a

GAO

United States General Accounting Office

Report to Congressional Requesters

June 2004 PACIFIC 

GROUNDFISH

Continued Efforts 

Needed to Improve 

Reliability of Stock 

Assessments

GAO-04-606
www.gao.gov/cgi-bin/getrpt?GAO-04-606.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Anu K. Mittal at 

(202) 512-3841 or MittalA@gao.gov. 

Highlights of GAO-04-606, a report to

congressional requesters 

June 2004

PACIFIC GROUNDFISH

Continued Efforts Needed to Improve 

Reliability of Stock Assessments 

The reliability of the NMFS assessments is questionable for the five species 

GAO reviewed, although the assessments were based on the best 

information available at the time they were conducted. According to NMFS 

officials and a National Research Council report, to obtain reliable results 

each stock assessment should include at least one NMFS data source of 

sufficient scope and accuracy because such data are derived from unbiased, 

statistical designs. However, in the yelloweye assessment, no NMFS data 

were used, and in the darkblotched, canary, and bocaccio assessments, the 

NMFS data were limited because the NMFS’ surveys were conducted in 

trawlable waters only. A 2003 NMFS report concluded that darkblotched 

groundfish are less abundant and bocaccio and canary are more abundant in 

untrawlable waters. Also for all five species, NMFS lacks a standard 

approach for ensuring the reliability of non-NMFS data used in stock 

assessments. Some assessors reviewed the quality of non-NMFS data; others 

did not. The assessors who reviewed the quality of the non-NMFS data found 

errors that made some of the data unusable or that could have impaired the 

reliability of certain stock assessments. Finally, for four species, the stock 

assessment reports were questionable because they did not present the 

uncertainty associated with the population estimates. For example, the 

canary stock assessment review panel recommended that standard estimates

of uncertainty be included in the assessment report because without them it 

is difficult to determine their reliability. 

NMFS has taken steps to implement some of the recommendations 

contained in the NMFS stock assessment improvement plan, but much 

remains to be done. NMFS has concentrated its efforts mostly on improving 

data quantity. For example, NMFS increased the frequency of groundfish 

stock assessments and extended the geographic ranges of the shelf and 

slope surveys to cover over 300 more miles along the southern California 

coast. However, because of staffing and funding limitations, NMFS has not 

yet implemented many of the recommendations aimed at obtaining more 

types of data and improving data quality. For example, NMFS has not 

collected enough ecosystem data, and the frequency and range of 

recruitment surveys (estimated production of new members of a fish 

population) are limited. Finally, because of other program priorities, NMFS 

has not implemented the recommendation to create a comprehensive plan 

that combines the improvement plan and its complementary plans. 

NMFS records indicate at least $8.9 million is needed to complete ongoing 

and planned stock assessment improvements—$2.6 million that NMFS’ 

Northwest Fisheries Science Center requested but did not receive in fiscal 

years 2001 to 2003, and $6.3 million requested for fiscal years 2004 and 2005. 

It will cost about (1) $7.7 million to improve the types of data used, such as 

more untrawlable water and recruitment surveys and (2) $1.2 million to 

improve the quality of data used in stock assessments, such as enhanced 

calibration of vessel equipment and standardized trawl survey procedures. 

The actual cost of the remaining improvements may be even higher than the 

$8.9 million estimated because the estimates primarily reflect the amount of 

money that agency officials believed could be realistically obtained, rather 

than what the improvements might cost.

Because of concerns raised about 

the accuracy of National Marine 

Fisheries Service (NMFS) stock 

assessments, GAO reviewed the 

assessments for five species of 

Pacific groundfish: Pacific hake 

and four types of rockfish—

bocaccio, canary, darkblotched, 

and yelloweye. Specifically, for 

these five species GAO (1) 

assessed the reliability of NMFS’ 

stock assessments, (2) identified 

which relevant recommendations 

from NMFS’ stock assessment 

improvement plan have been 

implemented and which have not, 

and (3) identified the costs 

associated with planned and 

ongoing improvements to 

groundfish stock assessments. 

