COASTAL ZONE 

MANAGEMENT

Opportunities Exist for 

NOAA to Enhance Its 

Use of Performance 

Information

Report to Congressional Committees

July 2014

GAO-14-592

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-592, a report to 

congressional committees

July 2014

COASTAL ZONE MANAGEMENT

Opportunities Exist for NOAA to Enhance Its Use of 

Performance Information

Why GAO Did This Study

The U.S. coast is home to more than

half the U.S. population and integral to 

the nation’s economy. Under the 

Coastal Zone Management Act, NOAA

administers the CZMP, a federal-state 

partnership that encourages states to

balance development with protection of

coastal zones in exchange for federal 

financial assistance and other 

incentives. In 2008, GAO reviewed the 

CZMP and recommended

improvements for CZMP performance

assessment tools.

A fiscal year 2013 appropriations 

committee report mandated GAO to

review NOAA’s implementation of the 

act. This report examines (1) how 

states allocated CZMP funds awarded 

in fiscal years 2008 through 2013 and 

(2) how NOAA’s primary performance 

assessment tools have changed since 

GAO’s 2008 report and the extent to 

which NOAA uses performance 

information in managing the CZMP. 

GAO reviewed laws, guidance, and 

performance-related reports; analyzed 

CZMP funding data for fiscal years

2008-2013; and interviewed NOAA 

officials and a nongeneralizeable 

sample of officials from seven states

selected for receiving the most fiscal 

year 2012 funding in each of NOAA’s 

regions.

What GAO Recommends

GAO recommends that NOAA

document an approach to analyze and 

revise, as appropriate, its performance 

measures against key attributes, revise

its process for selecting stakeholders 

to survey in its state program 

evaluations, and document a strategy 

for using the performance information it 

collects. NOAA concurred with the 

recommendations.

What GAO Found

During fiscal years 2008 through 2013, the 34 states participating in the National 

Oceanic and Atmospheric Administration’s (NOAA) National Coastal Zone 

Management Program (CZMP) allocated nearly $400 million in CZMP funds for a 

variety of activities. States allocated this funding for activities spanning six broad 

focus areas based on goals outlined in the Coastal Zone Management Act. For 

example, states allocated about a quarter of their CZMP funding to the coastal 

habitat focus area, according to NOAA’s analysis. Coastal habitat activities 

encompassed a variety of actions to protect, restore, or enhance coastal habitat 

areas, such as habitat mapping or restoration planning efforts of marsh habitats 

for fish and wildlife and enhanced recreational opportunities. 

NOAA’s two primary performance assessment tools—its CZMP performance 

measurement system and state program evaluations—have limitations, even with 

changes NOAA made since 2008, and NOAA makes limited use of the 

performance information it collects. Regarding the performance measurement 

system, NOAA has made changes such as taking steps intended to improve the 

reliability of data it collects. However, its current measurement system does not 

align with some key attributes of successful performance measures, including the 

following: 

• Balance: a balanced set of measures ensures that a program’s various goals 

are covered. NOAA removed the coastal water quality focus area, one of six 

focus areas based on goals in the act, to streamline the performance

measurement system. As a result, the system may not provide a complete 

picture of states’ overall performance across all focus areas based on goals 

in the act.

• Limited overlap: measures should produce new information beyond what is 

provided by other data sources. NOAA’s system includes measures that 

overlap with financial data provided in cooperative agreements. By requiring 

states to submit financial data available through other sources, NOAA may 

be unnecessarily burdening states with data collection requirements.

NOAA plans to review and potentially revise its measurement system, but it has 

not documented the approach it plans to take, including how the measures will 

align with key attributes of successful performance measures. Regarding state 

program evaluations, in 2013, NOAA revised its process to conduct evaluations 

more efficiently, at a reduced cost. However, GAO identified a limitation in 

NOAA’s method for sampling stakeholders to survey under its revised process 

that may result in the selection of stakeholders that do not span all six focus 

areas based on goals of the act. Finally, NOAA makes limited use of the 

performance information it collects from these tools. For example, since it began 

collecting performance measurement data in 2008, NOAA used the data once to 

report on accomplishments. NOAA recognizes the importance of using 

performance information to improve program implementation, but it has not 

documented a strategy for how it will use its performance information to manage 

the program. As a result, NOAA may not be realizing the full benefit of collecting 

View GAO-14-592. For more information, performance information.

contact Anne-Marie Fennell at (202) 512-3841 

or fennella@gao.gov.
Page i GAO-14-592 Coastal Zone Management

Letter 1

Background 4

States Allocated Nearly $400 Million in CZMP Funds during Fiscal 

Years 2008 through 2013 for a Wide Range of Coastal 

Management Activities 13

Limitations Exist with NOAA’s Performance Assessment Tools, 

and NOAA Makes Limited Use of Performance Information 20

Conclusions 33

Recommendations for Executive Action 34

Agency Comments and Our Evaluation 35

Appendix I Objectives, Scope, and Methodology 37

Appendix II National Coastal Zone Management Program (CZMP) 

Performance Measurement System Summary Data 41

Appendix III Key Attributes of Successful Performance Measures Previously 

Identified by GAO 48

Appendix IV Comments from the Department of Commerce 49

Appendix V GAO Contact and Staff Acknowledgments 53

Tables

Table 1: Focus Areas Based on Goals for State Coastal 

Management Programs Outlined in the Coastal Zone 

Management Act 5

Table 2: Types of Funding Awarded to State Coastal Management 

Programs under the Coastal Zone Management Act 8

Table 3: National Oceanic and Atmospheric Administration 

Actions to Address Recommendations for the National 

Coastal Zone Management Program (CZMP) Made by

GAO in 2008 12

Contents
Page ii GAO-14-592 Coastal Zone Management

Table 4: Components of the National Oceanic and Atmospheric 

Administration’s (NOAA) Former and Revised Evaluations 

of State Coastal Management Programs 27

Table 5: Summary of National Coastal Zone Management 

Program (CZMP) Performance Measurement System 

Data, 2011 through 2013 41

Figures

Figure 1: Coastal States Participating in the National Coastal Zone 

Management Program 10

Figure 2: States’ Coastal Zone Management Program Funding 

Allocations by Focus Area, Fiscal Years 2008 through 

2013 14

Abbreviations

CZMP National Coastal Zone Management Program

EPA Environmental Protection Agency

GPRA Government Performance and Results Act of 1993

NOAA National Oceanic and Atmospheric Administration

OCRM Office of Ocean and Coastal Resource Management 

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Page 1 GAO-14-592 Coastal Zone Management

441 G St. N.W.

Washington, DC 20548

July 16, 2014 

The Honorable Barbara Mikulski

Chairwoman

The Honorable Richard Shelby

Ranking Member

Subcommittee on Commerce, Justice, 

Science and Related Agencies 

Committee on Appropriations

United States Senate

The Honorable Frank Wolf

Chairman 

The Honorable Chaka Fattah

Ranking Member

Subcommittee on Commerce, Justice, 

Science and Related Agencies 

Committee on Appropriations

House of Representatives

The U.S. coastal zone—which includes areas along the Atlantic, Pacific, 

and Arctic oceans, the Gulf of Mexico, and the Great Lakes—is home to 

more than half of the population of the United States and plays an integral 

role in our nation’s economy, contributing to over half of the U.S. gross 

domestic product and supporting more than 66 million jobs. The coastal 

zone provides harbors for ports, shipping, and navigation; opportunities 

for energy production from traditional sources such as offshore oil, and 

alternative sources, including wind, tidal, and wave; beaches and 

shorelines for recreation and tourism; and wetlands and estuaries that are 

critical for sustained fisheries. The coastal zone also provides important

environmental benefits including filtering pollution from runoff; buffering 

shoreline communities against storms; and providing habitat including 

spawning grounds, shelter, and food for marine life, and other threatened, 

endangered, and commercially important species. Increased population 

density and economic activity in the coastal zone, however, puts pressure 

on coastal habitats. 

In 1972, Congress enacted the Coastal Zone Management Act to balance 

the often competing demands for economic growth and development with 
Page 2 GAO-14-592 Coastal Zone Management

the need to protect coastal resources.

1 In doing so, Congress recognized 

that states have primary responsibility for planning and managing their 

coastal zones. On this basis and to help achieve the goals of the act, the 

Department of Commerce’s National Oceanic and Atmospheric 

Administration (NOAA), which has responsibility for implementing the act, 

administers a voluntary, cooperative program established under the act 

known as the National Coastal Zone Management Program (CZMP).2

 

The CZMP involves federal and state partnerships that encourage coastal 

states, Great Lakes states, and U.S. territories and commonwealths3

—

hereafter referred to as states—to balance and manage economic 

development and coastal protection. To participate, states must develop 

and implement a comprehensive coastal management program that 

addresses specific goals established in the act and meets other federal 

requirements, but states have the flexibility to design programs that best 

meet their own coastal needs. NOAA provides funding and technical 

assistance to support administrative and project-specific costs for state 

coastal management programs (state programs) it approves to participate 

in the CZMP. In fiscal year 2013, 34 of 35 eligible states had state 

programs and received CZMP funding. 

NOAA evaluates the CZMP’s performance using two primary tools—its 

CZMP performance measurement system and state program evaluations. 

NOAA, working with state programs, developed the performance 

measurement system in the mid-2000s, in response to congressional 

direction to assess the national impact of the CZMP and report on 

progress in meeting the act’s goals. In addition, NOAA is required under 

the act to conduct evaluations of each state program to assess its 

adherence to the act’s requirements. NOAA also collects performancerelated information from other sources, such as semiannual progress 

 1

Pub. L. No. 92-583, 86 Stat. 1280 (1972) (codified as amended at 16 U.S.C. §§ 1451-

1466).

2

Other programs established under the act and administered by NOAA include the 

National Estuarine Research Reserve System—a network of protected areas that provide 

research, education, and resource stewardship to help communities address coastal 

resource issues—and the Coastal and Estuarine Land Conservation Program, a funding 

program which provides matching funds to state and local governments to purchase 

priority coastal and estuarine lands of ecological, conservation, recreational, and historical 

importance. These programs are outside the scope of this review.

3

For purposes of the CZMP, the term “coastal state” is defined to include Puerto Rico, the 

Virgin Islands, Guam, the Northern Mariana Islands, and American Samoa.
Page 3 GAO-14-592 Coastal Zone Management

reports submitted by participating states describing progress in 

implementing their cooperative agreements. Cooperative agreements are 

the mechanisms by which NOAA provides congressionally appropriated 

financial assistance annually to states for the program activities they have 

agreed to undertake under the CZMP. We reviewed the CZMP in 2008 

and made several recommendations to address weaknesses we found in 

NOAA’s use of its tools to assess the performance of the CZMP, among 

others.4 NOAA agreed with all but one of our recommendations, and it 

has taken steps to address the majority of our recommendations. 

The House Appropriations Committee report for the Department of 

Commerce Fiscal Year 2013 appropriation mandated us to examine 

NOAA’s implementation of the Coastal Zone Management Act.5 Focusing 

on CZMP activities since our 2008 report, this report examines (1) how 

participating states allocated CZMP funds awarded in fiscal years 2008 

through 2013 and (2) how NOAA’s primary performance assessment 

tools have changed and the extent to which NOAA uses performance 

information to help manage the CZMP.

To conduct our work, we reviewed applicable laws, regulations, and 

NOAA guidance, including guidance on its CZMP performance 

measurement system and state program evaluations. We analyzed 

NOAA data on financial assistance awards for fiscal years 2008 through 

2013, NOAA analyses of states’ allocations of CZMP funds, and its 

performance measurement system data. To assess the reliability of these 

data, we interviewed NOAA officials and reviewed related documentation, 

and we determined the data we used to be sufficiently reliable for our 

purposes. We interviewed NOAA officials responsible for administering 

 4

GAO, Coastal Zone Management: Measuring Program’s Effectiveness Continues to Be a 

Challenge, GAO-08-1045 (Washington D.C.: Sept. 12, 2008). This report included seven 

recommendations—six recommendations to NOAA related to improving its assessment of

the effectiveness of the CZMP and one recommendation related to improving its funding 

award practices. The report also included one matter for Congressional consideration that 

Congress may wish to clarify whether it would like eligible states to receive equal amounts 

of CZMP administrative funding or whether these funds should be proportional and reflect 

each state’s respective shoreline miles and coastal population. Congress has not passed 

legislation related to this matter.

5

H.R. Rep. No. 112-463, at 21-22 (2012); see also the Explanatory Statement for the 

Senate Substitute Continuing Resolution, associated with the Consolidated and Further 

Continuing Appropriations Act of 2013, Pub. L. No. 113-6, and the House report 

incorporated by reference. 159 Cong. Rec. S1287-01 at S1300 (Mar. 11, 2013).
Page 4 GAO-14-592 Coastal Zone Management

the CZMP and conducting state program evaluations about the 

approaches they use to assess program performance, how they use 

performance information, and any changes they have made since 2008, 

including steps taken to address recommendations in our 2008 report. 

