Supporting Statement for:

Willingness To Pay Survey for Salmon Recovery in the Willamette Watershed

1. Identification of the Information Collection.

	1(a) Title of the Information Collection

Willingness To Pay Survey for Salmon Recovery in the Willamette Watershed (New), EPA #2489.01, OMB #2080-NEW

	1(b) Short Characterization/Abstract

The USEPA Office of Research and Development is investigating public values for options of salmon recovery in the Willamette Watershed in western Oregon. These values will be estimated via a willingness to pay mail survey instrument. Two anadromous fish species in the Willamette watershed are federally listed as threatened species; Spring Chinook, and Winter steelhead. The survey focuses on two attributes of recovery for these fish: the recovery status; and the time to recovery. The levels of recovery vary between "Threatened", "Minimal Recovery", and "Broad Recovery". The levels of time to recovery vary between 15 years, 25 years, and 50 years. The levels of recovery are based on two recovery possibilities described in the recovery plan (Oregon Dept of Fish and Wildlife and National Marine Fisheries Service, 2013). The time to recovery is based on investigating periods inclusive of but also potentially shorter or longer periods than the 25 year planning horizon mentioned in the recovery plan (Oregon Dept of Fish and Wildlife and National Marine and Fisheries Service, 2013). A choice experiment framework is used with statistically designed tradeoff questions, where recovery options are posed as increases in a yearly household tax. Each choice question allows a zero cost "opt out" option. The choice experiment is designed to allow independent isolation of the value of recovery and of time to recovery. A few additional questions to further understand the motivations for respondent choices, their river-related recreation behavior, and their attitudes towards wild origin versus hatchery origin fish are also included. Several pages of background introduce the issue to survey respondents. Limited sociodemographic questions are included to gauge how well the sample respondents represent the target population. The survey would be dispersed to Oregon residents.

2. Need for and use of the Collection

	2(a) Need/Authority for the Collection
Current ORD research revolves around the theme of sustainability (USEPA, 2013a). An overarching goal cited on the EPA website for sustainability research is:
	"EPA Sustainable communities research is providing decision tools and data for 	communities to make strategic decisions for a prosperous and environmentally 	sustainable future, and providing the foundation to better understand the balance between 	the three pillars of sustainability- environment, society and economy" (USEPA, 2013b).
As part of including public input for finding the "balance" of sustainability, this survey will estimate public values for salmon recovery in the Willamette watershed. Salmon recovery is a factor for numerous watershed management actions. Salmon is also a key driver for water temperature being listed as a Total Mean Discharge Level contaminant for the Willamette River.  The Willamette watershed is a subject of continuing research by ORD and other partners (USEPA, 2012a, 2012b;  Willamette Water 2100, 2013). The survey will gather public value information on salmon recovery scenarios to complement partnering natural science research. Benefits to Oregonians associated with salmon recovery have not been quantified.

	2(b) Practical Utility/Users of the Data

A continuing problem for communities dealing with natural resource management problems has been the issue of how to integrate natural resource valuation - both use and non-use values - into a feasible decision making process.  The primary goal of conducting economic valuation studies should be to improve the way in which communities frame choices regarding the allocation of scarce resources and to clarify the trade-offs between alternative outcomes. This problem is particularly relevant to salmon conservation efforts in the Pacific Northwest.  Despite the deep cultural importance of salmon to the citizens of the Pacific Northwest, there is a remarkable lack of valid empirical economic studies quantifying this importance to the general public and tribal groups in the region.  This is conspicuously true for the Willamette Basin, home to more than half of the state of Oregon's human population and to the few remaining spring-run Chinook salmon runs in the state. There are many competing uses for Oregon's waters and decision-makers are often faced with trade-offs on how to allocate resources to accommodate these uses. Many of these uses conflict with salmon conservation and to date there is not adequate information to quantify societal values for salmon preservation. The goal of this project will be to obtain estimates of the general Oregon population's preferences and values to protect and restore wild origin Chinook salmon and steelhead populations in the Willamette Basin.  Valid estimates of the public value for salmon will be useful in numerous policy contexts and will support numerous government agencies and community organizations to factor the value of salmon preservation benefits into their strategic policy and financial decisions.
3. Non duplication, Consultations, and Other Collection Criteria

	3(a) Non duplication

While there is much research and management in the Willamette watershed pertaining to salmon fisheries, there is very little public value research. This research would isolate specific aspects of the fishery, and allow the public to tally preferences for specific marginal fishery changes. Thus, quantification of the benefits of salmon recovery could be compared with costs of achieving recovery. Furthermore, discussions on Willamette salmon tend to focus on commercial or recreational angling, at the exclusion of general public opinion. This survey will allow investigating general public values for changes in this public resource. Qualitative research from focus groups pretesting the survey instrument indicates the possibility of significant public value for fishery recovery, regardless of respondent fishing behavior.

There has been one prior general public stated preference survey featuring threatened Willamette watershed salmon. Wallmo and Lew (2012) conducted a choice experiment survey to investigate public values for recovery of a variety of marine organisms, including Willamette Spring Chinook, with a nationwide sample. This study differs from that prior study in the following respects. This study derives further information and recovery levels from the recent recovery plan, and furthermore considers two levels of recovery. Furthermore, preferences for time to recovery will be investigated. Finally, this study will seek to compare recovery values across different components of Oregon's population. Oregon subpopulations both within and outside of the watershed, and both urban and rural will be sampled (see Supporting Statement Part B for more information). The nationwide sample from Lew and Wallmo is not extensive enough to allow isolating preferences of Oregonians, nor subpopulations of Oregonians (personal communication, Lew and Wallmo, 2012).

EPA has not identified any other studies that would consider Oregonians' public values for the different levels of recovery and time to recovery posed for Willamette watershed Spring Chinook and steelhead. The options were carefully pretested to balance background information with cognitive effort. The language, graphics, and question formats in the survey were carefully pretested and iteratively refined through seven focus groups. These focus groups were all in Oregon, occurring both within and outside of the Willamette watershed, and with both urban and rural participants.

	3(b) Public Notice Required Prior to ICR submission to OMB

This is the first of two federal register notices.