GAO recommends that the 

Secretary of Commerce require the 

Director of NMFS to take actions to 

improve the reliability of stock 

assessments, such as continuing 

efforts to improve the quality and 

types of data used in groundfish 

assessments, establishing a 

standard approach that requires 

that data used in stock assessments 

be evaluated for reliability, and 

requiring stock assessment reports 

clearly present the uncertainties in 

the assessments. 

NOAA generally agreed with the 

report’s accuracy and agreed with 

the report’s recommendations, but 

expressed concern that the report’s 

conclusion could be misconstrued 

to infer that the assessments are 

unreliable for use in managing the 

west coast groundfish fishery. 
Page i GAO-04-606 Pacific Groundfish Assessments

Contents

Letter 1

Results in Brief 3

Background 5

Reliability of NMFS’ Pacific Groundfish Stock Assessments Is 

Questionable 13

Some Recommended Stock Improvements Have Been Implemented, 

but Much Remains to be Done 18

Remaining Improvements Estimated to Cost at Least $8.9 

Million 23

Conclusions 26

Recommendations for Executive Action 27

Agency Comments and Our Evaluation 28

Appendixes

Appendix I: Objectives, Scope, and Methodology 31

Appendix II: Comments From the Department of Commerce 33

GAO Comments 42

Appendix III: GAO Contact and Staff Acknowledgments 47

GAO Contact 47

Staff Acknowledgments 47

Tables Table 1: Stock Assessment Reliability Issues for Five Pacific 

Groundfish Species 14

Table 2: Pacific Groundfish Stock Assessment Improvement Funds 

Requested and Received by Data Type and Quality, Fiscal 

Years 2001-2005 24

Figures Figure 1: Photograph of a Pacific Hake 9

Figure 2: Photograph of a Bocaccio Rockfish 10

Figure 3: Photograph of a Canary Rockfish 11

Figure 4: Photograph of a Darkblotched Rockfish 12

Figure 5: Photograph of a Yelloweye Rockfish 13
Contents

Page ii GAO-04-606 Pacific Groundfish Assessments

Abbreviations

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric Administration

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Page 1 GAO-04-606 Pacific Groundfish Assessments

United States General Accounting Office

Washington, D.C. 20548

A

June 4, 2004 Letr

The Honorable Gordon H. Smith

United States Senate

The Honorable Ron Wyden

United States Senate

Pacific groundfish, 82 species of bottom-dwelling fish, such as several 

species of rockfish and sole, have contributed to the economies of fishing 

communities in California, Oregon, and Washington, generating over $220 

million in income in 2001. However, some populations of Pacific groundfish 

have declined sharply because of natural conditions, such as climate, as 

well as man-made conditions, such as overfishing. In an effort to achieve 

sustainable populations, the National Marine Fisheries Service (NMFS) 

significantly reduced the allowable harvest for nine species of Pacific 

groundfish. NMFS made this decision based on its stock 

assessments—which include estimates of species’ total biomass (weight of 

the total population)—and recommendations from the Pacific Fishery 

Management Council, one of eight councils responsible for managing 

fisheries in federal waters. 

NMFS generally uses internal scientists or contracts with outside experts 

to conduct stock assessments. These assessors use multiple types of data, 

including data from external sources, such as state-collected data on the 

poundage and species of fish brought ashore by commercial and 

recreational fishermen. NMFS’ Northwest Fisheries Science Center 

(Northwest Center), which coordinates Pacific groundfish stock 

assessments, also collects its own data through fish population surveys, 

particularly two key surveys: (1) the shelf and slope bottom trawl survey, in 

which a trawl net is dragged along the ocean floor, and the resulting catch 

is sorted, counted, and biologically examined (e.g., age and sex) and (2) the 

acoustic survey, in which sound waves are used to measure density of 

schools of groundfish in mid-level waters; bottom trawls are not feasible in 

these waters. Fish survey and other data are entered into computerized 

mathematical models (stock assessment models), which estimate the total 

biomass for the fish species being assessed. However, concerns have been 

raised about the accuracy of stock assessments and therefore whether they 

can be relied upon to specify the amount of fish that can be harvested to 

ensure a sustainable population.
Page 2 GAO-04-606 Pacific Groundfish Assessments

In 1999, NMFS commissioned a national task force to review the stock 

assessment process across the agency. Task force members were from 

NMFS headquarters and five of the six NMFS science centers, including the 

Northwest Center. In the October 2001 Marine Fisheries Stock Assessment 

Improvement Plan,1

 the task force identified a lack of adequate data as the 

greatest impediment to producing reliable stock assessments and 

recommended actions to improve the quantity, quality, and types of data 

used in the models that estimate biomass. The task force also identified a 

need to better communicate and quantify uncertainties in these models.