We also reviewed our and others’ work on performance assessment, 

including our work on key attributes of successful performance 

measurement systems and elements of strong evaluation designs. We 

examined NOAA’s publicly available reports and documents on CZMP 

performance, including program fact sheets, program reports, and state 

program evaluation results. We interviewed state program officials from 

the seven states that received the most fiscal year 2012 CZMP funding in 

each of NOAA’s seven regions. These include California, Florida, Hawaii, 

Maine, Michigan, Texas, and Virginia. We obtained information about 

states’ use of CZMP funds, their perspectives on NOAA’s performance 

assessment tools, and how the results of a select project in each state we 

reviewed were reported to NOAA.6 We selected projects considering such 

factors as amount of CZMP funding, types of financial assistance and 

projects, and goals established in the act. We also conducted two site 

visits to observe and learn more about CZMP projects—one to a coastal 

habitat restoration project in Texas, and one to an ocean planning project 

in Virginia. We selected these projects for site visits considering project 

type, goals of the act the project addressed, and geographic location. 

Appendix I presents a more detailed description of our objectives, scope, 

and methodology.

We conducted this performance audit from June 2013 to July 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives. 

Congress enacted the Coastal Zone Management Act in 1972 to balance 

the often competing demands for economic growth and development with 

the need to protect coastal resources. To accomplish the goals of the act, 

Congress established a framework for a voluntary federal and state 

 6

Our review of the states’ information cannot be generalized across all states or projects. 

Background 
Page 5 GAO-14-592 Coastal Zone Management

coastal management partnership, the CZMP. The CZMP represents a 

unique federal-state partnership for protecting, restoring, and responsibly 

developing the nation’s coastal communities and resources, according to 

program documents. 

The act identifies specific goals for state programs that fall into six broad 

focus areas ranging from protecting and restoring coastal habitat to 

assisting with coastal community development efforts and improving 

government coordination and decision making (see table 1). 

Table 1: Focus Areas Based on Goals for State Coastal Management Programs Outlined in the Coastal Zone Management 

Act

Focus area Goal

Coastal habitat • Protecting natural resources, including wetlands, floodplains, estuaries, beaches, dunes, 

barrier islands, coral reefs, and fish and wildlife and their habitat, within the coastal zone

Coastal water quality • Managing coastal development to improve, safeguard, and restore the quality of coastal 

waters, and to protect natural resources and existing uses of these waters

Public access • Providing for public access to the coast for recreation

Coastal hazards • Managing coastal development to minimize the loss of life and property by improper 

development in coastal hazard areas and by the destruction of natural protective features

• Studying and developing, in any case in which the Secretary considers to be appropriate,

plans for addressing the adverse effects of land subsidence and sea-level rise

Coastal community development • Assisting in redevelopment of deteriorating urban waterfronts and ports, and sensitive 

preservation and restoration of historic, cultural, and esthetic coastal features 

• Providing for priority consideration for coastal-dependent uses and orderly processes for

siting major facilities related to national defense, energy, fisheries development, recreation, 

ports and transportation and the location, to the maximum extent practicable, of new 

commercial and industrial development in or adjacent to areas where such development 

already exists

Government coordination • Coordination and simplification of procedures in order to ensure expedited governmental 

decision making for the management of coastal resources 

• Continued consultation and coordination with, and the giving of adequate consideration to 

the views of, affected federal agencies

• Giving timely and effective notification of, and opportunities for public and local government 

participation in, coastal management decision making

• Assistance to support comprehensive planning, conservation, and management for living 

marine resources, and improved coordination between state and federal coastal zone 

management agencies and state and wildlife agencies

Source: GAO analysis of Coastal Zone Management Act.| GAO-14-592

States must submit comprehensive descriptions of their coastal 

management programs—which must be approved by the states’ 

governors—to NOAA for review and approval. As specified in the act, 
Page 6 GAO-14-592 Coastal Zone Management

states must meet the following requirements to receive NOAA’s approval 

for their state programs, among others: 

• designate coastal zone boundaries that will be subject to state 

management; 

• define what constitutes permissible land and water uses in coastal 

zones; 

• propose an organizational structure for implementing the state 

program, including the responsibilities of and relationships among 

local, state, regional, and interstate agencies; and 

• demonstrate sufficient legal authorities to carry out the objectives 

and policies of the state program, including the means by which a 

state will regulate land and water uses, control development, and 

resolve conflicts among competing activities in coastal zones to 

ensure their wise use.

The act provides states the flexibility to design programs that best 

address states’ unique coastal challenges, laws, and regulations, and 

participating states have taken various approaches to developing and 

carrying out their programs. For instance, there are generally two 

organizational structures used by states to implement their programs: (1) 

networked programs, which rely on multiple state and local agencies to 

implement their programs, and (2) non-networked, or comprehensive 

state programs that administer all aspects of the program through a single 

centralized agency. The coastal management activities carried out also 

vary across states with some states focusing on permitting, mitigation, 

and enforcement activities, while other states focus on providing technical 

and financial assistance to local governments and nonprofits for local 

coastal protection and management projects. If states make changes to 

their programs, such as changes in their coastal zone boundaries or 

organizational structures, the states must submit those changes to NOAA 

for review and approval.

The act includes two primary incentives to encourage states to develop 

coastal management programs and participate in the CZMP. First, 

participating states are eligible to receive federal funding from NOAA to 

support the implementation and management of their programs, which 

the agency receives annually through congressional appropriations. In 

fiscal year 2013, NOAA awarded participating states a total of 

approximately $61.3 million, a 9 percent decline from fiscal year 2008 
Page 7 GAO-14-592 Coastal Zone Management

awards, when it awarded just over $67.5 million across participating 

states.7 NOAA awards CZMP funding to individual states across three 

fund types—administrative, enhancement, and coastal nonpoint 

program—according to requirements in the act (see table 2). The majority 

of funding NOAA awards through the CZMP is administrative funding. 

Administrative funding, which requires state matching funds, supports 

general implementation of the state’s coastal management program. 

Under the act, NOAA may also award a maximum of $10 million annually 

in enhancement program funding to participating states. Enhancement 

funding is to be used by states to develop program changes, or 

enhancements, to their NOAA-approved programs in one or more of nine 

enhancement objectives specified in the act, as listed in table 2. In 

addition, Congress has generally provided direction on the total amount of 

funds to be awarded through the coastal nonpoint program to assist with 

states’ coastal nonpoint pollution control programs, which are programs to 

ensure states have necessary tools and enforceable authorities to 

prevent and control polluted runoff in coastal areas. According to NOAA 

officials, funding has not been provided for this program since fiscal year 

2009, when nearly $3.4 million was awarded to states. States may also 

use other sources of funding for their coastal nonpoint pollution control 

programs, including administrative and enhancement funding.

 7

Adjusting for inflation, the amount of CZMP funding declined by 16 percent over the 6-

year period. NOAA officials noted that fiscal year 2013 levels were lower than they might 

otherwise be due to the across the board sequester that cut federal funding that year.
Page 8 GAO-14-592 Coastal Zone Management

Table 2: Types of Funding Awarded to State Coastal Management Programs under the Coastal Zone Management Act

Qualifications and requirements Funding uses Funding distribution

Administrative funding (awarded through sections 306 and 306A of the act)

• Approved state coastal management 

program

• State matching funds required

Funding is to support implementation of state 

programs, including 

• personnel costs, equipment, and 

supplies;

• nonconstruction related activities such as 

permitting, planning, and public 

education type projects; and 

• funding to others, including local 

governments and nonprofit 

organizations.

A portion of the funds may also be used for 

low-cost construction projects or land 

acquisition projects that enhance public 

access to the coast, facilitate redevelopment 

of urban waterfronts or ports, or preserve and 

restore coastal habitat. 

NOAA determines the amount of federal 

appropriated National Coastal Zone 

Management Program (CZMP) funds to 

be awarded to each participating state 

through this funding type by

1. establishing a minimum and 

maximum award amount for states, 

and

2. applying a weighted formula that 

considers each state’s coastal 

population and miles of shoreline.

Maximum administrative award a state 

can receive annually has generally been 

capped in appropriations acts at $2 

million.

Enhancement funding (awarded through section 309 of the act)

• Approved state coastal management 

program

• Approved 5-year assessment and 

strategy report that identifies a 

state’s priority coastal management 

needs and planned projects to 

address one or more of nine 

enhancement objectives

• No state matching funds required 

Funding must be used to address one or 

more of the following nine enhancement 

objectives specified in the act:

1. wetland protection, restoration and 

enhancement;

2. reducing and managing development in 

coastal hazard areas;

3. increased public access to the coast;

4. reduction of marine debris along the 

coast;

5. control of cumulative and secondary 

impacts of development;

6. planning for the use of ocean and Great 

Lakes resources;

7. special area management planning and 

implementation;

8. facilitating the siting of energy and 

government facilities and related 

activities; and

9. facilitating siting of aquaculture facilities.

NOAA determines the amount of federal 

appropriated CZMP funds to be awarded 

to each qualifying state through this 

funding type.

NOAA’s process for distributing 

enhancement funds to qualifying states 

uses a weighted formula that considers 

state’s coastal population and miles of 

shoreline.

A small portion is competitively awarded 

through NOAA’ Projects of Special Merit 

Program, whereby states with 5-year 

assessment and strategy reports submit 

applications for innovative projects that 

further enhance strategies related to 

select national enhancement priority areas 

identified by NOAA.
Page 9 GAO-14-592 Coastal Zone Management

Qualifications and requirements Funding uses Funding distribution

Coastal nonpoint program funding (awarded through section 310 of the act)a

• Approved state coastal management 

program

• State coastal nonpoint pollution 

control program, required as part of 

the1990 reauthorization of the act to 

further state program efforts in 

addressing coastal water quality 

protection and restoration goals, 

whereby states develop a program 

to prevent or reduce nonpoint source 

pollution from a range of sourcesb

• State matching funds required

Funding must be used to implement state 

coastal nonpoint source pollution control 

programs.

NOAA determines the amount of 

Congressionally directed CZMP funds to 

be awarded to each qualifying state 

through this funding type.

Amount of funds awarded to individual 

states considers status of coastal nonpoint 

pollution control program approval. States 

with fully approved programs received 

greater amounts of funding while states 

with conditionally approved programs, 

meeting partial requirements, receive less.

Source: GAO analysis of the Coastal Zone Management Act.| GAO-14-592

a

Section 6217 of the Coastal Zone Act Reauthorization Amendments of 1990 amended the act to 

require state programs to develop coastal nonpoint pollution control programs to restore and protect 

coastal waters. Pub. L. No. 101-508, tit. VI, subtit. C, § 6217, 104 Stat. 1388, 1388-314 (1990) 

(codified as amended at 16 U.S.C. § 1455b). For fiscal years 2008 through 2013, NOAA awarded

funding for the coastal nonpoint program through section 310 of the Coastal Zone Management Act.

b

NOAA and the U.S. Environmental Protection Agency (EPA) jointly administer the coastal nonpoint 

program at the federal level, and both agencies must approve state coastal nonpoint pollution control 

programs. Nonpoint source pollution is runoff from sources such as lawns, roadways, farms, 

construction sites, and leaking septic tanks.

Second, federal agency activities in or affecting the uses or resources of 

a participating state’s defined coastal zone are required to be consistent 

to the maximum extent practicable with enforceable policies of the state’s 

program. Under this provision, known as federal consistency, states with 

approved programs must have the opportunity to review proposed federal 

actions for consistency with enforceable policies of their state programs. 

Types of federal actions that may be reviewed by states include federal 

agency activities, such as improvements made to a military base; licenses 

or permits to nonfederal applicants; financial assistance to state and local 

governments; and outer continental shelf activities, such as oil and gas 

development. If a state finds that a federal activity is not consistent with 

the state’s enforceable policies, the state can object to the activity and 

work with the federal agency to resolve any differences between the 

proposed activity and state policies. All participating state programs have 

developed federal consistency review processes.

Thirty-four out of 35 eligible states have federally approved coastal 

management programs (see fig. 1). Most state programs have been in 

existence for more than 30 years, with the earliest program approved in 

1976, and 29 states having received federal approval for their programs 
Page 10 GAO-14-592 Coastal Zone Management

by 1986. The most recent state to begin participating in the program is 

Illinois, which received federal approval in January 2012.

Figure 1: Coastal States Participating in the National Coastal Zone Management Program 

Note: For purposes of the CZMP, the term “coastal state” is defined to include Puerto Rico, the Virgin 

Islands, Guam, the Northern Mariana Islands, and American Samoa.
Page 11 GAO-14-592 Coastal Zone Management

a

By operation of Alaska State law, the federally approved Alaska Coastal Management Program 

expired on July 1, 2011, resulting in the state's withdrawal from participation in the CZMP. See 76 

Fed. Reg. 39857 (July 7, 2011). Alaska participated in the program from 1979 through July 2011.

NOAA’s Office of Ocean and Coastal Resource Management (OCRM) is 

responsible for general administration and oversight of the CZMP. NOAA 

plans to merge the OCRM with its Coastal Services Center—an office 

that provides coastal-related mapping tools and data; training on various 

coastal management issues such as climate adaptation and coastal 

restoration design and evaluation; and technical and other assistance to 

local, state, and regional coastal organizations—into a single office by the 

end of 2014. Under the current and planned office structure, NOAA 

officials are responsible for approving state programs and any program 

changes, administering federal funding to the states, providing technical 

assistance to states such as on the development of 5-year assessment 

and strategy reports that identify states’ priority needs and projects to 

address one or more of nine enhancement objectives required for 

enhancement funding, among other topics, and managing the CZMP 

performance measurement system. NOAA assigns coastal management 

specialists to work with individual state programs. As part of its 

administration of the program, NOAA evaluates program performance 

using its CZMP performance measurement system. NOAA began 

developing a framework for this performance measurement system in 

2001, started piloting it in 2004, and fully implemented the system by 

2008. The system consists of 15 performance measures that generally 

correspond with the goals of the act, and two additional measures to track 

state financial expenditures. The 17 total performance measures 

incorporate individual data elements, plus additional subcategories of 

information that state programs collect and report into the system 

annually (see app. II). 