	3(c) Consultations

The principal investigators for this effort are Matthew Weber, and Michael Papenfus, both affiliated with USEPA, ORD, Western Ecology Division, Corvallis, Oregon. M. Weber has past direct experience with willingness to pay survey research, with a study estimating public values for management changes for the river and riparian area of the Rio Grande in Albuquerque, New Mexico (Weber and Stewart, 2009). Previously approved OMB surveys were consulted in designing this survey, in particular an EPA study on fish and aquatic habitat impacts from cooling water intake structures (OMB # 2020-0283). The survey instrument booklet format and several questions formats were adapted from that study. M. Weber participated in a workshop amongst stated preference survey practitioners working on federal government projects, convened by NOAA and Stratus Consulting in June of 2012 (NOAA and Stratus Consulting, 2012). That workshop was a helpful forum for comparing notes in willingness to pay survey design, with an emphasis on strategies for presenting ecological goods in a way meaningful to the lay public. Several completed or working draft willingness to pay survey instruments were presented for group discussion, including a NOAA study on Elwha River restoration, with an attribute that includes salmon abundance changes (OMB NO. 0648-0638).

This survey uses an explicit approach to defining ecological commodities to be valued, following guidance in Boyd and Banzhaf (2007). Dr. Paul L. Ringold, research ecologist at USEPA, ORD was consulted for his experience identifying publicly valued stream commodities and metrics (Ringold et al., 2009; Ringold et al., 2013).

For descriptions of salmon abundance changes and management actions that could contribute to recovery, this survey relies on the recovery plan (Oregon Dept of Fish and Wildlife and National Marine and Fisheries Service, 2011).

Additional consultations with experts within ODFW, NOAA, EPA Region 10, and several external experts in stated preference survey design were used to assist in the design of the survey.

	3(d) Effects of Less Frequent Collection

Without this collection the public values for Oregonians for different options for Willamette watershed salmon recovery could not be estimated. There would then be a gap in understanding the public welfare relevance of recovering these fisheries. The public welfare relevance of natural science studies pertaining to these fisheries would also remain uncertain.

	3(e) General Guidelines

The survey will not violate any of the general guidelines described in 5 CFR 1320.5 or in
EPA's ICR handbook.

	3(f) Confidentiality

All responses to the survey will be kept confidential. The surveys will be processed, including data entry, by the principal investigators; nobody else will have a record of who has responded or the answers of any given respondent. A list of the addresses of the members of the sample who have responded versus those who have not will be maintained in order to more efficiently mail reminders and replacement surveys. This will be a single file, accessible to and updated only by the principal investigator. To protect confidentiality in survey results, each respondent will be identified by a numeric code in that file rather than their name or address. The survey questions do not ask for any personally identifiable information and personally identifiable information will not be entered in the results even if volunteered by the respondent, for example in the comments section. In the cover letter, respondents will be informed that their responses will be kept confidential. After the data collection is complete, the respondent status file will be deleted, and only the numeric code assigned to each respondent will remain. After data entry is complete, the surveys themselves will be destroyed.

The USEPA office location (the Western Ecology Division of USEPA) and USEPA electronic file system used by the principal investigator are highly secure. A keycard possessed only by USEPA employees and contractors is necessary to enter the building. The principal investigators are then in a separate keyed office space within the secure building. The computer system where the personal names and addresses associated with respondent numeric codes will be stored during the process of data entry is a secure server requiring principal investigator personal login username and password. At the conclusion of data entry, this file linking personal names and addresses to respondent codes will destroyed (along with hard copy survey responses themselves) at the conclusion of data entry and only respondent codes will remain.

	3(g) Sensitive Questions

There are no questions of a sensitive or personal nature in the survey.

4. The Respondents and the Information Requested

	4(a) Respondents/SIC Codes

The target respondents for this survey are representatives 18 yrs or older of Oregon households. A sample of household representatives 18 yrs or older, sufficient to address goals of the study will be contacted by mail following multiple contact protocol in Dillman (2009). A response rate of 30% will be targeted for each subpopulation of Oregon to be studied. To increase response rates from the sample, several contacts will be used, including a prenotice to all recipients, a reminder postcard, and follow-up mailing.

	4(b) Information Requested

		(i) Data items, including record keeping requirements

The current draft survey has also been uploaded to the federal register (note that the pages numbers are out of sequence on the electronic file so that they will print correctly double-sided). The survey is divided into 4 main parts. The first part is background for the choice questions. The second part is the choice questions themselves. The third part is questions designed to understand the context for why respondents responded to the choice questions as they did. These questions include attitudinal questions as well as recreational preferences questions. The fourth part is designed to assess whether major sociodemographic categories of the received sample are representative of the population sampled. There are no record keeping requirements asked of respondents.

		(ii) Respondent Activities

The following respondent activities are envisioned. Participants will read the cover letter and survey, respond to the survey questions, and return the survey using a provided postage paid envelope. Focus group and cognitive interview participants typically took no longer than 30 minutes to complete the survey, so 30 minutes per response is the estimated burden for the average respondent.

5. The Information Collected - Agency Activities, Collection Methodology, and Information Management

	5(a) Agency Activities

Development of the survey questionnaire through focus group and cognitive interview pretesting is occurring under the separate ICR# 2090-0028. Pretest techniques follow standard approaches in the qualitative methods literature (Morgan and Krueger, 1998; Rubin and Rubin, 2005), as well as guidance in the economics literature for the specific purposes of pretesting a willingness to pay survey (Johnston et al., 1995; Kaplowitz et al. 2001, Hoehn et al. 2003).

Under this ICR, agency activities will include:
      * Develop the choice experiment design
      * Obtain a representative sample mailing list for Oregon households sufficient for the goals of the study (see Supporting Statement Part B)
      * Printing of questionnaires
      * Mailing of prenotices
      * Mailing of cover letters and questionnaires
      * Reminder mailings
      * Follow-up mailings and replacement questionnaires to non-respondents as needed
      * Data entry and quality assurance of data file
      * Analysis of survey results, including characterization of nonresponse and potential degree of nonresponse bias
      * Modeling choice experiment results with a standard multinomial logit approach
      * Reporting survey results

	5(b) Collection Methodology and Management

The proposed survey is a choice experiment questionnaire delivered and returned by mail. Standard multi-contact mail survey methods will be used to increasing response rate (Dillman, 2009, pg. 242). The target response rate of 30% for each subpopulation of Oregon to be studied.

Data quality will be monitored by checking returned survey responses for consistency, and by assessing any comments made on the survey or returned with the survey that signal strategic responses or respondent confusion. Coded survey data will not include any identifying information of the respondents. Returned survey data will be coded and used as the dataset for multinomial logit regression modeling.

	5(c) Small Entity Flexibility

This survey will be administered to individuals, not businesses. Thus, no small entities
will be affected by this information collection.

