for Change in Burden

The total approved responses in December 2015 was 169,020. The total requested responses for this information collection are 125,863. The last information collection accounted for a mixed-mode collection comprising of mainly mail and telephone completes. This information collection accounts for changes in technology to a fully web enabled survey with some respondents opting for a phone or mail complete option.

16. Publication of Results

Tabulation Plans

NORC will use advanced statistical software such as SAS or R to generate frequencies of responses and cross-tabulations on key variables using weighted data. Fundamental measures for observation include:

• Numbers and characteristics of boating participants (i.e., boat owners and non-owners);

• Exposure rates (i.e., boating trips, “boat hours”) and behaviors;

• Numbers and types of boats (i.e., registered, documented, unregistered); and

• Number of boats with various types of safety equipment

Time Schedule for the Project

The Exposure Survey will proceed monthly during the survey year starting in February 2026 asking about boat trips in January 2026 and ending in January 2027 asking about boat trips in December 2026. The Participation Survey will include three waves of data collection in 2026 taking place in May 2026, September 2026, and January 2027.

NORC will deliver national, regional, and statewide estimates of recreational boats, boating households, boaters, boating exposures, boating practices, and boating activities in September 2027. The USCG will disseminate these findings in January 2028.

17. Non-Display of OMB Expiration Date

We are not seeking such approval. The OMB number will appear in appropriate Paperwork Reduction Act disclosure information.

18. Exceptions to "Certification for Paperwork Reduction Submissions"

There are no exceptions to the certification statement.

Works Cited

Dillman, D. A., Smyth, J. D., & Christian, L. M. (2014). Internet, phone, mail, and mixed-mode surveys: The tailored design method. John Wiley & Sons. 

Duffy, et al. (2020) National Recreational Boating Safety Survey Final Methodology Report. RTI International. March 2020.

Evans Policy Innovation Collaborative. Non-Motorized Boating Fatalities in Washington – December 2022. Accessed at uwnetid.sharepoint.com/sites/evans-public/Shared Documents/Forms/AllItems.aspx?id=%2Fsites%2Fevans-public%2FShared Documents%2FEPIC%2FBoating%2FNon-MotorizedBoatingWA_FinalReport%2Epdf&parent=%2Fsites%2Fevans-public%2FShared Documents%2FEPIC%2FBoating&p=true&ga=1

Government Accountability Office (2022). Recreational Boating: How Vessel Users Contribute to and Benefit from a Federal Trust Fund. Report to Congressional Committees. Accessed at https://www.gao.gov/assets/gao-23-105729.pdf

National Association of State Boating Law Administrators (2023). NRBSS Stakeholder Engagement Session. Accessed at https://higherlogicdownload.s3.amazonaws.com/NASBLA/76594a34-f3a1-4916-95ac-1e9c872170cc/UploadedImages/advocacy/committees/ERAC/NRBSS_Stakeholder_Meeting_12122023_w_speaker_notes_poll_and_open_question_results.pdf

Stanley, M., Roycroft, J., Amaya, A., Dever, J. A., & Srivastav, A. (2020). The Effectiveness of Incentives on Completion Rates, Data Quality, and Nonresponse Bias in a Probability-based Internet Panel Survey. Field Methods, 32(2), 159-179.  

United States Coast Guard (2023). 2023 Recreational Boating Statistics, COMDTPUB P16754.37. Accessed at https://uscgboating.org/library/accident-statistics/Recreational-Boating-Statistics-2023-Ch1.pdf

Appendix 1: Title 46, Subtitle II, Part I, Chapter 131, §13102: State recreational boating safety programs 

(a) To encourage greater State participation and uniformity in boating safety efforts, and particularly to permit the States to assume the greater share of boating safety education, assistance, and enforcement activities, the Secretary shall carry out a national recreational boating safety program. Under this program, the Secretary shall make contracts with, and allocate and distribute amounts to, eligible States to assist them in developing, carrying out, and financing State recreational boating safety programs  

(b) The Secretary shall establish guidelines and standards for the program. In doing so, the Secretary—  

(1) shall consider, among other things, factors affecting recreational boating safety by contributing to overcrowding and congestion of waterways, such as the increasing number of recreational vessels operating on those waterways and their geographic distribution, the availability and geographic distribution of recreational boating facilities in and among applying States, and State marine casualty and fatality statistics for recreational vessels;  

(2) shall consult with the Secretary of the Interior to minimize duplication with the purposes and expenditures of the Land and Water Conservation Fund Act of 1965 (16 U.S.C. 460l–4—460l–11) the Federal Aid in Sport Fish Restoration Act of 1950 (16 U.S.C. 777–777k), and with the guidelines developed under those Acts; and  

(3) shall maintain environmental standards consistent with the Coastal Zone Management Act of 1972 (16 U.S.C. 1451–1464) and other laws and policies of the United States intended to safeguard the ecological and esthetic quality of the waters and wetlands of the United States.  

(c) A State whose recreational boating safety program has been approved by the Secretary is eligible for allocation and distribution of amounts under this chapter to assist that State in developing, carrying out, and financing its program. Matching amounts shall be allocated and distributed among eligible States by the Secretary as provided by section 13104 of this title.  

46 USC §13107. Authorization of appropriations

(c)(B) Of the amounts used by the Secretary each fiscal year under subparagraph (A)—

(ii) not more than $1,500,000 is available to conduct by grant or contract a survey of levels of recreational boating participation and related matters in the United States.

Appendix 2: 2018 National Recreational Boating Safety Survey Non-Response Bias Analysis