In addition, NOAA evaluators, who are in a different NOAA division than 

specialists, are responsible for conducting individual state program 

evaluations, which are required under the act. State program evaluations 

are designed to examine the extent to which states have: (1) 

implemented their approved programs,(2) addressed coastal 

management needs identified in the act, and (3) adhered to the terms of 

CZMP funds awarded through cooperative agreements. NOAA’s state 

program evaluation reports identify state accomplishments and make 

recommendations for improving states’ programs. NOAA’s 

recommendations are classified as either necessary actions—actions a 

state must take by a specific date such as the next regularly scheduled 

evaluation—or program suggestions—actions it believes a state should 
Page 12 GAO-14-592 Coastal Zone Management

take to improve its program. NOAA may withdraw approval for a state’s 

program and financial assistance in cases where states do not address 

necessary actions. NOAA has not withdrawn approval for a state program 

as of the end of fiscal year 2013 and, according to NOAA officials, few 

necessary actions have been identified in past state evaluations. 

In 2008, we examined NOAA’s process for awarding financial assistance 

to states and how the agency evaluated the effectiveness of the CZMP. 

Of the seven recommendations we made in 2008, NOAA disagreed with 

one recommendation that the agency develop performance measures to 

evaluate the effectiveness of state programs in improving processes; 

NOAA agreed with the other six recommendations and has taken some 

actions to address them as described in table 3.

Table 3: National Oceanic and Atmospheric Administration Actions to Address Recommendations for the National Coastal 

Zone Management Program (CZMP) Made by GAO in 2008

Area for 

improvement

Recommendation Actions taken Status

Process for awarding 

federal funding

Review and revise, as needed, 

NOAA’s regulations and funding 

award practices to ensure that 

they are in alignment

Fiscal year 2011 – NOAA adjusted its formula for distributing 

federal funding to states in accordance with its regulations.

Fiscal year 2012 – NOAA began competitively awarding funding 

to selected projects through its Projects of Special Merit Program, 

whereby states submit applications for innovative projects that 

further enhance strategies related to select national enhancement 

priority areas identified by NOAA.

●

CZMP performance 

measurement system

Develop appropriate internal 

controls for verifying that the data 

received for the performance 

measurement system are reliable 

and consistent across 

participating states 

April 2010 – NOAA updated its national performance 

measurement system guidance for states that included 

documentation requirements for state submitted data. 

July 2010 – NOAA issued guidance to NOAA specialists on data 

review steps and initiated a formal review and approval process 

for state submitted data. 

●

Develop performance measures 

to assess state programs' 

effectiveness in improving 

processes

No action taken.a ○

Create targets for existing 

performance measures to assess 

the effectiveness of the national 

program

Fiscal year 2011 - NOAA identified targets for several of the

CZMP performance measures that NOAA and Commerce use to 

track progress on NOAA-specific and Commerce-wide goals 

related to environmental stewardship.b

◒
Page 13 GAO-14-592 Coastal Zone Management

Area for 

improvement

Recommendation Actions taken Status

Evaluations of state 

coastal management 

programs

Ensure that state evaluations are 

independent by revising the role of 

state program officials in the 

review process

June 2009 – NOAA began to reserve time during stakeholder 

interviews, conducted as part of the state program evaluations, 

for discussion without the presence of state program officials. In 

the past state program officials fully participated in stakeholder 

interviews which we found potentially hindered open discussion 

about the state program.

●

Establish performance goals so 

that evaluators have criteria for 

evaluating state coastal programs

Fiscal year 2011- NOAA required state programs to develop and 

track annual progress on three state evaluation metrics with state 

established targets.

●

Integration of 

performance 

assessment tools

Develop an approach to integrate 

the qualitative data from its 

periodic state program evaluations 

with the quantitative data in its 

performance measurement 

system

January 2013 - NOAA issued fact sheets to communicate the 

accomplishments of the CZMP using 2008 to 2011 national 

performance measurement system data and success stories 

reported by state programs, based on recommendations of a 

performance measurement system workgroup they assembled. 

◒

Legend: 

● = Recommendation closed - implemented 

◒ = Recommendation open - steps taken 

○ = Recommendation closed - not implemented

Source: GAO analysis of National Oceanic and Atmospheric Administration information. | GAO-14-592

a

NOAA disagreed with this recommendation, explaining that, after considering several process 

measures, it chose to include one measure related to the federal consistency process to demonstrate 

national program effectiveness in improving decision making. NOAA stated that additional process 

measures would increase implementation costs and diminish the focus on program outcomes. We 

believed the single federal consistency process measure did not adequately assess other key 

aspects of states’ effectiveness in coordinating and expediting government decision making. 

b

Annual targets for one CZMP measure related to acres of coastal habitat protected were established 

and tracked at the NOAA and Commerce-wide levels since fiscal year 2006.

During fiscal years 2008 through 2013, the 34 participating states 

allocated a total of nearly $400 million in CZMP funds for a variety of 

activities, generally related to the broad goals for state programs outlined 

in the Coastal Zone Management Act. Each year, NOAA analyzes its 

cooperative agreements with states for CZMP funding, and categorizes 

the states’ CZMP funding allocations as they correspond with the six 

focus areas based on the broad goals in the act, along with a seventh 

category to capture state program administrative costs, such as general 

program operations, supplies, and rent. According to NOAA’s analysis, 

during fiscal years 2008 through 2013, states’ allocations of CZMP funds 

varied across the seven categories, with about half concentrated in 

support of activities related to two focus areas, government coordination 

and coastal habitat (see fig. 2). 

States Allocated 

Nearly $400 Million in 

CZMP Funds during 

Fiscal Years 2008 

through 2013 for a 

Wide Range of 

Coastal Management 

Activities
Page 14 GAO-14-592 Coastal Zone Management

Figure 2: States’ Coastal Zone Management Program Funding Allocations by Focus Area, Fiscal Years 2008 through 2013

Notes: Percentages do not add to 100 percent due to rounding.

Focus areas and the state program management category are defined by NOAA, and amounts are 

approximate. CZMP funded activities could address more than one focus area. To address this 

challenge, NOAA developed written guidance for NOAA specialists who conduct the analysis that 

specifies the types of activities to include in each focus area and the state program management 

category, and direction on how to categorize funds in cases where a project or activity may fall in 

more than one category.

a

State program management is not a focus area, but rather it is a category used by NOAA to track 

CZMP funding not directly associated with the six focus areas, including state program administrative 

costs, such as general program operations, supplies, and rent.

NOAA officials told us that, while states have the flexibility to design and 

implement programs that best meet their unique needs, the agency does 

influence how states allocate CZMP funds through (1) NOAA’s review 

and approval of states’ 5-year assessment and strategy reports required 

for enhancement funding in which participating states prioritize projects 

that support program improvements and (2) NOAA’s periodic state 

program evaluations in which NOAA outlines necessary actions or makes 

program suggestions that can influence state program activities. NOAA 

officials said that they also informally shape or influence state program 
Page 15 GAO-14-592 Coastal Zone Management

activities through ongoing discussions with state program officials about 

funding proposals or specific projects, such as how projects might be 

adjusted to address NOAA priorities.

Examples of activities for which participating states allocated CZMP funds 

during fiscal years 2008 through 2013 in each of the six focus areas 

include the following:

• Government coordination. States allocated CZMP funds for 

activities including state and regional planning efforts that involve 

coordination among multiple levels of government and stakeholders to 

address complex and controversial coastal issues, such as 

comprehensive planning of ocean and nearshore areas, energy 

facility siting or special area management planning;8 federal 

consistency activities;9 technical assistance to local governments; and 

public outreach and education on coastal issues including website 

development and publications about a state program’s activities. 

According to NOAA’s analysis of cooperative agreements with states 

for CZMP funding, states allocated the largest amount of CZMP 

funding during the 6-year period—about 27 percent of total funding—

to government coordination activities. We found that a number of state 

programs use CZMP funds to support participation in regional 

organizations involving ocean planning activities that entail 

coordination across federal, state, and local governments. For 

example, state program officials in some Northeast and Mid-Atlantic 

states participate in regional organizations, such as the Northeast 

Regional Ocean Council and Mid-Atlantic Regional Council on the 

Ocean, that have ocean resource data collection and planning efforts 

under way. We also found that most states we reviewed provide some 

 8

Special area management plans are one of nine enhancement objectives eligible for 

enhancement funds. The act defines a special area management plan as “a 

comprehensive plan providing for natural resource protection and reasonable coastaldependent economic growth.” States have used such plans to address complex coastal 

issues, such as waterfront revitalization, in discrete geographic areas.

9

Under the federal consistency provision of the Coastal Zone Management Act, federal 

agency activities affecting any land or water use or natural resource of a participating 

state’s defined coastal zone are required to be consistent with enforceable policies of the 

state’s coastal management program to the maximum extent practicable. State federal 

consistency reviews involve states’ assessments of proposed federal actions that include 

federal agency activities, licenses or permits to nonfederal applicants, financial assistance 

to state and local governments, and outer continental shelf activities to ensure consistency 

with state program policies.

Government Coordination for an Ocean 

Planning Project in Virginia 

In fiscal year 2011, Virginia’s state program 

used coastal zone funds to initiate a 5-year 

ocean planning project that aims to balance 

existing and new ocean uses, such as 

offshore energy development, while also 

protecting ocean resources. The project 

involves coordination and outreach on ocean 

management objectives to government 

agencies, nongovernment organizations, and 

public and private stakeholders in eight 

sectors ranging from energy and ports, 

shipping, and navigation industries to 

recreational users and conservation groups. 

Other key components of the project include 

collecting and mapping ocean resource data 

and supporting regional ocean planning efforts 

in the Mid-Atlantic. To collect data on ocean 

uses where gaps were identified, Virginia’s 

state program is using participatory 

geographic information system workshops, a 

tool that allows groups of people to easily 

identify and annotate important areas on a 

projected map that are immediately captured 

in an electronic format. As data are verified, 

Virginia’s state program makes them available 

to the public on its website, and data from 

Mid-Atlantic states will be combined and made 

available for public use on the Mid-Atlantic 

Regional Council on the Ocean’s data portal. 

Virginia’s state program received a total of 

nearly $200,000 in fiscal years 2011 and 2012 

coastal zone funds to complete initial project 

phases. State program officials told us they 

expect the project will lead to increased 

willingness of stakeholders to discuss the 

ocean as a shared resource, and provide 

decision makers with the data needed to make 

informed decisions about ocean management.

Map produced by Virginia ocean stakeholders 

showing offshore locations commonly used for 

small vessel charter fishing.

Source: Virginia Coastal Zone Management Program. | 

GAO-14-592
Page 16 GAO-14-592 Coastal Zone Management

type of technical or financial assistance to local governments to 

support local level coastal management activities and projects. 

• Coastal habitat. States allocated CZMP funds for coastal habitat 

protection and restoration activities including the acquisition or 

placement of easements on coastal lands; restoration of coastal 

habitats; data collection and mapping of coastal habitats; 

development of plans for habitat acquisition, restoration, and other 

habitat management needs; implementation of permitting and 

enforcement programs that protect coastal habitat through planning 

and regulation of development; or support of land management 

programs such as those for coastal preserves and parks. States also 

allocated CZMP funds for public outreach and education activities that 

focused on coastal habitat protection and restoration. According to 

NOAA’s analysis, approximately 24 percent of CZMP funds awarded 

during fiscal years 2008 through 2013 were allocated to coastal 

habitat protection and restoration activities. According to NOAA’s 

CZMP performance measurement system data from 2008 through 

2013, states reported that they used CZMP funds to protect nearly 

23,300 acres of coastal habitat through acquisition or easement, 

restore nearly 37,400 acres of coastal habitat, and through regulatory 

programs protect more than 123,000 net acres of coastal habitat.10 

 10CZMP performance measurement system data reported for a given year do not 

correspond directly with funds awarded to states in each fiscal year but can include 

activities completed using funding awarded for up to 3 fiscal years.

Protecting Coastal Habitat in Texas

The Texas state program used coastal zone 

funds to support a multiyear marsh restoration 

project on the Texas Gulf Coast near Corpus 

Christi. Over the past 60 years, about 340 

acres of coastal marsh habitat were lost due 

to the construction of an adjacent highway and

subsequent erosion. A local nonprofit 

organization began restoring the marsh in 

2005. The project involved scooping sand, 

clay, and shells from the bay bottom and piling 

the material into terraces and mounds; 

planting native grasses on the terraces to 

stabilize the structures and provide habitat; 

and constructing an outer rock berm to protect 

the new marsh area from strong waves in the 

bay, as shown below. 

Project officials told us Texas’s state program 

provided about $1 million in coastal zone 

funding, about 20 percent of the project’s total 

cost, to the nonprofit organization responsible 

for the project. Other funding to carry out the 

project was provided by the EPA, U.S. Fish 

and Wildlife Service, state government 

sources, and grants from private foundations. 