	5(d) Collection Schedule

A breakdown of the expected collection schedule is as follows:

   * Week 1: Printing surveys
   * Week 2: First contact mailing for pilot survey, notifying that a survey will be mailed in 1-2 weeks
   * Week 3 and 4: Pilot survey mailing
   * Week 5 and 6: Pilot survey reminder postcards mailing
   * Week 7 through 9: Data entry of pilot survey results. Revising estimation of the beta vector (coefficients on utility variables, see part B of the supporting statement). Adjusting the choice experiment and cost levels for the main survey mailing based on the beta vector estimated from the pilot survey
   * Week 10: First contact mailing for main survey mailing, notifying that a survey will be mailed in 1-2 weeks
   * Week 11 and 12: Main survey mailing
   * Week 13 and 14: Main survey reminder postcards mailing
   * Week 15 through 18: Main survey additional reminders and replacement surveys as necessary to reach target response rate
   * Week 19 to 20: Data entry

The schedule above is staged such that if response rates are higher or lower than expected, the appropriate number of replacement surveys will be printed and mailed to most efficiently use funds.

6. Estimating The Burden and Cost of the Collection

	6(a) Estimating Respondent Burden

For a typical respondent, a conservative estimate of their time to review and respond to survey questions is 30 minutes. The target will be 250 responses from each of the three subpopulations of Oregon to be studied: the urban population within the Willamette valley; the rural population within the Willamette valley; and the population residing outside of the Willamette valley .  Assuming the target of 750 people total respond to the survey, the burden is 375 hours. This would be a one-time expenditure of their time.

	6(b) Estimating Respondent Costs
		(i) Estimating Labor Costs

The Bureau of Labor Statistics reports an average hourly wage for Oregon for all occupations. The most recent data is an average wage of $21.75 per hour, for May 2012 (Bureau of Labor Statistics, 2012). Assuming 750 participants fill out the survey, the total estimated respondent labor cost is $8,156.

		(ii) Estimating Capital and Operations and Maintenance Costs

There are no anticipated capital, operations or maintenance costs associated with this collection.

		(iii) Capital/Start-up Operating and Maintenance (O&M) Costs

There are no anticipated capital, operations or maintenance costs associated with this collection.

		(iv) Annualizing Capital Costs

There are no anticipated capital, operations or maintenance costs associated with this collection.

	6(c) Estimating Agency Burden and Cost

The various aspects of the survey mailing are assumed to be done by the principal investigators, with an associated hourly wage rate of $32.50. Preparing survey mailings, tracking nonrespondents, sending new mailings as needed, and data entry are anticipated to amount to 8 weeks total or 320 hours of work. Agency labor cost would be 320 hours times $32.50 per hour or $10,400.

	6(d) Estimating the Respondent Universe and Total Burden and Costs

Assuming 750 participants throughout Oregon fill out the survey, the total labor cost is estimated at $8,156.

	6(e) Bottom Line Burden Hours and Cost Tables

Item
Quantity
Cost
Public Burden
Time burden: 0.5 hours per respondent
750 persons
375 hours; $8,156 labor
Agency Burden
Time burden
Entire project
320 hrs; $10,400 labor
Mailing list
Mailing lists for Oregon, including sufficient coverage of subpopulations
$1,000
Prenotice letter paper and printing
2,500 pieces
$175
Prenotice envelopes
2,500 pieces
$250
Prenotice postage (bulk mail)
2,500 pieces
$1,000
Color surveys paper and printing
3,000 pieces
(includes estimated replacements)
$4,400
Printing return envelopes 10.5" x 7.5"
3,000 pieces
(includes estimated replacements)
$600
Outgoing envelopes 11.5" x 8.75"
3,000 pieces
(includes estimated replacements)
$450
Outgoing survey postage (bulk mail)
3,000 pieces
(includes estimated replacements)
$2,800
Return survey postage (bulk mail)
750 pieces
$750
Reminder postcard paper & printing
2,500 pieces
$150
Total

$30,131

The estimated respondent burden for this study is 750 hours and $8,156. The estimated agency cost for this study is 320 hours and $10,400. Agency costs besides labor hours total $11,575 for the mailing list, paper, printing, and postage.

	6(f) Reasons for Change in Burden

The survey is a one-time data collection activity.

	6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is estimated to average 0.5 hours per response.  Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information.  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.

  To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-ORD-2013-0448, which is available for online viewing at www.regulations.gov, or in person viewing at the Office of Research & Development (ORD) Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays.  The telephone number for the Reading Room is<PHONE_NUMBER>, and the telephone number for the ORD Docket is<PHONE_NUMBER>.  An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-HQ-ORD-2013-0448 and OMB Control Number 2080-NEW in any correspondence.

Part B of Supporting Statement

1. Survey Objectives, Key Variables, And Other Preliminaries
(a) Survey Objectives

The objectives of the survey are bulleted below:
   * To estimate public values for changing the status of threatened Willamette watershed Spring Chinook and steelhead.
   * To estimate public values for the time to recovery (if recovery is chosen) for Willamette watershed Spring Chinook and steelhead.
   * To compare estimated public values for urban and rural households within the Willamette watershed.
   * To compare estimated public values for households within and outside of the Willamette watershed.

(b) Key Variables

The survey asks respondents whether they would choose an annual household tax increase for the next 25 years in exchange for changes in the scope and timing of Willamette basin Spring Chinook salmon and steelhead recovery. The key variables are:

Status of Willamette Basin Wild Salmon and Steelhead: This is a variable describing the recovery status and annual abundance of wild fish returning to the Willamette basin.  The survey considers three possible levels of this variable.  The future baseline is termed  'No Intervention / Threatened'.  With this option there is no change in recovery status or fish abundance from current conditions.  The risk of Spring Chinook salmon going extinct in the next 100 years remains between 60 and 100 percent.  Two different increases from the baseline are posed.  These increases are termed 'minimal recovery' and 'broadsense recovery'.  'Minimal recovery' represents an increase in wild fish returning to the Willamette basin from 20,000 (current status) to 40,000 fish.  Under this option, the risk of going extinct in the next 100 years is 'no longer significant'.   'Broadsense recovery' represents an increase in wild fish returning to the Willamette basin from 20,000 (current status) to 70,000 fish.  Under this option, the risk of going extinct in the next 100 years is 'no longer significant'.

Tax increase per year: Each change varying from the expected future of reduced flows and cottonwood/willow acreages in the North and South has an associated cost. These cost levels currently vary from $0 for the Expected Future, to as high as $50 (subject to change based on pilot survey results). These cost levels are not tied to actual costs estimates for the changes, but rather are designed to bracket values. That is, the design goal is to set cost levels such that some people agree to them and some people don't agree to them. A pilot survey will be used to test whether cost levels posed in the survey should be revised.