In this context, you requested that we review NMFS’ stock assessments for 

five species of Pacific groundfish: Pacific hake as well as four types of 

rockfish—bocaccio, canary, darkblotched, and yelloweye. Specifically, for 

these five species you asked us to (1) assess the reliability of NMFS’ stock 

assessments, (2) identify which relevant recommendations from the stock 

assessment improvement plan have been implemented and which have not, 

and (3) identify the estimated costs associated with planned and ongoing 

improvements to groundfish stock assessments.

To address these issues, we reviewed key laws and stock assessment 

studies (2002 and 2004 studies for Pacific hake, 2002 and 2003 studies for 

bocaccio, 2002 study for canary, 2000 and 2003 studies for darkblotched, 

and 2001 and 2002 studies for yelloweye), along with the types of fish 

population surveys used and the controls over stock assessment data. We 

spoke with officials from NMFS, the Oregon Department of Fish and 

Wildlife, the Washington Department of Fish and Wildlife, the California 

Department of Fish and Game, the Pacific Fishery Management Council, 

the Pacific States Marine Fisheries Commission, environmental groups, 

and industry associations, as well as fishermen and academics. We also 

reviewed NMFS’ budget documents to develop cost estimates. We did not 

simulate NMFS’ stock assessment models or evaluate the mathematical 

and statistical methodologies used in the models. We conducted our review 

from May 2003 through April 2004 in accordance with generally accepted 

government auditing standards. See appendix I for additional details on our 

scope and methodology.

1

Marine Fisheries Stock Assessment Improvement Plan, U.S. Department of Commerce, 

NOAA Tech. Memo. NMFS-F/SPO-56, 69, 2001. 
Page 3 GAO-04-606 Pacific Groundfish Assessments

Results in Brief For a variety of reasons, the reliability of the NMFS assessments is 

questionable for the five species we reviewed, although the assessments 

were based on the best information available at the time they were 

conducted. First, according to NMFS officials and a 1998 National Research 

Council report, to obtain reliable results, each stock assessment should 

include at least one source of NMFS-collected data of sufficient scope and 

accuracy because such data are derived from unbiased, statistical, and 

scientific designs. However, the four rockfish assessments did not meet 

this standard, although the assessment for Pacific hake did. NMFS did not 

use any of its own data in the yelloweye assessment, and the NMFS data 

used in the bocaccio, canary, and darkblotched assessments were limited 

because NMFS conducted its surveys in trawlable waters only; these fish 

also inhabit both trawlable and untrawlable waters. In the absence of data 

from rocky, untrawlable waters, the assessors estimated overall biomass 

using the NMFS data collected from the trawlable areas. However, in 2003, 

NMFS found that darkblotched are less abundant and bocaccio and canary 

are more abundant in untrawlable waters. As a result, some rockfish 

populations may be overstated, while others may be understated. Second, 

for all the species, NMFS lacks a standard approach for ensuring the 

reliability of non-NMFS data used in the stock assessments. As a result, 

some assessors reviewed the quality of these data while others did not. The 

assessors who reviewed the quality of the non-NMFS data found errors that 

they believed made the data unusable or impaired the reliability of the 

stock assessment. Finally, the reliability of four of the stock assessment 

reports—bocaccio, canary, darkblotched, and yelloweye—is questionable 

because they did not present the uncertainty associated with the 

population estimates. The National Research Council, NMFS, and GAO 

agree that estimates of uncertainty should be included in stock assessment 

reports because without them it is difficult to determine their reliability. 