According to project officials, the project was 

completed in spring 2014 and has resulted in 

160 acres of restored marsh that provide 

habitat for fish, crabs, shrimp, nesting birds, 

sea grass, and other plants and animals. The 

project also resulted in the creation of new 

opportunities for public recreation, such as 

fishing and kayaking, and the marsh protects 

the adjacent highway from coastal hazards, 

such as storms, according to project officials.

Earthen terraces and mounds provide 

restored marsh habitat along the Texas Gulf 

Coast.

Source: Lanmon Aerial Photography, Inc. | GAO-14-592
Page 17 GAO-14-592 Coastal Zone Management

• Coastal hazards. States allocated CZMP funds for activities that help 

coastal communities minimize risks from coastal hazards, such as 

storms, tsunamis, and sea-level rise, and improve hazard awareness 

and understanding. Such activities include assessment and planning 

efforts, such as developing mitigation plans, risk and vulnerability 

assessments, and data collection and mapping to identify and 

manage development in areas vulnerable to coastal hazards; 

implementation of hazard mitigation projects; implementation and 

enforcement of hazard policies, regulations, and requirements; and 

education and training on coastal hazard topics. According to NOAA’s 

analysis of cooperative agreements with states for CZMP funding, 

about 13 percent of CZMP funds awarded in fiscal years 2008 through 

2013 were allocated for coastal hazards projects. The coastal hazards 

focus area was the one focus area where the share of CZMP funds 

allocated steadily increased over the 6-year period, from roughly 7 

percent in fiscal year 2008 to about 16 percent in fiscal year 2013. 

Most state program officials we spoke with identified their work to help 

communities reduce future damage from hazardous events and 

impacts from sea-level rise related to climate change as among their 

more significant projects. NOAA also identified coastal hazards work 

as a priority area, and in 2011, through the agency’s funding 

guidance, began encouraging states to use CZMP funding for projects 

that improve the resiliency of coastal communities to adapt to the 

impacts of coastal hazards and climate change. In addition, many of 

the projects that were awarded funding under the competitive Projects 

of Special Merit Program in fiscal years 2012 and 2013 were identified 

by states as addressing, at least in part, coastal hazards, according to 

NOAA officials.11 For example, South Carolina’s project to study tidal 

inlet dynamics and erosion and Maine’s adaptation planning project 

for its coastal parks both addressed coastal hazard issues. NOAA’s 

CZMP performance measurement system data for 2008 through 2013

show that states reported working with more than 410 communities to 

reduce risks from coastal hazards and nearly 230 communities to 

improve public awareness of coastal hazards issues. 

 11Under NOAA’s Projects of Special Merit Program, states with 5-year assessment and 

strategy reports may submit applications for specific projects that further enhance area 

strategies related to select national enhancement priority areas identified by NOAA.

Addressing Coastal Hazards in California

According to recent National Research 

Council projections, sea levels along the coast 

of California may rise by as much as 65 

inches by 2100. To help prepare for potentially 

severe effects on the state’s economy, natural 

resources, infrastructure, and human health, 

California’s state program is using coastal 

zone funding to develop sea-level rise policy 

guidance to aid state and local coastal land 

use planning and permitting. The guidance 

includes sea-level rise projections, information 

on adaptation measures, and step-by-step 

directions to help state and local governments 

incorporate sea-level rise in planning and 

regulatory decisions.

In 2011, California’s program received more 

than $300,000 in coastal zone funds to 

develop the guidance that involved 

researching state, national, and international 

efforts to address sea-level rise; developing 

draft guidance for review by state and local 

governments; and holding public hearings to 

obtain stakeholder views on the draft 

guidance. The draft guidance was issued in 

October 2013, and California program officials 

plan to issue final guidance in summer 2014. 

California program officials told us that in the 

long-term they expect the guidance to assist 

local communities in adopting zoning and land 

use ordinances to protect vulnerable areas 

within the coastal zone from sea-level rise. 

A beach access point along the California 

coast that is vulnerable to sea-level rise.

Source: Santa Barbara Channel Keeper. | GAO-14-592
Page 18 GAO-14-592 Coastal Zone Management

• Coastal water quality. States allocated CZMP funds for water quality 

permitting and enforcement activities such as permitting of storm 

water discharges; activities and projects related to water quality 

management including vegetative plantings or other nonstructural 

shoreline erosion control projects; water quality monitoring; activities 

and projects for local governments to improve water quality 

management; technical assistance, data collection, mapping, 

planning, and policy development to address water quality issues; 

marine debris and other coastal cleanup or pollution prevention 

programs; and projects and activities that provide technical assistance 

to marinas to reduce nonpoint source pollution; and public outreach 

and education on water quality issues. Activities include those that 

support states in implementing their coastal nonpoint source pollution 

control programs. According to NOAA’s CZMP performance 

measurement system data, from 2008 through 2013, states reported 

that they worked with more than 680 communities to develop nonpoint 

source pollution management policies and plans, or complete related 

projects, and removed 27 million pounds of marine debris through 

coastal cleanup activities. 

A Coastal Water Quality Monitoring and 

Modeling Project in Florida 

Estuaries—such as Sarasota Bay, that spans

about 56 miles along the southwest Florida 

coast—are important productive ecosystems 

that provide habitat for a diversity of species. 

Nonpoint source pollution carried through 

runoff influences the health of the Sarasota 

Bay, which has limited tidal flushing, no major 

tributary, and receives most of its freshwater 

from rainfall and associated runoff.

Florida’s coastal management program 

provided nearly $150,000 in coastal zone 

funds to support a multiyear water quality 

monitoring and modeling study in Sarasota 

Bay led by the Florida Fish and Wildlife 

Research Institute. The study was designed to 

help determine major factors affecting the 

ecological health of the bay. Specifically, 

coastal zone funding was used for statistical 

modeling to differentiate between the effects 

of polluted runoff into the bay during storm 

events from the effects of natural algal, or 

other natural sources of nutrients, in the bay. 

Florida state program officials told us that 

understanding ecological responses in 

estuaries can facilitate planning to minimize 

potential impacts and help maintain overall 

ecosystem health. Continued water quality 

monitoring and modeling is being completed in 

the bay with other funding sources, according 

to Florida officials. 

An aerial view of Sarasota Bay in southwest 

Florida shows the lagoon system with a series 

of barrier islands to the west.

Source: Florida Coastal Office. | GAO-14-592
Page 19 GAO-14-592 Coastal Zone Management

• Coastal community development. States allocated CZMP funds for 

activities including planning and construction to support the 

redevelopment of urban waterfronts, ports, and harbors; technical 

assistance to local governments related to waterfront redevelopment; 

community planning, land-use planning, green infrastructure planning, 

and other sustainable development efforts; and public outreach and 

education activities specific to coastal community development 

issues. According to CZMP performance measurement system data 

from 2008 through 2013, states reported that they worked with more 

than 580 coastal communities to promote development and growth in 

ways that protect coastal resources and with more than 250 

communities to redevelop ports and waterfronts. 

• Public access. States allocated CZMP funds for activities including 

creating new public access sites through easements or right of ways; 

enhancing existing public access through trails, handicap features, or 

educational signage; developing plans, collecting data, and providing 

technical assistance to local governments on public access planning; 

and conducting public outreach and education activities on public 

access issues. According to NOAA’s analysis, states allocated the 

least amount of CZMP funding (about 6 percent of total CZMP 

funding) for activities that improve public access to the coast. Unlike 

other focus areas, a number of states did not allocate funds for public 

access. According to NOAA officials, some states may not need to 

use CZMP funding to support public access projects, for example, 

because they already have sufficient public access to coastal areas. 

In total, according to CZMP performance measurement system data 

from 2008 through 2013, states reported that with CZMP funds and 

through regulatory programs they helped create nearly 700 new public 

coastal access sites and helped enhance nearly 1,500 existing sites. 

State program officials told us that CZMP funding is important because it 

can help leverage other financial resources and provides sustained, 

multiyear funding for projects. We found that CZMP-funded projects and 

activities often involved partnerships with various entities and used 

multiple sources of funding. According to state program officials, CZMP 

funds were often the catalyst for obtaining additional financial assistance 

or other resources. For example, we visited a $5.2 million, multiyear 

marsh restoration project along the Texas Gulf coast that received nearly 

20 percent of overall project funding through the CZMP and additional 

financial support from eight other federal, state, and private sources. 

Representatives from the nonprofit organization responsible for managing 

the project told us that CZMP funds received during the initial stages 

helped attract other funding partners needed for such a large-scale 

A Coastal Community Development Project 

in Maine

Declining access to the coastline is an 

ongoing challenge for industries that depend 

on it, such as commercial fishing, seafood 

processing, and shipping. Through its Working 

Waterfronts Program, Maine’s state program 

seeks to conserve and enhance working 

waterfronts, or those portions of the coastline 

that support water-dependent industries. 

Spurred in part by a 2007 study showing that 

about 20 miles of working waterfront remained 

on the state’s 5,300 mile coast, Maine began 

using coastal zone funds to support a program 

that purchases covenants that restrict use on 

properties that are important to commercial 

fishing. These covenants allow the landowner 

to retain ownership of a property, but require 

that the owner use it indefinitely for fishingrelated purposes only. 

Specifically, Maine uses coastal zone funding 

to support the salaries of staff members who 

solicit and review proposals from landowners, 

while using state bond funding to purchase 

the covenants. Maine program officials 

reported that the program has successfully 

purchased covenants on 22 working 

waterfront properties, including the mussel 

processing facility pictured below. Maine’s 

Working Waterfronts Program also provides 

financial assistance to local governments to 

undertake shore and harbor planning projects, 

such as planning for waterfront infrastructure 

improvements, and it supports the 

development of a national coalition to share 

best practices for waterfront protection.

A covenant on this mussel processing facility 

will ensure the property is used indefinitely for 

fishing-related purposes only.

Source: Maine Department of Marine Resources. | 

GAO-14-592
Page 20 GAO-14-592 Coastal Zone Management

restoration project. Similarly, Virginia’s program used $6,000 of its CZMP 

funding to leverage staff from six partner organizations to plan and 

conduct a Marine Debris Summit that laid the groundwork for developing 

a marine debris plan and establish priorities for future work, which state 

program officials expect will serve as a model for other Mid-Atlantic 

states. Most of the state programs we reviewed also provide competitive 

grants or offer other assistance to leverage local resources to address 

coastal issues. For example, Florida’s program competitively awards a 

portion of its administrative funds annually through grants to coastal 

counties and municipalities for projects that help communities address a 

wide range of coastal issues, and these grants require local entities to 

match the state grants. Similarly, Maine’s program uses CZMP funds 

annually to provide competitive grants to coastal communities for 

planning activities that support harbor management and development or 

improve shoreline access, but actual implementation of the projects must 

be funded through other sources.

NOAA’s two primary performance assessment tools, the CZMP 

performance measurement system and its state program evaluations, 

have limitations, even with changes NOAA has made since 2008, and 

NOAA uses the performance information it collects to a limited extent in 

managing the CZMP. We found that NOAA’s CZMP performance 

measurement system does not align with some key attributes of 

successful performance measures. In addition, in its method for selecting 

stakeholders to survey during state program evaluations, NOAA may be 

susceptible to collecting incomplete and biased information because, in 

part, it uses a single criterion to select stakeholders to survey. 

Furthermore, NOAA makes limited use of the performance information it 

collects—for instance, NOAA does not use data from its performance 

measurement system or its evaluations of state programs to improve 

implementation of the CZMP at the national level—and, as a result, may 

not be realizing the full benefit of collecting such information.

Limitations Exist with 

NOAA’s Performance 

Assessment Tools, 

and NOAA Makes 

Limited Use of 

Performance 

Information 
Page 21 GAO-14-592 Coastal Zone Management

NOAA’s CZMP performance measurement system, which the agency 

developed in response to congressional direction to assess the national 

impact of the CZMP, has limitations, even with changes the agency made 

to the system since our 2008 report. Specifically, NOAA has made 

changes to several aspects of the data collection and review components 

of its system, including the following: 

• establishing a requirement, in 2010, that state programs submit 

documentation of source information to support their data 

submissions, such as documentation of the public access sites being 

reported for public access performance measures;12

• refining, in 2009, 2010, and 2011, the names and definitions of some 

performance measures with the intention of clarifying the activities 

that a given measure is intended to capture;13 and 

• issuing internal guidance, in 2010, for NOAA staff to review statesubmitted data and accompanying documentation to ensure that only 

eligible activities are reported by the states, among other things.14

With these changes, the system aligns with some key attributes of 

successful performance measures. In our past work, we found that 

successful performance measures typically align with key attributes 

including reliability, clarity, balance, numerical targets, and limited 

overlap, among others (see app. III for a complete list of key attributes we 

identified).15 In our current review, we found that some of the changes 

 12This change was in response to our 2008 recommendation that NOAA improve its 

internal controls by verifying state-submitted data.

13For example, for a performance measure on the number of training and coordination 

events offered by a state program, NOAA clarified in its 2010 guidance that coordination 

events reported should be limited to those that are initiated or funded by a state program.

14This change was in response to our 2008 recommendation that NOAA improve its 

internal controls by verifying state-submitted data.