(c) Statistical Approach

The statistical approach to analyzing survey results will be a multinomial logit model (Ben-Akiva and Lerman, 1985).

(d) Feasibility

The survey has been extensively pretested, as described below, to balance providing background needs and cognitive difficulty for respondents. The principal investigators have research funding to cover the costs of the survey.

2. Survey Design
(a) Target Population And Coverage

The target population is households in the state of Oregon. Respondent coverage will be such that each household in each respective area has an equal probability of being selected to receive a survey, based on the mailing list.

(b) Sample Design
(i) Sampling Frame

The sample frame is households in the state of Oregon.. A sample will be such that each household in each respective area has an equal probability of being selected to receive a survey, based on best available mailing lists, available from companies specializing in preparing mailing lists for surveys.

(ii) Sample Size

There is no single sample size choice since there will be uncertainty with estimates regardless of sample size. This survey design will utilize the rule of thumb of available from the developers of Sawtooth Software (Orme, 1998), a software popular for designing choice sets. This formula was also recently utilized by NOAA (OMB # 0648-0585). The rule of thumb formula for a minimum sample size for each Oregon subpopulation is:

(n x t x a)/c > = 500

Where:
n = minimum number of respondents
t = number choice questions
a = number of alternatives per task (not including the "status quo" option)
c = number of "analysis cells."

When considering main effects, c is equal to the largest number of levels for any single attribute. If considering all two-way interactions, c is equal to the largest product of levels of any two
attributes (Orme, 1998). The sample size for each Oregon subpopulation will be based on a main effects model. A minimum of 3 choice questions will be in each survey, with two options each (not counting "expected future"), and the maximum number of levels for any single attribute is 3. Thus the minimum sample size "n" is 250 for each of the three subpopulations to be sampled. This value is larger than the 200 minimum suggested when the intent is to compare subgroups (Orme, pg 67). Bateman et al. (2002; pg. 110) recommend a sample size of 500 to 1,000 (for each subgroup) for close-ended contingent valuation questions, but also note a smaller sample size can be used if one collects more information per respondent (as with replications in choice experiments). With a target response rate of 30%, this means approximately 2,500 Oregon households total will receive a survey, distributed across the three target subpopulations.

(iii) Stratification Variables

Urban Oregon households within the Willamette valley, rural Oregon households within the Willamette valley, and Oregon households outside of the Willamette valley will be treated as different subpopulations.

(iv) Sampling Method

A sample mailing list for each Oregon subpopulation will be purchased from a mail survey support company. The company will be given instructions to prepare the sample such that each household in each subpopulation has an equal chance of being chosen (a simple random sample approach).

(v) Multi-Stage Sampling

Not applicable.

(c) Precision Requirements
(i) Precision Targets

Louviere et al. (2000) provide a formula, based on elementary statistical theory, for the minimum sample size "n" for target accuracy and confidence interval of predicting a proportion, assuming a large sample frame population, a simple random sample strategy is used, and choice occasions from each respondent can be assumed to be independent:

n > = (q/r*p*a[2])Φ[-1]((1+α)/2)

where "p" is the population proportion, as predicted within "a" percent of the true value with probability "α" or greater, "q" = 1-p, "r" is replications (choice occasions per respondent) and "Φ[-1] (.)" is the inverse cumulative normal distribution function. This study will use a target of plus or minus 10% for predicting population proportions to be estimated, with a probability of 0.95. Assuming a population proportion of 0.3, and a minimum r of 3, the minimum sample size is 174 respondents, less than the 250 sample size planned for each subpopulation.

(ii) Nonsampling error

With a target response rate of 30% there will be a large percentage of nonrespondents. If preferences of nonrespondents differ markedly from respondents, nonresponse bias will affect the results. A nonresponse analysis will be conducted by comparing the sociodemographics of the respondents with the sampling frame. A description of any sociodemographics that were less represented in the responses will be included in the results write-up. If respondents and nonrespondents have markedly different sociodemographics, the sociodemographic vector of the sampling frame (as opposed to the respondents) will be fed into the model to obtain valuation estimates for an "average" household (Morrison, 2000).

(d) Questionnaire Design

The current draft survey is also uploaded to the federal register (note that the pages numbers are out of sequence on the electronic file, they are sequenced so that they will print correctly double-sided). Below is a description of the sections and questions.

PART 1
Background. The title on the cover page reads "Oregon Salmon and Steelhead Recovery - What do YOU think should be done?" and the cover photo shows a salmon jumping up a waterfall. Page 2 describes the rationale for the survey and provides a brief description of what the survey is about.  Short descriptions of the fish species considered, the geographic extent of the recovery plan, and current population numbers of salmon and steelhead are provided and compared to estimates of fish returning to the rest of the Columbia basin. Page 3 provides additional background information on Willamette basin salmon and steelhead and lists some of the primary factors that have led to them being added to the Endangered Species list.  A map of the Willamette basin is shown beneath the background information.  Page 4 provides detailed background information on the wild origin salmon and steelhead that are the focus of the recovery plan.  Additional information is provided describing the definition of the current 'threatened' status and some information is given on additional fisheries in the Willamette basin and other wild salmon and steelhead populations in Oregon. Page 5 provides a description of hatchery origin salmon and steelhead in the Willamette basin. These descriptions are provided so that respondents clearly understand the differences between hatchery origin fish and the populations of wild origin fish that are target of the recovery plan. Pages 6, 7,  8, and 9 provide information on the subsequent choice questions including detailed descriptions of the different recovery options.  A description of the payment mechanism is also provided.  The first attribute of the recovery option is the wild salmon and steelhead status.  This includes its label ('threatened', 'minimal recovery', or 'broadsense recovery') along with the projected number of wild fish returning annually to the Willamette basin.  The second attribute for each recovery option is 'time to recovery'.  This attribute describes the number of years that the recovery plan will take to implement before the chosen recovery status is achieved.  Under the 'no recovery' option there is no schedule of recovery. Page 9 also presents a graph showing the fish population abundances as a function of recovery time.  This attribute has 4 different levels (no recovery, 15 years, 25 years, and 50 years).

PART 2
Questions 1-2: These question evaluate the respondent's understanding of the different recovery options described presented in the pages above.  Question 1 evaluates the respondent's understanding of the different recovery options and Question 2 evaluates the respondent's understanding of the 'time to recovery' options.