NMFS has taken steps to implement the NMFS stock assessment 

improvement plan recommendations to improve stock assessments, but 

much remains to be done to enhance their reliability. While the task force 

considered the lack of adequate data—in quantity, quality, and type—as the 

greatest impediment to accurate stock assessments, the Northwest Center 

has concentrated most of its efforts on improving data quantity. For 

example, starting in 2003, the Northwest Center extended the geographic 

ranges of the shelf and slope surveys, expanding them to cover over 300 

additional miles along the southern California coast. It also increased the 

frequency of the groundfish shelf and slope survey from triennially to 

annually and the frequency of the Pacific hake acoustic survey from 
Page 4 GAO-04-606 Pacific Groundfish Assessments

triennially to biennially. However, NMFS has not yet fully implemented 

many of the recommendations aimed at obtaining more types of data and 

improving data quality. For example, although Northwest Center officials 

recognize that recruitment surveys (estimated production of new members 

of a fish population) should be conducted biannually along the entire coast, 

these surveys are currently conducted only annually and only in selected 

regions. While Northwest Center officials also recognize that actions, such 

as calibrating vessel equipment to ensure comparable survey data, are 

needed to improve data quality, these actions have not yet been fully 

implemented. Finally, NMFS has not implemented the recommendation to 

create a comprehensive plan that combines the improvement plan and 

related plans to develop integrated program initiatives. Although NMFS 

officials recognize a need for such a plan, other priorities have precluded 

them from developing it.

According to NMFS funding and budget documents, NMFS needs at least 

$8.9 million to complete ongoing and planned improvements to its stock 

assessments of Pacific groundfish—$2.6 million that the Northwest Center 

had requested but did not receive in fiscal years 2001 through 2003, and 

$6.3 million requested for fiscal years 2004 and 2005. Specifically, according 

to these records, the Northwest Center has the following funding needs:

• $7.7 million to improve the types of data used, including $2.4 million for 

surveys of untrawlable waters, $2.1 million to expand acoustic and 

recruitment surveys, and $3.2 million to collect ecosystem data and

• $1.2 million to improve the quality of data used in stock assessments, 

including $600,000 to enhance the calibration of vessel equipment, 

$525,000 to develop and implement methods to more accurately 

distinguish among groundfish species, and $75,000 to standardize trawl 

survey procedures.

The actual cost of implementing improvements to Pacific groundfish stock 

assessments may be even higher than the $8.9 million estimated because 

the Northwest Center’s budget requests primarily reflect the amount of 

money the Center believed it could realistically obtain, rather than what the 

improvements would cost, according to NMFS officials.
Page 5 GAO-04-606 Pacific Groundfish Assessments

Background The Magnuson-Stevens Fisheries Conservation and Management Act 

granted responsibility for managing marine resources to the Secretary of 

Commerce.2

 The Secretary delegated this responsibility to NMFS, which is 

part of Commerce’s National Oceanic and Atmospheric Administration 

(NOAA). The act also established eight regional fishery management 

councils, each responsible for making recommendations to the Secretary 

of Commerce about managing fisheries in federal waters. The eight fishery 

management councils—consisting of fishing industry participants, state 

and federal fishery managers, and other interested parties—and their areas 

of responsibility include the following: 

• Caribbean Council, covering waters off the U.S. Virgin Islands and the 

Commonwealth of Puerto Rico; 

• Gulf of Mexico Council, covering waters off Texas, Louisiana, 

Mississippi, Alabama, and the west coast of Florida; 

• Mid-Atlantic Council, covering waters off New York, New Jersey, 

Delaware, Maryland, Virginia, and North Carolina; 

• New England Council, covering waters off Maine, New Hampshire, 

Massachusetts, Rhode Island, and Connecticut; 

• North Pacific Council, covering waters off Alaska; 

• Pacific Council, covering waters off California, Oregon, and Washington;

• South Atlantic Council, covering waters off North Carolina, South 

Carolina, Georgia, and the east coast of Florida; and

• Western Pacific Council, covering waters off Hawaii, American Samoa, 

Guam, the Commonwealth of the Northern Mariana Islands, and 

uninhabited U.S. territories in the Western Pacific.