15Other key attributes of successful performance measures we have identified in our past 

work are: linkage, objectivity, core program activities, and government-wide priorities. See 

GAO, Environmental Justice: EPA Needs to Take Additional Actions to Help Ensure 

Effective Implementation, GAO-12-77 (Washington, D.C.: Oct. 6, 2011) and Tax 

Administration: IRS Needs to Further Refine Its Tax Filing Season Performance 

Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). We developed nine attributes 

of performance measures based on previously established GAO criteria. In addition, we 

considered key legislation, such as the Government Performance and Results Act of 1993 

(GPRA) and the IRS Restructuring and Reform Act of 1998, and other performance 

management literature. Our nine attributes may not cover all the attributes of successful 

performance measures, but we believe these are some of the most important.

NOAA’s CZMP 

Performance 

Measurement System 

Does Not Align with Some 

Key Attributes of 

Successful Performance 

Measures
Page 22 GAO-14-592 Coastal Zone Management

NOAA made to its CZMP performance measurement system since 2008 

are consistent with such key attributes. For example, NOAA’s 

requirement that state programs submit documentation of source 

information and its internal guidance for how staff are to review this 

documentation correspond with the key attribute of ensuring the reliability 

of performance measures.16 In addition, NOAA’s steps to refine the 

names and definitions of certain performance measures are 

demonstrative of the key attribute of clarity, meaning that measures are 

clearly stated and have names and definitions consistent with the 

methodology used to calculate them. 

On the other hand, we found limitations in the CZMP performance 

measurement system that did not align with the key attributes. For 

instance, in 2011, NOAA eliminated its coastal water quality focus area—

corresponding to one of the six focus areas based on goals of the CZMP 

outlined in the act. In eliminating this focus area, NOAA removed five 

related performance measures; states continue to report on one measure 

related to coastal water quality, but do so under another focus area on 

coastal community development. Balance, or having a set of measures 

that cover a program’s various goals, is a key attribute of successful 

performance measures. We found that having measures that correspond 

to various program goals provided agencies with a complete picture of 

performance.17 NOAA officials indicated that they eliminated the coastal 

water quality focus area based on a 2011 performance measurement 

system workgroup’s recommendation to streamline the measurement

system.18 They further explained that they took this action because state 

programs were no longer receiving coastal nonpoint program funding, 

which often funded activities in support of coastal water quality, and that 

activities under this focus area were often tied to the coastal community 

development focus area. In speaking with some state program officials, 

however, we found that improving coastal water quality remains a priority 

for their programs even without coastal nonpoint program funding. 

 16A reliable measure is one that is calculated using standard procedures, such that the 

same result would likely be produced if the procedures were applied repeatedly to the 

same situation. 

17GAO-12-77 and GAO-03-143.

18The 2011 workgroup was composed of NOAA and state program officials. It was tasked 

with reviewing and revising the CZMP performance measurement system to more 

effectively communicate program accomplishments. 
Page 23 GAO-14-592 Coastal Zone Management

Similarly, representatives from the Coastal States Organization’s coastal 

water quality workgroup indicated that many state programs have made 

progress in developing and implementing coastal nonpoint pollution 

control programs, but that these results are not quantified by NOAA. 

In addition, NOAA has not established numerical targets for the measures 

in its CZMP performance measurement system for the purpose of 

tracking progress or assessing performance of the CZMP. Our past work 

found that numerical targets are a key attribute of successful performance 

measures because they allow managers to compare planned 

performance with actual results.19 In 2008, we recommended that NOAA 

establish numerical targets for performance measures that would help 

track progress toward meeting program goals and help assess the overall 

CZMP effectiveness. NOAA’s 2011 performance measurement system 

workgroup also recommended that NOAA set targets to help it more 

effectively measure and communicate CZMP performance. NOAA agreed 

with these recommendations, but it has not established numerical targets 

for the measures in its CZMP performance measurement system to 

assess CZMP performance. NOAA officials explained that state programs 

vary widely, making it difficult to set targets at the national level.20 Officials 

also said that they first need to review the performance measures before 

they assess the feasibility of developing numerical targets. NOAA officials 

added that NOAA has set numerical targets for four CZMP performance 

measures, which are included in Commerce’s department-wide goals 

related to environmental stewardship.21 NOAA officials told us that they 

considered historical performance measure data and state programs’ 

planned strategies when establishing these targets, but they do not use 

them to assess CZMP performance. We continue to believe that, without 

 19GAO-12-77 and GAO-03-143.

20We have previously identified strategies to help federal programs overcome challenges 

in setting targets, such as developing targets based on historical performance data, trend 

analyses, planned strategies and program improvements, or multiyear targets, when 

specific annual targets cannot be identified. See: GAO, State Small Business Credit 

Initiative: Opportunities Exist to Enhance Performance Measurement and Evaluation, 

GAO-14-97 (Washington, D.C.: Dec. 18, 2013 and Managing for Results: Strengthening 

Regulatory Agencies’ Performance Management Practices, GAO/GGD-00-10

(Washington, D.C.: Oct. 28, 1999). 

21Data from four CZMP performance measures—one coastal habitat measure, two 

coastal hazards measures, and one coastal community development measure—along 

with data from other NOAA programs are used to support two department-wide 

performance measures established under the GPRA Modernization Act.
Page 24 GAO-14-592 Coastal Zone Management

setting numerical targets for the CZMP performance measurement 

system, NOAA will not have a benchmark to help it determine the extent 

to which the CZMP may be meeting expectations.

Finally, the CZMP performance measurement system includes 

performance measures that involve the collection of data by state 

programs that are already available to NOAA from other sources. Limited 

overlap, another key attribute of successful performance measures, notes 

that measures should produce new information beyond what is provided 

by other data sources and that redundant or unnecessary performance 

information costs resources and clouds the bottom line by making 

managers sort through excess information.22 We found that the CZMP 

performance measurement system includes at least two financial 

measures whereby states collect and submit financial expenditure data 

similar to data states already provide NOAA through their cooperative 

agreements.23 NOAA officials told us that, in developing the CZMP 

performance measurement system, they anticipated that including such 

measures would be useful for tracking the amount of CZMP funding used 

in different focus areas each year. However, NOAA used the financial 

information from its CZMP performance measurement system to prepare 

a one-time summary of performance measure data published in 2013. In 

contrast, it uses financial information drawn from cooperative agreements 

on an annual basis to analyze states’ planned uses of CZMP funding. 

NOAA officials acknowledged that they may need to review the utility of 

requiring state programs to collect financial expenditure data for the 

performance measurement system. By requiring states to collect and 

submit financial data similar to data that they already provide in their 

cooperative agreements and making limited use of these data, NOAA 

 22GAO-12-77 and GAO-03-143.

23The two measures require states to submit 20 individual pieces of financial data into the 

CZMP performance measurement system. One measure requires state programs to 

report the amount of CZMP funds and state matching funds spent in five different focus 

areas, such as public access and coastal habitat. A second measure requires states to 

report on CZMP funds and state matching funds provided to local governments in the form 

of financial and technical assistance by focus area. Because state programs have 3 years 

after funds are awarded to obligate CZMP funds before they must be returned to NOAA, 

data reported annually by states in the CZMP performance measurement system may 

include funds awarded from up to 3 prior fiscal years. Financial information from states’

cooperative agreements, on the other hand, corresponds to states’ planned uses of funds 

in the upcoming fiscal year.
Page 25 GAO-14-592 Coastal Zone Management

may be unnecessarily burdening state programs with data collection 

requirements.

Several state program officials we interviewed told us that collecting data 

for the numerous data elements under the 17 performance measures is a 

time- and resource-intensive activity, with a few stating that this is 

particularly true relative to the amount of CZMP funds they receive. Some 

indicated, for instance, that they spend 30 staff days or more per year 

collecting these data. State officials said that, in particular, data for the 

financial measures are among the most time-consuming to collect and 

report to NOAA. Other state officials told us that collecting data on the 

number of educational and training events and participants for each focus 

area is especially time-consuming, with one official noting that collecting 

data on number of participants is particularly burdensome when events 

are hosted by parties other than the program itself. 

NOAA officials told us they recognized the need to continue to review and 

potentially streamline or revise the CZMP performance measurement 

system, and that they intend to do so once the merger of OCRM and the 

Coastal Services Center is complete, which they expect to occur by the 

end of 2014. In the interim, NOAA officials said they initiated at the 

beginning of fiscal year 2014 an effort to assess all performance 

measures collected by the various programs within the two offices, 

including the CZMP, to determine which measures may be most effective 

in tracking and communicating progress toward goals identified in the 

merged office’s strategic plan. NOAA officials said they are committed to 

developing a strong framework for evaluating the performance of all 

programs under its merged coastal management office. However, the 

agency has not documented the approach it plans to take for these 

efforts. Federal internal control standards state the need for federal 

agencies to establish plans that encompass actions the agency will take 

to help ensure goals and objectives can be met.24 Without a documented 

approach for how it plans to assess its CZMP performance measurement 

system—including the scope and criteria it will use, such as how it will 

ensure its measures align with key attributes of successful performance 

measures—NOAA cannot demonstrate that its intended effort will 

improve its CZMP performance measurement system.

 24GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).
Page 26 GAO-14-592 Coastal Zone Management

In 2013, NOAA revised its process for conducting state program 

evaluations, which are required under the Coastal Zone Management Act 

to assess state programs’ adherence to the act’s requirements, but we 

identified a limitation in NOAA’s method for sampling stakeholders under 

the revised process. According to NOAA documents, the purpose of the 

revisions was to conduct evaluations more efficiently, at a reduced cost, 

while continuing to meet evaluation requirements outlined in the act.25 In 

revising its state program evaluations, NOAA made changes in the timing 

and methods for collecting information from participating states (see table 

4). A NOAA official estimates that the agency’s revised evaluation 

process will save the agency approximately $236,000 annually. NOAA 

began evaluating state programs using its revised process at the 

beginning of fiscal year 2014 with evaluations of seven state programs. 

We did not evaluate NOAA’s implementation of its revised state program 

evaluations because NOAA had not completed its first cycle at the time of 

our review and, therefore, it was too early to assess the effectiveness of 

its revisions. However, we did assess NOAA’s revised evaluation design 

against our and others’ work on program evaluations to identify standards 

for strong evaluation design.26 We were unable to evaluate the qualitative 

components of its revised evaluation design—including the change in the 

scope of the evaluations from NOAA’s review of all aspects of each state 

program to a review of a few areas determined by NOAA—because the 

results of using these methods cannot be fully assessed until the 

evaluations have been conducted. But, we did evaluate the steps NOAA 

laid out in its guidance on its methods for collecting information and 

identified a limitation in its method for sampling stakeholders to survey. 

 25Under the act, state program evaluations are to examine the extent to which states 

have: (1) implemented their approved programs; (2) addressed coastal management 

needs identified in the act; and (3) adhered to the terms of CZMP funds awarded through 

cooperative agreements. 16 U.S.C. § 1458(a).

26GAO, Designing Evaluations: 2012 Revision, GAO-12-208G (Washington, D.C.: January 

2012) and Office of Management and Budget, Standards and Guidelines for Statistical 

Surveys (Washington, D.C.: September 2006). 

NOAA Cannot Ensure 

That Its Revised Process 

for Surveying 

Stakeholders to Inform 

State Program Evaluations 

Will Produce Complete 

and Unbiased Information 
Page 27 GAO-14-592 Coastal Zone Management

Table 4: Components of the National Oceanic and Atmospheric Administration’s (NOAA) Former and Revised Evaluations of 

State Coastal Management Programs

Evaluation component Former evaluation process Revised evaluation process

Frequency of evaluations Each state program evaluated every 3 years; 

11 evaluations conducted per year

Each state program evaluated every 5 years; 

7 evaluations conducted per year

Scope Evaluations consider all aspects of program 

requirements in equal depth

Evaluations focus on three “target areas,” which 

are recurring or major issues facing a state 

program or innovative or high impact projects 

being undertaken; other program requirements 

are also considered

Timing of information collection NOAA collects information from state 

programs immediately before and during the 

site visit

NOAA collects documents and answers from 

state programs on a standard set of questions 

early in the evaluation process to help determine 

evaluation target areas and inform other aspects 

of the evaluation

Methods for information collection In-person site visits and interviews conducted 

for each evaluation

Stakeholders provide information during site 

visit meetings

In-person site visits conducted for up to two 

evaluations per year

Stakeholders provide information through 

surveys and interviews, either by 

telephone/video-conference for evaluations 

without site visits, or in-person for evaluations 

with site visits

Use of quantitative data No state-specific quantitative performance 

measures included in evaluations

NOAA reviews progress toward three statespecific performance measures and numerical 

targets as part of evaluationsa

Findings document 30 to over 50 pages in length 5 to 10 pages in length

Source: GAO analysis of NOAA information. | GAO-14-592

a

NOAA required each state program to develop three state-specific performance measures and 

targets to address a recommendation from our 2008 report that NOAA establish performance goals to 

evaluate state programs. Evaluation target areas and targets associated with state-specific 

performance measures have no relationship to one another. NOAA’s guidance says that it is 

coincidental that it chose to use the term “target area” within the evaluation context and the term 

“target” as one component of an evaluation performance measure.