Questions 3- 4 evaluate the respondent's attitudes towards public issues besides the Willamette recovery plan for salmon and steelhead.  These questions serve as a reminder of the many public issues for which public resources can be allocated.

Question 5 begins the respondents' thought process of weighing the different attributes that will comprise the subsequent choice questions.  This questions asks them to the rate the importance of each attribute.

Questions 6 through 8: These questions comprise the choice experiment portion of the survey, where respondents choose between different cost levels and recovery plan options. There is always an opt-out zero cost option. Following standard techniques of choice experiments, the options (also known as profiles) presented to respondents will be a fraction of the theoretically possible combinations of attributes, selected to yield the most informative preference information.  There will be different survey versions, with three questions per survey (also known as "replications").  These replications serve as an efficient method of allowing sufficient number of tradeoffs for model estimation. These practices save expense and also reduce the sample size and associated public burden.  Page 13 provides an example choice question for respondents to review before proceeding to the actual choice questions.

Choice Experiment Design
All possible choice profile tradeoffs could be presented to respondents, but would be an inefficient way to gauge preferences. Instead, "fractional factorial" models are a standard approach (Louviere et al., 2000). A statistical software will be used to develop the most efficient choice experiment design, given a total number of design choice sets to manipulate, as well as a provisional beta vector (Kuhfeld, 2010). Essentially the software will search for the questions, given the constraint on choice sets, likely to yield the most preference information. The computer generated design will be manually checked for any potentially dominating choices, or scenarios that may seem unlikely to respondents. The total number of choice sets must be at least as large as the number of parameters to be estimated and is typically much more. A number of choice sets that allows each level to occur an equal number of times is also desirable, for balance (Kuhfeld, 2010; pg. 78).

PART 3
Questions 9 - 18  These questions shed light on motivations underlying the respondent's answers, and also to test for inconsistencies in their responses. Question 10 helps identify "protest bids" for respondents that choose not to pay for philosophical reasons other  than a price that is too high.
Question 19: This question asks respondents for their views on hatchery origin versus wild origin salmon and steelhead in the Willamette basin.

PART 4
Questions 20 through 29: These are sociodemographic questions that allow comparing the received sample with the sample population as a gauge of representativeness.

3. PRETESTS AND PILOT TESTS
Pretests

The survey content and format has undergone extensive pretesting. Focus groups to test and refine the survey instrument were conducted in April 2013.  Eight focus groups were held throughout Oregon under ICR # 2090-0028.  Six of the focus groups were held within the Willamette basin and two were held outside the Willamette basin.  Focus groups were held in both urban and rural areas. Focus group participants were recruited from the general public by a market research contractor using standard market research methods, including paying participants an incentive fee as compensation for their opportunity cost of time.

The information collected from the focus groups was used to refine and develop the survey instrument to ensure that each question was easy to understand and elicited information from respondents that is consistent with each question's intent. The current draft survey instrument has also been uploaded to the federal register (note that the pages numbers are out of sequence on the electronic file, they are sequenced so that they will print correctly double-sided).

Pilot Test

A pilot survey will be mailed to a subset of the Oregon subpopulation samples. This will not represent an additional burden, but will be some designated fraction of the total mailing. This will allow for the possibility of adjusting the survey for any problems that may surface after this initial wave of survey returns before committing to the full mailing. The entire beta parameter vector (see econometric specification section below) may be revised based on analysis of the results, in particular the cost levels may need to be adjusted to efficiently bracket values. Costs will not vary between the subpopulations to guard against "starting point bias" as being a potential reason for any statistically significant changes in values between subpopulations.

4. COLLECTION METHODS AND FOLLOW-UP.
(a) Collection Methods

A mail survey collection method is selected due to its frequent and successful use in the choice experiment literature and its relatively low cost.

(b) Survey Response And Follow-up

Multiple contact methods (Dillman, 2009; pg 242) will be used. Thus, those who have already responded will be tracked in a spreadsheet to ensure follow-up mailings are only sent to those who have not yet responded.

5. ANALYZING AND REPORTING SURVEY RESULTS
(a) Data Preparation

All data entry will be conducted by the Principal Investigators. Debriefing question responses that are at odds with voting question responses will be used to flag respondent confusion, and these data will not be used. Responses that indicate protest to the payment vehicle used in this survey, i.e. philosophical objection to increased taxes, will not be used. Responses from persons less than 18 yrs of age as indicated from the `what year were you born' question will not be used.

(b) Analysis

A standard multinomial logit model, as described by Ben-Akiva and Lerman (1985), will be fit to the data. Let U = utility of household (well-being). Consider U to be a function of a vector zin of attributes for alternative i, as perceived by household respondent n. The variation of preferences between individuals is partially explained by a vector Sn of sociodemographic characteristics for person n.

Uin = V(zin, Sn) + ε(zin, Sn) = Vin + εin

The "V" term is known as indirect utility and "ε" is an error term treated as a random variable (McFadden 1974), making utility itself a random variable. An individual is assumed to choose the option that maximizes their utility. The choice probability of any particular option (Expected Future, Option A, or Option B) is the probability that the utility of that option is greatest across the choice set Cn:

P (i│Cn) = Pr[Vin + εin  >=  Vjn + εjn , for all j ∈ Cn, j not equal to i]

If error terms are assumed to be independently and identically distributed, and if this distribution can be assumed to be Gumbel, the above can be expressed in terms of the logistic distribution:
Pn(i) = e[μVin] / ∑ e[μ][Vj][n]
The summation occurs over all options Jn in a choice set. The assumption of independent and identically distributed error terms implies independence of irrelevant attributes, meaning the ratio of choice probabilities for any two alternatives is unchanged by addition or removal of other unchosen alternatives (Blamey et al. 2000). The "μ" term is a scale parameter, a convenient value for which may be chosen without affecting valuation results if the marginal utility of income is assumed to be linear. The analyst must specify the deterministic portion of the utility equation ``V,'' with subvectors z and S. The vector z comes from choice experiment attributes, and the vector S comes from attitudinal, recreational, and sociodemographic questions in the survey. An econometrics software will be used to estimate the regression coefficients for z and S, with a linear-in-parameters model specification. These coefficients are used in estimating average household value for a change in one level to another level of a particular attribute for welfare estimation. Welfare of a change is given by (Holmes & Adamowicz 2003):

$ Welfare = (1/βc)[V[0] - V[1]]

where βc is the coefficient on cost, V[0] is an initial scenario, and V[1] is a change scenario.