In addition to these eight councils, NMFS has six regional science centers, 

which are responsible for generating the scientific information necessary 

for the conservation, management, and use of each region's marine 

2

Pub. L. No. 94-265, 90 Stat. 331 (codified as amended at 16 U.S.C. §§ 1801-1883).
Page 6 GAO-04-606 Pacific Groundfish Assessments

resources. The six fishery science centers and their areas of responsibility 

are as follows: 

• Alaska Center, covering the coastal oceans off Alaska and parts of the 

west coast of the United States; 

• Northeast Center, covering waters along the Northeast Continental Shelf 

from the Gulf of Maine to Cape Hatteras, North Carolina;

• Northwest Center, covering the northeast Pacific Ocean, primarily 

waters off the coasts of California, Oregon, Washington, and British 

Columbia;3

• Pacific Islands Center, covering the central and western Pacific Ocean; 

• Southwest Center, primarily covering waters off the coast of California 

and areas throughout the Pacific and Antarctic Oceans;4

 and

• Southeast Center, covering waters along the continental southeastern 

United States as well as Puerto Rico and the U.S. Virgin Islands.

The Magnuson-Stevens Act, as amended by the Sustainable Fisheries Act,5

also established national standards for fishery conservation and 

management. These standards deal with preventing overfishing, using 

scientific information, using fishery resources efficiently, minimizing 

bycatch,6

 and minimizing administrative costs. The regional councils use 

these standards to develop appropriate plans for conserving and managing 

fisheries under their jurisdiction, including measures to prevent overfishing 

and to rebuild overfished stocks as well as measures to protect, restore, 

and promote the long-term health and stability of the fishery.

3

In addition, the Northwest Center and the Southwest Center share some responsibilities in 

freshwater rivers and streams in Idaho, Oregon, Montana, and Washington.

4

Ibid.

5

Pub. L. No. 104-297, 110 Stat. 3559 (1996).

6

Under the Magnuson-Stevens Act, “bycatch” means fish that are harvested in a fishery, but 

which are not sold or kept for personal use. Bycatch includes fish discarded for regulatory 

or economic reasons.
Page 7 GAO-04-606 Pacific Groundfish Assessments

In 1982, the Pacific Fishery Management Council (Pacific Council) released 

its initial Fishery Management Plan for groundfish. The Pacific Council’s 

goal is to have long-range plans for managing groundfish fisheries that will 

promote a stable planning environment for the seafood industry, including 

marine recreation interests, and will maintain the health of the resource 

and environment. To help achieve these goals, stock assessments are 

conducted on groundfish species to estimate fish populations. Since 1995, 

the Northwest Center has had lead responsibility for conducting stock 

assessments on Pacific groundfish. The Northwest Center receives 

assistance from other NMFS science centers, such as the Southwest 

Center, which conducted the bocaccio assessment. 

Stock assessments are the biological evaluation of the status of fish stocks. 

Stock assessments provide official estimates in key areas, such as the size 

of the stock population, the size of the spawning population, the amount of 

fish that have died (fish mortality), and the estimated number of fish at a 

particular young age (recruitment). Stock assessments form the scientific 

basis used by regional councils to determine biologically sustainable 

harvests and guide the monitoring and rebuilding of overfished and 

threatened stocks. For example, regional councils use stock assessments 

and other indicators of biological productivity to recommend to NMFS a 

maximum, or total allowable catch, in a particular fishery—typically for a 

year. Stock assessments are a key tool for managing fisheries. Without 

stock assessments, fishery managers would have limited information about 

the status of fisheries in making decisions about setting harvest levels and 

developing plans to rebuild overfished stocks.

For each species, the assessor reviews previous stock assessments, gathers 

available data about the species being assessed, runs the data through 

computer-generated models, and estimates the species’ total biomass. 

Stock assessors use NMFS-collected data, such as stock surveys conducted 

on NOAA vessels or contracted commercial fishing vessels, as well as data 

collected by non-NMFS sources, such as commercial and recreational 

catch data collected by state agencies. The following six key types of data 

are collected: 

• Stock abundance—surveys of how many fish constitute a stock’s total 

size or weight.