Under its revised evaluation process, NOAA relies in part on information 

obtained through stakeholder surveys, but we found that through its 

method of sampling stakeholders to survey, the agency may be 

susceptible to collecting incomplete and biased information. According to 

NOAA guidance on its revised evaluations, stakeholder surveys are 

intended to provide information about stakeholders’ perspectives and 

opinions across a range of topics, from a state program’s top three 

strengths and weaknesses to opportunities for improving a program’s 

federal consistency and permitting processes. The guidance states that 

NOAA will use stakeholder survey responses to identify evaluation target 

areas, as well as obtain information about the extent to which a state 
Page 28 GAO-14-592 Coastal Zone Management

program is performing effectively in areas outside of the target areas. 

NOAA officials indicated that they plan to analyze survey results by 

collating respondents’ answers to identify common themes. NOAA 

evaluators will identify a sample of stakeholders to survey from 12 

categories of organizations that stakeholders represent, including federal 

agencies, state agencies, nonprofit organizations, academic institutions, 

and local businesses and industries. According to NOAA officials, they 

adopted the criterion of stakeholder categories to ensure that 

stakeholders whose views were not consistently represented in the 

former evaluations—such as those from local businesses and 

industries—are included in evaluations conducted under the revised 

process. NOAA evaluators will select stakeholders to survey from these 

12 categories from a list of potential stakeholders to survey compiled by 

state program officials and NOAA specialists working with the state. 

According to the Office of Management and Budget’s Standards and 

Guidelines for Statistical Surveys, a survey sampling method should yield 

the data required to meet the objectives of the survey.27 Our previous 

work has found that strong program evaluations rely on data that 

sufficiently reflect the activities and conditions a program is expected to 

address.28 Because NOAA’s stakeholder sampling method is guided by 

one criterion—categories of stakeholder organizations—NOAA may not 

collect information that reflects the various activities and aspects of the 

state programs. Specifically, under the act, NOAA is required to evaluate 

the extent to which state programs have addressed coastal management 

needs reflecting the six focus areas based on the goals identified in the 

act. In the absence of additional criteria for selecting stakeholders to 

survey, NOAA may select a sample of stakeholders whose work with a 

state program does not span all of the act’s goals, potentially leaving 

NOAA without information to inform its evaluation of a state’s 

performance on one or more goals. Such an information gap could be 

significant because stakeholder surveys are intended to be a main source 

of information on how well a program is performing in areas beyond those 

identified as target areas. 

 27Office of Management and Budget, Standards and Guidelines for Statistical Surveys 

(Washington, D.C.: September 2006). 

28GAO-12-208G. 
Page 29 GAO-14-592 Coastal Zone Management

Furthermore, when using a nonprobabilistic sampling method, such as 

that being employed by NOAA for its stakeholder surveys, the Office of 

Management and Budget’s survey guidelines state that agencies should 

demonstrate that they used an impartial, objective method to include or 

exclude people or organizations from a sample. Our previous work on 

program evaluation also found that evaluation data should be sufficiently 

free of bias or other errors that could lead to inaccurate conclusions.

29

Because state program officials responsible for identifying potential 

stakeholders to survey have a vested interest in their programs, NOAA’s 

process is susceptible to collecting biased information. NOAA specialists 

who work with state programs also contribute to the selection process. 

However, we found that some NOAA specialists are not regionally located 

or have worked with a state program for a short period of time and, 

therefore, their knowledge or experience to inform the selection process 

may be limited. NOAA’s evaluation guidance recognizes the need to 

assess its revised process in the future and states that the agency plans 

to evaluate the effectiveness and efficiency of its revised state program 

evaluation process after conducting 8 to 10 evaluations.

We found that in managing the CZMP, NOAA makes limited use of the 

performance information it collects. Our past work has found that 

performance information can be used across a range of management 

functions to improve programs and results, including to (1) identify 

problems or weaknesses in programs and take corrective actions, (2) set 

program priorities and develop strategies, (3) recognize and reward 

organizations who meet or exceed expectations, and (4) identify and 

share effective approaches to program implementation.30 For example, 

our previous work found that the Department of Labor effectively used 

performance measure data to identify technical assistance needs of state 

programs and to then provide assistance to try to improve performance. 

The department also used performance measure data as a basis for 

providing financial incentives to state programs that receive federal 

grants. We found that agencies realize the full benefit of collecting 

 29GAO-12-208G. 

30GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005) and 

Managing for Results: Executive Branch Should More Fully Implement the GPRA 

Modernization Act to Address Pressing Governance Challenges, GAO-13-518

(Washington, D.C.: June 26, 2013).

NOAA Makes Limited Use 

of Performance Data It 

Collects in Managing the 

CZMP
Page 30 GAO-14-592 Coastal Zone Management

performance information only when they use such information to make 

decisions designed to improve results. 

NOAA collects performance information through its CZMP performance 

measurement system, state program evaluations, and other sources, but 

we found that the agency generally does not use the information it 

collects to help manage the CZMP at a national level. Specifically, we 

found the following:

• NOAA uses its CZMP performance measurement system data to 

report on national program accomplishments on a limited basis. In 

particular, in 2013, NOAA produced one report summarizing 

performance measurement system data from 2008 through 2011.31

However, NOAA has not published additional similar reports, and has 

not used performance measurement system data for other purposes. 

For example, the agency has not used the performance measurement 

system data to identify potential problems or weaknesses in the 

CZMP, set program priorities or strategies, or recognize and reward 

high-performing state programs—which may limit the usefulness of 

collecting such data. 

• NOAA does not use its state program evaluations to assess the 

performance or improve the implementation of the CZMP at the 

national level. NOAA uses its state program evaluations to identify 

state-specific accomplishments and encourage or require the state 

under evaluation to make improvements or take corrective actions. 

But, according to NOAA officials, the agency does not regularly 

analyze findings from individual state evaluations to identify and share 

effective approaches across states or to identify common 

performance weaknesses that may warrant national focus or

assistance.32 Our analysis of recent NOAA evaluations of the seven 

state programs we reviewed found that NOAA recommended the 

states undertake similar actions. In five of the seven state program 

 31The report provides examples of results achieved by the CZMP, such as creation of 470 

new public access sites in support of the CZMP goal to create and enhance public access 

to coastal areas, and protection of 14,500 acres of coastal habitat between 2008 and 

2011, in support of the CZMP goal to protect coastal habitat through acquisition or 

easement. 

32In 2007, NOAA produced a summary of findings from state program evaluation reports 

that were issued in fiscal year 2006. NOAA officials said they no longer have the capacity 

to prepare such a summary due to limited staffing and other resource constraints. 
Page 31 GAO-14-592 Coastal Zone Management

evaluations, for example, NOAA recommended that programs 

undertake strategic planning, and for four of the seven programs, 

NOAA recommended that programs improve their coordination with 

local governments or other partners who help carry out coastal 

management activities. Yet NOAA has not analyzed these evaluations 

to identify common findings. One NOAA specialist we spoke with 

suggested that NOAA could also use the results of its state program 

evaluations to recognize and reward high-performing state programs. 

For instance, the NOAA specialist suggested that NOAA could modify 

its eligibility requirements for its Projects of Special Merit funding such 

that only high-performing programs, with any necessary actions from 

past state program evaluations fully implemented, would be eligible to 

receive funding. 

• NOAA does not use performance-related information from other 

sources to support its management of the CZMP. NOAA uses state 

programs’ semiannual progress reports—which contain, among other 

things, “success stories,” or examples of a state program successfully 

addressing coastal management issues33—to track states’ progress in 

implementing their cooperative agreements. However, NOAA does 

not use information from these reports to identify and promote 

effective approaches to coastal management by regularly sharing 

states’ success stories across states or with other stakeholders. The 

2011 performance measurement system workgroup composed of 

NOAA and state program officials recommended that NOAA develop 

a website to share success stories on an annual basis. NOAA did not 

implement this recommendation because, according to NOAA 

officials, at that time it was incorporating success stories into a 

quarterly newsletter. According to a NOAA document, the agency 

produced the newsletter in response to requests from states for more 

information about how other state programs address coastal 

management issues. NOAA stopped issuing this newsletter in 2012, 

when its office merger began, and NOAA officials said they are now 

evaluating how the merged office might best share information about 

the CZMP across state programs and with other stakeholders.

NOAA’s strategic plan for its merged coastal management office 

recognizes the importance of using and reporting performance 

 33For example, according to an example from NOAA, a success story from Virginia’s 

program describes how the program’s coordination and research efforts helped facilitate 

the passage of state legislation protecting dunes and beaches. 
Page 32 GAO-14-592 Coastal Zone Management

information. According to this plan, NOAA is committed to maintaining a 

culture of monitoring and evaluation to improve the implementation of its 

programs. We found, however, that the strategic plan does not include a 

documented strategy for using the performance data NOAA collects 

through its CZMP performance measurement system, state program 

evaluations, or other sources of information, such as states’ semiannual 

progress reports, to manage the CZMP. NOAA officials told us that 

because the office merger is under way, they have not formulated a 

strategy for how the merged office will use performance data to inform 

and manage the CZMP, but they recognized the need to do so once the 

merger is complete. Federal control standards state the need for federal 

agencies to document management approaches to ensure goals and 

objectives can be met.34 Without a documented strategy for using the full 

range of performance information it collects, NOAA may not be taking full 

advantage of the performance information that its specialists, evaluators, 

and state program officials spend time and resources collecting, and it 

cannot ensure that it is realizing the full benefit of collecting such 

information, such as identifying common problems in state programs and 

taking corrective actions, setting national program priorities and 

developing strategies, recognizing state programs that exceed 

expectations, or identifying and sharing effective approaches to program 

implementation. 

Finally, NOAA has not taken steps to integrate data from its CZMP 

performance measurement system with information from its state

program evaluations to develop a complete picture of the CZMP’s 

performance, as we recommended in our 2008 report. In 2008, we found 

that NOAA was not integrating quantitative national performance measure 

data with qualitative information from state program evaluations to 

develop a more comprehensive assessment of the CZMP’s performance. 

NOAA agreed with our recommendation to develop an approach for 

integrating the two types of information and, in response, tasked the 2011 

performance measurement system workgroup with developing a method 

for better communicating performance measure data. The workgroup 

recommended a template for communicating program results that 

includes quantitative national performance measure data and qualitative 

success stories from states’ semiannual progress reports. However, 

NOAA has not drawn on this quantitative and qualitative information for 

 34GAO/AIMD-00-21.3.1.
Page 33 GAO-14-592 Coastal Zone Management

purposes other than producing a report in 2013 summarizing performance 

measurement system data. Specifically, NOAA has not integrated 

quantitative and qualitative information to better understand program 

performance, improve its assessment of difficult-to-measure activities, or 

validate its assessments of program progress. We have previously found 

that agencies that used multiple sources of data to assess performance 

had information that covered more aspects of program performance than 

those that relied on a single source.35 We also found that agencies can 

improve their performance assessments by using program evaluation 

information to validate performance measurement system data.36 We 

continue to believe that developing an approach to combine performance 

information from its CZMP performance measurement system and state 

program evaluations could help NOAA obtain a more complete picture of 

CZMP performance.

The CZMP plays an integral role in helping states protect, restore, and 

manage the development of the nation’s coastal resources and habitats. 

In managing the CZMP, NOAA is challenged with the task of assessing 

the performance of the program, composed of partnerships with 34 

individual states, each with unique coastal habitats, and differing laws, 

organizational structures, and funding priorities. NOAA is to be 

commended for its progress in improving its two primary performance 

assessment tools—its CZMP performance measurement system and 

state program evaluations—since we last reviewed the agency’s 

performance assessment processes in 2008. We are encouraged by 

NOAA’s recognition of the importance of using performance information 

to improve the implementation of the CZMP. However, NOAA does not 

use or have a documented strategy for how it will use the performance 

information it collects from its CZMP performance measurement system, 

state program evaluations, or other sources of performance-related 

information, as appropriate, to aid its management of the CZMP. Without 

a documented strategy for using the range of its performance information, 

NOAA cannot ensure that it is collecting the most meaningful information 

and realizing the full benefit of the significant amount of information it and 

 35GAO, Managing for Results: Challenges Agencies Face in Producing Credible 

Performance Information, GAO/GGD-00-52 (Washington, D.C.: Feb. 4, 2000). 

36GAO, Program Evaluation: Studies Helped Agencies Measure or Explain Program 

Performance, GAO/GGD-00-204 (Washington, D.C.: Sept. 29, 2000). 

Conclusions
Page 34 GAO-14-592 Coastal Zone Management

the states collect, such as identifying common problems in state 

programs and taking corrective actions, setting national program priorities 

and developing strategies, recognizing state programs that exceed 

expectations, or identifying and sharing effective approaches to program 

implementation.

We also are encouraged by NOAA’s intentions to review and possibly 

revise the CZMP performance measurement system once its new coastal 

office is in place, but the agency has yet to document the approach it 

plans to take—including the scope and criteria it will use for this effort. In 

the absence of a documented approach indicating how it will review its 

performance measurement system, NOAA cannot ensure that its 

upcoming effort will take into consideration key attributes of successful 

performance measures, including balance and limited overlap, or result in 

a system that provides meaningful information that can be used by NOAA 

to determine how effectively the CZMP is performing relative to its goals. 