Econometric Specification

A main effects utility function is hypothesized.  A generic format of the indirect utility function to be modeled is:

V = βo  + β1(Recovery status) + β2(Time to recovery) + β5(Cost)

(c) Reporting Results
The results will be written up and submitted to a peer-reviewed environmental journal.

References

Arrow, K., Solow, R., Leamer, E., Portney, P., Rander, R., Schuman, H., 1993. Report of the NOAA panel on contingent valuation. Federal Register 58(10): 4602-14.

Bateman, I.J., R.T. Carson, B. Day, M. Hanemann, N. Hanley, T. Hett, M. Jones-Lee, G.
Loomes, S. Mourato, E. Ozdemiroglu, D.W. Pierce, R. Sugden, and J. Swanson. 2002.
Economic Valuation with Stated Preference Surveys: A Manual. Northampton, MA:
Edward Elgar.

Ben-Akiva, M., and S. R. Lerman. 1985. Discrete choice analysis. MIT Press, Cambridge, Massachusetts.

Blamey, R. K., J. W. Bennett, J. J. Louviere, M. D. Morrison, and J. Rolfe. 2000. A test of policy labels in environmental choice modeling studies. Ecological Economics 32:269 - 286.

Boyd, J., Banzhaf, S., 2007. What are ecosystem services? The need for standardized environmental accounting units. Ecological Economics 63 (2 - 3), 616 - 626.

Brouwer, R. 2000. Environmental value transfer: state of the art and future prospects. Ecological Economics 32(1): 137-152.

Bureau of Labor Statistics. 2012. http://www.bls.gov/oes/current/oes_or.htm#00-0000 . Retrieved May, 2013.

Desvousges, W.H., Naughton, M.C., and G.R. Parsons. 1992. Benefit transfer: conceptual problems in estimating water quality benefits using existing studies. Water Resources Research 28 (3), 675 - 683.

Dillman, D.A., J.D. Smyth, and L.M. Christian. Internet, Mail, and Mixed-Mode Surveys: The Tailored Design Method. Third Edition. 2009. John Wiley & Sons, Inc., Hoboken, N.J.

Hoehn, J.P., Lupi, F., Kaplowitz, M.D., July, 2003. Untying a Lancastrian bundle: valuing ecosystems and ecosystem services for wetland mitigation. Journal of Environmental Management 68(3): 263-272.

Holmes, T. P., and W. L. Adamowicz. 2003. Attribute-based methods. Pages 171 - 220 in P. A. Champ, K. J. Boyle, and T. C. Brown, editors. A primer on nonmarket valuation. Chap . 6. Kluwer Academic Publishers, The Netherlands.

Johnston, R.J., Weaver, T.F., Smith, L.A., Swallow, S.K., April, 1995. Contingent Valuation Focus Groups: Insights from Ethnographic Interview Techniques. Agricultural and Resource Economics Review, 56-68.

Kaplowitz, M.D., Hoehn, J.P., February, 2001. Do focus groups and individual interviews reveal the same information for natural resource valuation? Ecological Economics 36(2): 237-247.

Kuhfeld, W.F. 2010. Marketing Research Methods in SAS. SAS 9.2 Edition, MR-2010. Available for download at: http://support.sas.com/techsup/technote/mr2010.pdf.

McFadden, D. 1974. Conditional logit analysis of qualitative choice behavior. Pages 105 - 142 in P. Zarembka, editor. Frontiers in econometrics. Chap. 4. Academic Press, New York.

Morrison, M. 2000. Aggregation biases in stated preference studies. Australian Economic Papers 39:215 - 230.

Louviere, J.J., D.A. Hensher, and J.D. Swait. 2000. Stated Choice Methods: Analysis and Application. Cambridge University Press. 402 p.

Morgan, D.L., and R.A. Krueger. 1998. Focus Group Kit (6 volumes). Sage Publications, Thousand Oaks, CA.

NOAA Office of Habitat Conservation and Office of Response and Restoration, and Stratus Consulting. 2012. Ecosystem Valuation Workshop (binder prepared for workshop participants). Dates: June 6-7, 2012. Location: Asheville, N.C.

Oregon Department of Fish and Wildlife and National Marine Fisheries Service. 2011. Upper Willamette River Conservation and Recovery Plan for Chinook Salmon and Steelhead. http://www.dfw.state.or.us/fish/CRP/upper_willamette_river_plan.asp. Retrieved May, 2013.

Orme, B. 1998. Sample Size Issues for Conjoint Analysis Studies. Sawtooth Software Research Paper Series, Sawtooth Software, Inc.

Ringold, P.L., Boyd, J.W., Landers, D., Weber, M., Meeting Date: July 13 to 16, 2009. Report from the Workshop on Indicators of Final Ecosystem Services for Streams. EPA/600/R-09/137. 56 p. http://www.epa.gov/nheerl/arm/streameco/index.html

Ringold, P.L., J. Boyd, D. Landers, and M. Weber. 2013. What data should we collect? A framework for identifying indicators of ecosystem contributions to human well-being. Frontiers in Ecology and the Environment 11: 98 - 105.

Rubin, H.J., Rubin, I.S, 2005. Qualitative Interviewing. 2nd Edition. Sage Publications. Thousand Oaks, CA.

USEPA. 2012a. Sustainable and Healthy Communities: Strategic Research Action Plan 2012-2016. http://www.research.epa.gov/research/docs/shc-strap.pdf.  Retrieved May, 2013.

USEPA. 2012b. Safe and Sustainable Water Resources.
http://www.epa.gov/research/docs/sswr-strap.pdf. Retrieved May, 2013.

USEPA. 2013a. Research Programs: Science for a Sustainable Future. http://www.epa.gov/ord/research-programs.htm. Retrieved April, 2013.

USEPA. 2013b. Sustainability. http://www.epa.gov/sustainability/. Retrieved April, 2013.

Wallmo, K. and D. Lew. 2012.  Public Willingness to Pay for Recovering and Downlisting Threatened and Endangered Marine Species.  Conservation Biology. 26(5):830-839.

Willamette Water 2100, 2013.  http://www.water.oregonstate.edu/ww2100/.  Retrieved May 2013.

Weber, M., Stewart, S., 2009. Public Valuation of River Restoration Options on the Middle Rio Grande. Restoration Ecology 17(6):762-771.