We are further encouraged by NOAA’s commitment to evaluate the 

effectiveness and efficiency of its revised state program evaluation 

process and to modify it, as needed, as it moves forward with its 

implementation. In the interim, however, NOAA’s method for selecting 

stakeholders to survey during state program evaluations—which relies on 

a single criterion and on state program officials who have a vested 

interest in the program—may result in the collection of incomplete or

biased information that does not ensure perspectives are gathered from 

stakeholders representing a variety of program goals and are collected in 

an objective manner, potentially undermining the sufficiency and 

credibility of the data the produces. In the absence of additional criteria 

for selecting stakeholders to survey, NOAA may select a sample of 

stakeholders whose work with a state program does not span the act’s six 

focus areas or who present less-than-objective assessments of a state 

program. 

To ensure that NOAA collects and uses meaningful performance 

information to help manage the CZMP, including continuing to improve its 

CZMP performance measurement system and its state program 

evaluations, we are recommending that the Secretary of Commerce direct 

the Administrator of NOAA to take the following three actions:

• Develop a documented strategy to use the range of performance 

information the agency collects, as appropriate, to aid its management 

of the CZMP, such as to identify potential problems or weaknesses in 

the CZMP; set program priorities or strategies; or recognize and 

Recommendations for 

Executive Action
Page 35 GAO-14-592 Coastal Zone Management

reward high-performing state programs.

• As part of its intended review of the CZMP performance measurement 

system and in consideration of how it intends to use the performance 

information, document the approach it plans to take to analyze and 

revise, as appropriate, the performance measures, and in so doing 

ensure the analysis considers key attributes of successful 

performance measures, such as balance and limited overlap.

• Revise the sampling methodology for selecting stakeholders to 

survey—included as part of its state program evaluation process—to 

ensure perspectives are gathered from stakeholders representing a 

variety of program goals and are collected in an objective manner.

We provided a draft of this report to the Department of Commerce for 

review and comment. In written comments provided by NOAA through 

Commerce (reproduced in appendix IV), NOAA generally agreed with our 

findings and concurred with our recommendations. NOAA also provided 

technical comments that we incorporated, as appropriate. In its comment 

letter, NOAA stated that while it found GAO’s evaluation of the CZMP 

performance measurement system accurate, the agency did not agree 

with GAO’s assessment that eliminating a stand-alone category for 

coastal water quality could negatively affect the system’s ability to reflect 

the goals of the CZMA in a balanced way. NOAA stated that removal of 

the coastal water quality focus area did not impair its ability to track 

progress in meeting the water quality goal of the CZMA, explaining that it 

retained one measure composed of two data elements related to coastal 

water quality, but housed under a different focus area. We agree that the 

two-part measure NOAA maintained related to coastal water quality may 

provide important information on performance in this area. However, we 

continue to believe that the information it is collecting related to coastal 

water quality may not be balanced in comparison to the information it is 

collecting for the other five focus areas, which could in turn result in 

inconsistent performance information when looking across the six focus 

areas of the program. NOAA concurred with the three recommendations 

in the report and described actions it plans to address them. With regard 

to the first recommendation, NOAA stated that it plans to develop a 

strategy for using performance information it collects, including 

information from its performance measurement system, evaluations of 

state programs, performance reports, and other sources, and noted that it 

will build upon existing efforts to share lessons-learned regarding 

successful approaches or shared challenges across the national program. 

In addressing our second recommendation, on documenting its approach 

Agency Comments 

and Our Evaluation
Page 36 GAO-14-592 Coastal Zone Management

for analyzing and revising, as appropriate, the performance measures, 

NOAA stated that it plans to conduct a review of CZMP performance 

measures in fiscal year 2015 as part of its ongoing analysis of 

performance measures for programs under its new coastal office. In 

response to our third recommendation, NOAA stated that it will revise its 

sampling methodology to ensure stakeholders representing a variety of 

program goals are selected.

We are sending copies of this report to the Secretary of Commerce, the 

appropriate congressional committees, and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or fennella@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix V.

Anne-Marie Fennell

Director, Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-14-592 Coastal Zone Management

Focusing on National Coastal Zone Management Program (CZMP) 

activities since our 2008 report, our objectives were to examine (1) how 

participating states allocated CZMP funds awarded in fiscal years 2008 

through 2013 and (2) how the National Oceanic and Atmospheric 

Administration’s (NOAA) primary performance assessment tools have 

changed and the extent to which NOAA uses performance information to 

help manage the CZMP.

To examine how participating states allocated CZMP funds awarded in 

fiscal years 2008 through 2013, we reviewed the Coastal Zone 

Management Act and related regulations and guidance, including NOAA 

funding guidance and allocation memos. We analyzed NOAA data on 

federal funds awarded by state and by funding type from fiscal years 

2008 to 2013, and we compared this data against annual NOAA funding 

guidance and allocation memorandums to states. Based on our analysis, 

and interviews with NOAA officials, we found the data to be sufficiently 

reliable. We reviewed NOAA’s analysis of states’ allocations of CZMP 

funding for fiscal years 2008 through 2013, which was based on NOAA’s 

review of its cooperative agreements for federal funding with states. 

NOAA’s analysis involved the categorization of states’ funding allocations 

for projects into six focus areas based on the goals of the act and an 

additional state program management category as defined by NOAA to 

cover administrative costs, such as general program operations, supplies, 

and rent. NOAA officials noted that total funding allocation amounts are 

approximate and that many CZMP funded activities could address more 

than one focus area. For example, Maine state program officials told us 

their activities to conserve and enhance properties that provide 

commercial fishing access address both coastal community development 

and public access focus areas. To address this challenge, NOAA 

developed written guidance for NOAA specialists who conduct the 

analysis that specifies the types of activities to include in each focus area 

and the state program management category, as well as direction on how 

to categorize funds in cases where a project or activity may fall in more 

than one category. For instance, NOAA defined funds in the government 

coordination focus area to include, among others, activities that involved 

coordination with other government agencies and stakeholders, technical 

assistance to local governments, or public outreach and education 

activities only if they did not correspond to other focus areas. To 

determine the reliability of NOAA’s analysis, we interviewed 

knowledgeable NOAA officials, reviewed NOAA’s process for categorizing 

proposed activities and projects, including its written guidance on 

categorizing CZMP-funded activities and its steps to compare funding 

amounts to ensure that the double-counting of funds did not take place. 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-14-592 Coastal Zone Management

We did not independently verify the results of NOAA’s analysis, but we 

verified major categories used in NOAA’s analysis for consistency across 

years, checked the total allocated funds in NOAA’s analysis against total 

federal funding award data, and reviewed NOAA’s categorization of a 

small sample of projects. We concluded the data to be sufficiently reliable 

for our purposes of reporting states’ allocated uses of CZMP funds. 

We also reviewed data from NOAA’s CZMP performance measurement 

system from 2008 through 2013 (the most recent years for which data 

was available) to further illustrate how CZMP funds were used. To assess 

the reliability of NOAA’s CZMP performance measurement system data, 

we interviewed NOAA officials about reliability of the data and reviewed 

corresponding documentation including performance measures guidance 

to states and internal guidance to NOAA specialists about their required 

reviews of data submitted. We did not independently verify performance 

measure data submitted by state programs, but based on our review of 

steps taken by NOAA to review state-submitted data, we found the data 

sufficiently reliable for the purposes of our report.

To examine how NOAA’s primary performance assessment tools have 

changed since 2008, and the extent to which NOAA uses performance 

information to help manage the CZMP, we analyzed applicable laws and 

guidance including the act, and NOAA’s guidance on its CZMP 

performance measurement system and state program evaluations. We 

reviewed documentation on changes NOAA has made to these two 

performance tools, including steps taken to address our 2008 report 

recommendations,1 and we interviewed NOAA officials about the changes 

they made and their use of performance information. We reviewed GAO’s 

work on performance measurement to identify key attributes associated 

with successful performance measures2 and assessed NOAA’s CZMP 

performance measurement system against these attributes by reviewing 

the agency’s performance measures and guidance on the system and 

interviewing NOAA and state program officials. We also analyzed NOAA’s 

CZMP performance measurement system data from 2011, 2012, and 

2013. We reviewed our and others’ work on program evaluations to 

 1

GAO-08-1045.

2

GAO-12-77 and GAO-03-143.
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-14-592 Coastal Zone Management

identify standards for strong evaluation design3 and assessed NOAA’s 

process for evaluating state coastal programs against these standards by 

examining NOAA’s evaluation guidance and interviewing NOAA officials. 

We examined information NOAA maintains on CZMP performance 

including fact sheets, states’ cooperative agreements, semiannual 

progress reports, performance measurement system data submitted by 

states, and state program evaluation reports. 

In conducting our work on both objectives, we interviewed representatives 

of the Coastal States Organization, a nonprofit organization that 

represents coastal states on legislative and policy issues, as well as state 

program officials from the seven states that received the most fiscal year 

2012 CZMP funding in each of NOAA’s seven regions (California, Florida, 

Hawaii, Maine, Michigan, Texas, and Virginia) about how states used 

CZMP funds and for their perspectives on NOAA’s management and 

assessment of the overall national program. We also reviewed the seven 

states’ cooperative agreements and semiannual progress reports for 

fiscal years 2011 and 2012 (the most recent years for which reports were 

available) to learn about projects undertaken by these seven states. We 

selected one CZMP-funded project in each of the seven states to further 

determine and illustrate how states used funds on a project-level basis 

and to learn about how the results of a select project are captured by 

NOAA’s performance assessment tools. In selecting projects to review, 

we considered the amount of CZMP funds allocated to specific projects, 

funding type, project type (e.g., projects that provide financial and 

technical assistance to local governments, planning projects, 

construction-related projects, permitting activities), and focus area (e.g., 

coastal habitat, government coordination). Our review of the states’ 

information cannot be generalized across all states or projects. We also 

interviewed coastal program officials from American Samoa and the 

Northern Mariana Islands to obtain perspectives from territories on 

NOAA’s performance assessment tools and territories’ use of this 

performance information.

We conducted two site visits to observe and learn more about CZMP 

projects—one to a coastal habitat restoration project in Texas and one to 

an ocean planning project in Virginia. We selected these projects for site 

 3

GAO-12-208G and Office of Management and Budget, Standards and Guidelines for 

Statistical Surveys (Washington, D.C.: September 2006). 
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-14-592 Coastal Zone Management

visits considering project type, focus area addressed, and geographic 

location. During our site visits, we met with state program officials and 

also interviewed stakeholders involved in the selected projects, as well as 

stakeholders involved in other CZMP-funded projects. In Texas, we met 

with the nonprofit organization managing the coastal habitat restoration 

project and toured the restoration site; in Virginia, we visited a public 

access enhancement project that received CZMP funding.

We conducted this performance audit from June 2013 to July 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 41 GAO-14-592 Coastal Zone Management

The National Oceanic and Atmospheric Administration’s (NOAA) CZMP 

performance measurement system is organized by broad focus areas that 

are related to five of the six primary focus areas based on the goals of the 

CZMP as outlined in the Coastal Zone Management Act. The system 

consists of 17 performance measures—15 of the 17 measures are 

organized under the five broad focus areas (NOAA removed the sixth 

focus area, coastal water quality, from its performance measurement 

system in 2011 in response to a performance measurement system 

workgroup’s recommendation to streamline the system), and the 

remaining 2 measures are to track state financial expenditures. Each of 

the 17 measures is composed of several individual data elements. For 

example, the performance measure on federal consistency is composed 

of two data elements that track the number of projects reviewed and the 

number of projects modified under states’ federal consistency review 

processes. In addition, some data elements are further broken down into 

specific categories, such as types of federal consistency projects

modified. See table 5 for a list of the performance measures and 

supporting data elements and categories, as reported by participating 

state programs for 2011 through 2013.