As stated by the NOAA Blue Ribbon Panel on Contingent Valuation ( Arrow et al. 1993, p. 4610), "  some antagonists of the CV approach go so far as to suggest that there can be no useful information content to CV results. The Panel is unpersuaded by these extreme arguments." The panel later follows with the conclusion "[ t] he Panel concludes that under [ conditions described in the report], CV studies convey useful information. We think it is fair to describe such information 52 as reliable by the standards that seem to be implicit in similar contexts, like market analysis for new and innovative products ." It appears that the comments of Section B reflect the type of " extreme" opinions that the NOAA panel found unconvincing.

Section B suggests that stated preference derived from CV studies are akin to " juries' punitive damage awards," and are " not consistent with economists' rational models." This statement is again at odds with current practice as reflected by the NOAA panel ( p. 4610), which states that " CV studies can produce results reliable enough to be the starting point of a judicial process of damage assessment, including lost passive use values." Moreover, as stated by Freemen ( 2003, p. 154), " stated preference valuation methods  are likely to offer the only feasible approaches to estimating nonuse values."

The primary theme of the comments in this section appears to be the distinction between behavior in real markets and behavior stated in surveys   with the former assumed by the commenter to reflect true, underlying values, and the latter assumed to reveal only " expressions of attitudes." However, while critics of stated preference methods often claim vast divergences between stated and real market behavior, evidence from comparisons of binding referenda to stated preference responses contradicts this extreme opinion. Existing studies find close correspondence between choices in stated preference surveys and voting behavior in binding, consequential referenda ( Bateman et al. 2002, p. 318; Schläpfer et al. 2004). Hence, in these true tests of criterion validity, responses in hypothetical and real contexts comport quite closely, suggesting that stated preference surveys can provide useful indications of that which individuals " are willing to forgo to enjoy a particular benefit" ( Circular A 4, as quoted in the received comment).

As a final note on this section, EPA emphasizes that many of the claims made in Section B represent empirical questions that are appropriately addressed within the survey design process. For example, with regard to the incentive structure of stated preference questions   that are often cited as a key distinction between stated and real market choices   Carson et al. ( 1999, p. 124) state that " one must endeavor to provide questions with a proper incentive structure." As emphasized by the NOAA Panel ( Arrow et al. 1993), Schkade and Payne ( 1994), Mitchell and Carson ( 1989) and many others, appropriate survey design can identify the mechanisms through which respondents respond to CVM questions and assess whether responses reflect the types of tradeoffs required by neoclassical theory for appropriate expressions of stated values. Thus, EPA is using focus groups to assist in the design of the stated preference study to value ecological gains from the 316( b) regulation.

As emphasized by Johnston et al. ( 1995), Mitchell and Carson ( 1989), Bateman et al. ( 2002), Desvousges et al. ( 1984), Desvousges and Smith ( 1988) and many others, the use of focus groups to assist in the design of stated preference surveys is well established, as is the capacity of focus groups to provide insight into motivations underlying respondents' stated willingness to pay values. Indeed, EPA emphasizes that focus groups will be used, following the advice of Mitchell 53 and Carson ( 1989), Desvousges et al. ( 1984) and Johnston et al. ( 1995), to test for and eliminate or ameliorate potential biases which may be associated with stated preference methodology.

Within this context, EPA believes that the potential concerns reflected in Part B provide even stronger rationale for conducting focus groups   as these comments reflect exactly the type of issues that focus groups are meant to address in stated preference survey design. Accordingly, EPA will take special care within the proposed focus groups to address the concerns and issues raised by this section.

Part III The commenter states that survey respondents will be unable to isolate " pure non use values that are measurable directly, and that indirect use values are likely to capture the full value of the resource." Thus, EPA should use other methods ( experimental economics) for measuring nonuse values. For detailed responses to this comment, see EPA's response to Part I, Section A, page5, above and EPA's response to Part III, Section B.

Part III, Section A The commenter asserts that EPA was unable to demonstrate that the values of reduced damages to forage species and non landed commercial and recreational species are " indeed" non use values. This section repeats issues raised in Part II, Section A, page 5. For a response to this comment, see EPA's response to Part I, Section A, page5, above. Part III, Section B EPA emphasizes that the TER comment on the potential of the experimental economics methods to provide superior estimates compared to the stated preference methods ( as in Part II above) is focused more on stated preference surveys than on focus groups. The ICR in question addresses focus groups   not the survey that may be designed using the proposed focus groups. There is no evidence in the literature that suggests that experimental economics methods provide a substitute for qualitative evidence that may be gathered from appropriately moderated focus group sessions.

More broadly, however, Part III, Section B of the received comments proposes experimental economics as a means to measure " individuals' true willingness to pay for " non use" items," using " cash motivated students." EPA has a number of concerns with this proposed solution, as reflected in the current literature.

First, and perhaps most importantly, it is quite unclear how the proposed experimental economics methods would estimate non use values, given the majority position in the literature that " stated preference valuation methods  are likely to offer the only feasible approaches to estimating nonuse values" Freemen ( 2003, p. 154). Indeed, EPA guidelines for economic analysis ( US EPA 2000, p. 84) state that " contingent valuation is the only established method capable of measuring 54 non use values." While experimental methods have often been used to assess the convergent validity ( often inappropriately referred to as criterion validity ( Bateman et al. ( 2002)) of CVM responses addressing private and in some cases public goods, EPA is aware of no literature showing conclusively that experimental economics methods are able to reliably estimate non use values.

EPA also questions the supposition that experimental economics methods will by default provide appropriate measures of underlying willingness to pay   or criterion values from which stated preferences may be compared. Notwithstanding the common and theoretically unsupported presumption that simulated markets requiring real payments necessarily reveal true criterion values ( i. e., actual WTP), the markets used in economic lab experiments universally incorporate simulated elements as a means to permit comparisons with hypothetical markets   particularly in cases involving public goods. For example, researchers often simulate markets in experimental laboratory settings, or might implement surveys that require respondents to mail actual payments in order to obtain specified public goods ( Murphy and Stevens 2004; Spencer et al. 1998).

While such simulated markets   experimental or otherwise   might generate unbiased WTP estimates, they are often conducted in institutional settings unfamiliar to respondents. Such settings may generate novel or unusual behavior, confusion, distrust, or other behaviors that may lead to misstatements of true, underlying WTP. For such reasons Bateman et al. ( 1987) argue that comparisons involving WTP estimates obtained through simulated or experimental markets do not qualify as true tests of criterion validity ( i. e., they do not provide unambiguous measures of true willingness to pay in actual markets). The most common alternative   the use of individual or group donation mechanisms ( e. g., Champ et al. 1997; Foster et al. 1997; Seip and Strand 1992)   suffers from confounding effects of free riding and the associated lack of incentive compatibility ( Bateman et al. 1987; Shläpfer et al. 2004). As a result, as stated by Murphy and Stevens ( 2004, p. 185), one cannot unambiguously claim that values estimated using laboratory experiments are any more representative of true willingness to pay than values estimates using hypothetical markets.