Table 5: Summary of National Coastal Zone Management Program (CZMP) Performance Measurement System Data, 2011 

through 2013a

2011 2012 2013

Focus area: Government Coordination

Performance measure 1: Federal Consistency

Total number of federal consistency projects technically reviewed (determined to be 

applicable for federal consistency review) during the reporting period 6,767 7,014 6,540

Number of federal consistency projects modified due to consultation with the applicant to 

meet coastal zone management policies, by category:

Number of federal agency activity projects 99 138 105

Number of federal license or permit activity projects 629 529 504

Number of outer continental shelf projects 0 0 0 

Number of projects for federal financial assistance to state agencies or local 

governments

19 27 99

Total number: 747 694 708

Performance measure 2: CZMP Regulatory Habitat Protection

Number of acres of habitat estimated to have been lost by permit due to activities subject 

to coastal zone management regulatory programs, by category:

Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 42 GAO-14-592 Coastal Zone Management

2011 2012 2013

Number of acres of tidal (or Great Lakes) wetlands 1,384 417 499 

Number of acres of beach and dune habitat 18 43 50 

Number of acres of nearshore habitat (intertidal, subtidal, submerged) 298 2,858 8,864 

Number of acres of other habitat types 3,413 2,106 3,690

Total number: 5,112 5,423 13,102

Number of acres of habitat estimated to have been gained or mitigated due to activities 

subject to coastal zone management regulatory programs, by category:

Number of acres of tidal (or Great Lake) wetlands 437 917 916 

Number of acres of beach and dune habitat 10 567 671 

Number of acres of nearshore habitat (intertidal, subtidal, submerged) 220 892 160 

Number of acres of other habitat types 76,630 20,359 30,070 

Total number: 77,298 22,736 31,817

Performance measure 3: Coordination Events

Number of coordination events offered by state programs, by category:

Number of government coordination events 587 475 1,236

Number of public access coordination events 51 108 88

Number of coastal habitat coordination events 233 155 247

Number of coastal hazards coordination events 83 99 187

Number of coastal community development coordination events 138 126 161

Total number: 1,092 963 1,919

Number of stakeholder groups participating in coordination events offered by state 

programs, by category:

Number of stakeholder groups participating in government coordination events 2,808 5,578 6,861

Number of stakeholder groups participating in public access coordination events 386 507 439

Number of stakeholder groups participating in coastal habitat coordination events 1,410 962 1,748

Number of stakeholder groups participating in coastal hazards coordination events 773 1,268 1,516

Number of stakeholder groups participating in coastal community development 

coordination events

1,312 2,203 1,627

Total number: 6,689 10,518 12,191

Performance measure 4: Education and Training

Number of educational activities related to government coordination offered by state 

programs

450 148 141

Number of participants in educational activities related to government coordination offered 

by state programs

25,482 10,105 15,531
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 43 GAO-14-592 Coastal Zone Management

2011 2012 2013

Number of training events related to government coordination offered by state programs 118 85 51

Number of participants in training events related to government coordination offered by 

state programs

2,945 1,980 1,113

Focus area: Public Access 

Performance measure 5: 306A Programs

Number of public access sites created through acquisition or easement with assistance 

from CZMP funding or state program staff

15 22 9

Number of existing public access sites enhanced with assistance from CZMP funding or 

state program staff

106 207 122

Performance measure 6: Public Access Regulatory Programs

Number of public access sites created through coastal zone management regulatory 

requirements

128 105 92

Number of public access sites enhanced through coastal zone management regulatory 

requirements

252 218 212

Performance measure 7: Public Access Education and Training

Number of educational activities related to public access offered by state programs 73 51 71

Number of participants in educational activities related to public access offered by state 

programs

16,590 4,655 10,360

Number of training events related to public access offered by state programs 4 36 20

Number of participants in training events related to public access offered by state 

programs

43 443 294

Focus area: Coastal Habitat 

Performance measure 8: Habitat Protected and Restored

Number of acres of coastal habitats protected by acquisition or easement with assistance 

from CZMP funding or state program staff, by category:

Number of acres of tidal or Great Lakes wetlands 1,054 247 216

Number of acres of beach and dune habitat 0 0 0
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 44 GAO-14-592 Coastal Zone Management

2011 2012 2013

Number of acres of nearshore habitat (intertidal, subtidal, submerged) 319 16 217

Number of acres of other types of habitat 1,496 2,841 5,241

Total number: 2,870 3,104 5,673

Number of meters of coastal habitats protected by acquisition or easement with 

assistance from CZMP funding or state program staff, by category:

Number of meters of beach and dune habitat 48 0 0

Number of meters of nearshore habitat (intertidal, subtidal, submerged) 0 0 461,341

Number of meters of other types of habitat 335 2,589,988 1,623,188

Total number: 383 2,589,988 2,084,529

Number of acres of coastal habitats under restoration with assistance from CZMP funding 

or state program staff, by category:

Number of acres of tidal or Great Lakes wetlands 3,169 1,544 5,135

Number of acres of beach and dune habitat 1,100 1,456 261

Number of acres of nearshore habitat (intertidal, subtidal, submerged) 407 68 162

Number of acres of other types of habitat 1,342 292 469

Total number: 6,018 3,359 6,027

Number of meters of coastal habitats under restoration with assistance from CZMP 

funding or state program staff, by category:

Number of meters of beach and dune habitat 21,929 220 5,829

Number of meters of nearshore habitat (intertidal, subtidal, submerged) 0 2,089 1,411

Number of meters of other types of habitat 47,167 2,333 28,534

Total number: 69,096 4,642 35,774

Performance measure 9: Marine Debris Removal

Number of marine debris removal activities completed with assistance from CZMP funding 

or state program staff 3,667 2,444 2,879

Estimated number of pounds of debris removed by the above reported marine debris 

removal activities 5,560,328 7,342,283 5,214,067

Performance measure 10: Education and Training

Number of educational activities related to coastal habitat offered by state programs 1,643 1,636 2,756

Number of participants in educational activities related to coastal habitat offered by state 

programs 110,244 77,059 94,464
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 45 GAO-14-592 Coastal Zone Management

2011 2012 2013

Number of training events related to coastal habitat offered by state programs 95 120 867

Number of participants in training events related to coastal habitat offered by state 

programs 2,435 2,217 3,026

Focus area: Coastal Hazards 

Performance measure 11: Hazard Management

Number of communities that completed a project to reduce future damage from hazards 

with assistance from CZMP funding or state program staff 150 47 68

Number of communities that completed a project to increase public awareness of hazards 

with assistance from CZMP funding or state program staff 25 57 47

Performance measure 12: Education and Training

Number of educational activities related to coastal hazards offered by state programs 180 225 296

Number of participants in educational activities related to coastal hazards offered by state 

programs 9,158 19,320 12,280

Number of training events related to coastal hazards offered by state programs 94 51 65

Number of participants in training events related to coastal hazards offered by state 

programs 2,769 3,147 1,934

Focus area: Coastal Community Development

Performance measure 13: Sustainable Development and Waterfront Redevelopment

Number of coastal communities that developed or updated sustainable development 

ordinances, policies, and plans with assistance from CZMP funding or state program staff 121 75 82

Number of coastal communities that completed a project to implement a sustainable 

development plan with assistance from CZMP funding or state program staff 15 9 17

Number of coastal communities that developed or updated port or waterfront 

redevelopment ordinances, policies, and plans with assistance from CZMP funding or 

state program staff 33 43 55

Number of coastal communities that completed a project to implement a port or waterfront 

redevelopment plan with assistance from CZMP funding or state program staff 7 10 6
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 46 GAO-14-592 Coastal Zone Management

2011 2012 2013

Performance measure 14: Polluted Runoff Management

Number of coastal communities that developed or updated polluted runoff management 

ordinances, policies, and plans with assistance from CZMP funding or state program staff 394 43 29

Number of coastal communities that completed projects to implement polluted runoff 

management plans with assistance from CZMP funding or state program staff 20 14 25

Performance measure 15: Education and Training

Number of educational activities related to coastal community development offered by 

state programs 337 406 258

Number of participants in educational activities related to coastal community development 

offered by state programs 20,316 49,079 304,535

Number of training events related to coastal community development offered by state 

programs 104 69 96

Number of participants in training events related to coastal community development 

offered by state programs 3,118 1,802 2,277

Financial measures

Performance measure 16: CZMP Federal and Matching Dollars Spent and Leveraged

Number of CZMP federal and matching dollars spent, by category:

Number of dollars spent on government coordination $29,329,142 $30,171,489 $33,469,124

Number of dollars spent on public access $10,725,475 $10,041,236 $11,117,341

Number of dollars spent on coastal habitat $16,004,722 $15,564,484 $18,393,891

Number of dollars spent on coastal hazards $9,253,705 $9,744,802 $8,324,826

Number of dollars spent on coastal community development $14,573,592 $13,699,274 $15,408,095

Total number: $79,886,635 $79,221,285 $86,713,278

Number of dollars leveraged by CZMP funds, by category:

Number of dollars leveraged for government coordination $1,844,137 $5,644,764 $2,139,203

Number of dollars leveraged for public access $20,131,692 $6,774,100 $8,409,871

Number of dollars leveraged for coastal habitat $5,711,793 $10,471,749 $9,081,037

Number of dollars leveraged for coastal hazards $3,722,965 $3,676,160 $3,718,439

Number of dollars leveraged for coastal community development $6,268,895 $10,916,677 $4,924,452

Total number: $37,679,482 $37,483,450 $28,273,002
Appendix II: National Coastal Zone 

Management Program (CZMP) Performance 

Measurement System Summary Data

Page 47 GAO-14-592 Coastal Zone Management

2011 2012 2013

Performance measure 17: CZMP Federal and Matching Dollars Provided as Technical and Financial Assistance

Number of CZMP federal and matching dollars spent on technical assistance to local 

governments, by category:

Number of dollars spent on technical assistance for government coordination $5,983,609 $5,204,857 $6,220,180

Number of dollars spent on technical assistance for public access $1,558,676 $1,567,885 $2,145,533

Number of dollars spent on technical assistance for coastal habitat $3,356,390 $1,938,202 $3,165,608

Number of dollars spent on technical assistance for coastal hazards $2,039,983 $1,705,382 $1,651,832

Number of dollars spent on technical assistance for coastal community development $4,459,762 $3,987,681 $3,071,162

Total number: $17,398,420 $14,404,007 $16,254,314

Number of CZMP federal and matching dollars provided as financial assistance to local 

governments, by category:

Number of dollars provided as financial assistance for government coordination $3,197,009 $3,222,016 $4,175,156

Number of dollars provided as financial assistance for public access $6,658,021 $4,265,777 $5,529,215

Number of dollars provided as financial assistance for coastal habitat $3,012,060 $1,708,034 $2,926,198

Number of dollars provided as financial assistance for coastal hazards $1,588,859 $1,109,051 $1,680,944

Number of dollars provided as financial assistance for coastal community 

development $4,455,786 $5,659,039 $6,587,395

Total number: $18,911,735 $15,963,918 $20,898,908

Source: GAO analysis of National Oceanic and Atmospheric Administration data. | GAO-14-592

Notes: 

Focus areas and a financial measures category are highlighted in blue shading, corresponding 

performance measures are noted using dark gray shading, and supporting data elements that 

compose each performance measure are noted using light gray shading.

Measures data that involve acreages or dollar values may not add to the totals as listed due to 

rounding.

If a state program does not complete activities related to a given measure or data element during the 

reporting cycle, then it need not report data for that measure or element, according to a NOAA official. 

We found that the reported data for most measures and data elements do not contain data from all 

state programs. For example, in 2012, 33 states reported data on the total number of federal 

consistency projects reviewed, while 7 states reported data on the number of public access sites 

created through acquisition or easement with assistance from CZMP funding or state program staff. 

CZMP performance measurement system data does not directly correspond to funds awarded to 

states each fiscal year. Because state programs have 3 years after funds are awarded to obligate 

CZMP funds before they must be returned to NOAA, performance measurement system data for a 

given fiscal year may include activities completed using funds awarded from up to 3 prior fiscal years.

a

All state programs are required to report CZMP performance measurement system data to NOAA on 

an annual basis. NOAA officials indicated that states report data to the national performance 

measurement system as activities are completed. Specifically, states report data on a cycle that 

corresponds to the start date of their award (either July 1 or October 1) and reflect completed 

activities for the previous year (July 1 to June 30, or October 1 to September 30). For example, 2011 

data represent activities completed between July 1, 2010 through June 30, 2011, or October 1, 2010 

through September 30, 2011.
Appendix III: Key Attributes of Successful 

Performance Measures Previously Identified 

by GAO

Page 48 GAO-14-592 Coastal Zone Management

Attributes Definition

Potentially adverse consequences of not meeting 

attribute

Linkage Measure is aligned with division and agency-wide 

goals and mission and clearly communicated 

throughout the organization.

Behaviors and incentives created by measures may 

not support achieving division or agency-wide goals or 

mission.

Clarity Measure is clearly stated and the name and definition 

are consistent with the methodology used to calculate 

it.

Data may confuse or mislead users.

Numerical target Measure has a numerical target. Managers may not be able to determine whether 

performance is meeting expectations.

Objectivity Measure is reasonably free from significant bias or 

manipulation.

Performance assessments may be systematically 

over- or understated.

Reliability Measure produces the same result under similar 

conditions.

Reported performance data may be inconsistent and 

add uncertainty.

Core program 

activities

Measures cover the activities that an entity is expected 

to perform to support the intent of the program.

Information available to managers and stakeholders in 

core program areas may be insufficient.

Limited overlap Measure provides new information beyond that 

provided by other data sources.

Manager may have to sort through redundant, costly 

information that does not add value.

Balance Taken together, measures ensure that an 

organization’s various priorities are covered.

Measures may over emphasize some goals and skew 

incentives.

Government-wide 

priorities

Each measure should cover a priority such as quality, 

timeliness, and cost of service.

A program’s overall success is at risk if all priorities are 

not addressed.

Sources: GAO, Environmental Justice: EPA Needs to Take Additional Actions to Help Ensure Effective Implementation, GAO-12-77 (Washington, D.C., Oct. 6, 2011) and Tax Administration: IRS Needs to 

Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). | GAO-14-592

Appendix III: Key Attributes of Successful 

Performance Measures Previously Identified 

by GAO
Appendix IV: Comments from the Department 

of Commerce

Page 49 GAO-14-592 Coastal Zone Management

Appendix IV: Comments from the 

Department of Commerce
Appendix IV: Comments from the Department 

of Commerce

Page 50 GAO-14-592 Coastal Zone Management
Appendix IV: Comments from the Department 

of Commerce

Page 51 GAO-14-592 Coastal Zone Management
Appendix IV: Comments from the Department 

of Commerce

Page 52 GAO-14-592 Coastal Zone Management
Anne-Marie Fennell, (202)512-3841 or fennella@gao.gov

In addition to the individual named above, Alyssa M. Hundrup (Assistant 

Director), Elizabeth Beardsley, Mark A. Braza, Elizabeth Curda, John 

Delicath, Tom James, Katherine Killebrew, Patricia Moye, Dan Royer, 

Kiki Theodoropoulos, and Swati Sheladia Thomas made key contributions 

to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361501)
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