Moreover, EPA strongly questions the ability of lab experiments with college students   as proposed in Part III, Section B   to provide valid measures of non use values among the general population. The literature demonstrates that willingness to pay varies according to demographic attributes ( e. g., Johnston et al. 2003). Moreover, theory indicates that willingness to pay is bounded by income ( i. e., the budget constraint). College students clearly face a budget constraint distinct from that faced by the larger population   and likely have underlying preferences that differ as well. Hence, EPA feels that responses from college students   like responses from any single demographic group   are likely to biased and thus unlikely to provide valid inferences regarding preferences of the general population affected by the proposed Phase III regulations. For this reason EPA is using focus groups drawn from general population. 55 References Arrow, K. , R. Solow, E. Leamer, P. Portney, R. Rander, and H. Schuman. 1993. Report of the NOAA Panel on Contingent Valuation, Federal Register 58 ( 10): 4602 4614.

Bateman, I. J., R. T. Carson, B. Day, M. Hanemann, N. Hanley, T. Hett, M. Jones Leee, G. Loomes, S. Mourato, E. Ozdemiroglu, D. W. Pierce, R. Sugden, and J. Swanson. 2002. Economic Valuation with Stated Preference Surveys: A Manual. Northampton, MA: Edward Elgar.

Boardman, A. E., D. H. Greenberg, A. R. Vining, and D. L. Weimer. 2001. Cost Benefit Analysis: Concepts and Practice, 2nd edition. Upper Saddle River, NJ: Prentice Hall.

Carson, R. T., N. E. Flores, and R. C. Mitchell. 1999. The Theory and Measurement of Passive Use Value, in Valuing Environmental Preferences: Theory and Practice of the Contingent Valuation Method in the US, EU, and Developing Countries, edited by I. J. Bateman and K. G. Willis, Oxford University Press, Oxford, UK.

Champ, P. A., R. C. Bishop, T. C. Brown, and D. W. McCollum. 1997. " Using Donation Mechanisms to Value Nonuse Benefits from Public Goods." Journal of Environmental Economics and Management 33: 151 162.

Desvousges, W. H., V. K. Smith, D. H. Brown, and D. K. Pate. 1984. The Role of Focus Groups in Designing a contingent Valuation Survey to Measure the Benefits of Hazardous Waste Management Regulations. Research Triangle Institute: Research Triangle Park, NC.

Desvousges, W. H. and V. K Smith. 1988. Focus Groups and Risk Communication: the Science of Listening to Data. Risk Analysis 8: 479 484.

Foster, V., I. J. Bateman, and D. Harley. 1997. " Real and Hypothetical Willingness to Pay for Environmental Preservation: A Non experimental Comparison." Journal of Agricultural Economics 48( 2): 123 138.

Freeman, A. M. III. 2003. The Measurement of Environmental and Resource Values: Theory and Methods. Washington, DC: Resources for the Future.

Johnston, R. J., T. F. Weaver, L. A. Smith and S. K. Swallow. 1995. Contingent Valuation Focus Groups: Insights From Ethnographic Interview Techniques. Agricultural and Resource Economics Review 24( 1): 56 69.

Johnston, R. J., S. K. Swallow, T. J. Tyrrell and D. M. Bauer. 2003. Rural Amenity Values and 56 Length of Residency. American Journal of Agricultural Economics 85( 4): 1000 1015.

Mitchell, R. C. and R. T. Carson. 1989. Using Surveys to Value Public Goods: The Contingent Valuation Method. Resources for the Future, Washington, D. C.

Murphy, J. J. and T. H. Stevens. 2004. Contingent Valuation, Hypothetical Bias, and Experimental Economics. Agricultural and Resource Economics Review 33( 2): 182 192.

Myers, R. and B. Worm. 2003. Rapid worldwide depletion of predatory fish communities. Nature, Vol. 423, 280 283.

Schkade, D. A. and J. W. Payne. 1994. How People Respond to Contingent Valuation Questions: A Verbal Protocol Analysis of Willingness to Pay for an Environmental Regulation. Journal of Environmental Economics and Management 26: 88 109.

Schläpfer, F., A. Roschewitz, and N. Hanley. 2004. Validation of Stated Preferences for Public Goods: A Comparison of Contingent Valuation Survey Response and Voting Behavior. Ecological Economics 51( 1): 1 16.

Seip, K. and Strand, J. 1992. Willingness to Pay for Environmental Goods in Norway: A Contingent Valuation Study with Real Payments. Environmental and Resource Economics 2: 91 106.

Spencer, M. A. S. K. Swallow, and C. J. Miller. 1998. Valuing Water Quality Monitoring: A Contingent Valuation Experiment Involving Hypothetical and Real Payments. Agricultural and Resource Economics Review 27( 1), 28 42.

Trivedi, Bijal P. 2002. " Cold war military technologies have devastated global fish populations." National Geographic Today. February 25, 2002. ( http:// www. seaaroundus. org/ magazines/ 2002/ NatGeograph_ 25Feb02. pdf)

U. S. EPA. 2000. Guidelines for Preparing Economic Analyses. ( EPA 240 R 00 003). U. S. EPA, Office of the Administrator, Washington, DC, September 2000.

U. S. EPA. 2004. The Regional Benefits Assessment for the Proposed Section 316( b) Rule for Phase III Facilities. ( EPA 821 R 04 017). U. S. EPA, Office of Water, Washington, DC, November 2004.

U. S. Office of Management and Budget ( OMB). 1996. " Economic Analysis of Federal Regulations under Executive Order 12866." January 11, 1996. Available at: http:// www. whitehouse. gov/ omb/ inforeg/ riaguide. html. 57 Attachment 5: EPA Response to Public Comments from PSEG Corporation Services ( Docket ID: OW 2004 0020 0007)

The brief letter from the PSEG Corporation Services ( PSEGCS) does not address focus groups explicitly, but rather states that PSEGCS agrees with and supports comments submitted by the Utility Water Act Group ( UWAG), of which PSEGCS is a member. Thus, EPA refers interested parties to the document entitled " Response to Comments from the American Chemistry Council, American Forest & Paper Association, American Iron and Steel Institute, American Public Power Association, American Petroleum Institute, and Utility Water Act Group and Accompanying Triangle Economic Research ( TER) Report."