• Commercial and recreational fisheries data—the amount and 

composition of fish caught from a particular stock, whether caught 

intentionally by commercial and recreational fishermen or 
Page 8 GAO-04-606 Pacific Groundfish Assessments

unintentionally caught and discarded. Data sources include fishing 

logbooks, dockside samples, and onboard observations, among others.

• Life history—biological data, such as the age and sex composition of 

the stock, age at first maturity, fertility, average lifespan, and natural 

mortality.

• Ecosystem relationships—data on the relationship between a fish stock 

and its physical environment, as well the relationship of a fish stock to 

other species.

• Recruitment research—data on the abundance of juvenile and larval 

fish (fish at their earliest stage), which helps scientists forecast the size 

of a particular stock in the future.

• Synoptic oceanographic sampling—data on the ocean ecosystem, such 

as water temperature or salinity, plankton composition, or ocean 

currents. 

For each stock assessment, a review panel, consisting of NMFS scientists 

and outside experts, independently reviews the methodology of the 

assessment and works with the assessor to ensure their comments are 

adequately addressed.

Through 2003, 24 of the 82 species of Pacific groundfish have had a full 

quantitative stock assessment. Relying on these assessments, NMFS has 

declared that nine species of Pacific groundfish are overfished, including 

the five species of Pacific groundfish we reviewed in this report—Pacific 

hake as well as bocaccio rockfish, canary rockfish, darkblotched rockfish, 

and yelloweye rockfish. Rockfish are long-lived, late-maturing and 

slow-growing species, making them particularly susceptible to overfishing. 

More specifically:
Page 9 GAO-04-606 Pacific Groundfish Assessments

Pacific hake, also called Pacific whiting, is generally found off the west 

coast of North America. It is one of many species of hake distributed in the 

Atlantic and Pacific oceans. Fishing of Pacific hake primarily takes place 

off the coasts of northern California, Oregon, Washington, and British 

Columbia. Fishermen use mid-water trawls and generally fish over the 

ocean bottom at depths of 100 to 500 meters. Pacific hake was declared 

overfished in 2002 because the 2002 stock assessment estimated Pacific 

hake biomass at 700,000 metric tons. By 2004, the biomass was estimated at 

between 2.7 and 4.2 million metric tons, and Pacific hake is no longer 

considered overfished. Figure 1 shows a picture of a Pacific hake.

Figure 1: Photograph of a Pacific Hake

Source: Guy Fleischer, Northwest Fisheries Science Center, NMFS.
Page 10 GAO-04-606 Pacific Groundfish Assessments

Bocaccio rockfish generally inhabit waters off the coast of northern Baja, 

Mexico to Alaska. Bocaccio, commonly sold at market as “red snapper,” are 

commercially fished using trawls, hook-and-line and gillnets. Adult 

bocaccio commonly live over rocky areas or open areas of the ocean’s floor 

to about 320 meters. Bocaccio were formally declared to be “overfished” in 

1999. The 2003 stock assessment estimated the bocaccio biomass at 7,133 

metric tons. Figure 2 shows a picture of a bocaccio rockfish.

Figure 2: Photograph of a Bocaccio Rockfish

Source: Robert Lauth, Alaska Fisheries Science Center, NMFS.
Page 11 GAO-04-606 Pacific Groundfish Assessments

Canary rockfish inhabit the northeastern Pacific Ocean, from northern 

Baja, Mexico to the western Gulf of Alaska. Adult canary rockfish are 

primarily found along the continental shelf, from 46 to 457 meters deep. 

Canary rockfish are harvested commercially using trawl nets and 

hook-and-line and are also considered an important species for 

recreational fishermen. NMFS declared canary rockfish as overfished in 

2000. The 2002 stock assessment estimated the canary rockfish biomass at 

6,197 metric tons. Figure 3 shows a picture of a canary rockfish.

Figure 3: Photograph of a Canary Rockfish

Source: Robert Lauth, Alaska Fisheries Science Center, NMFS.
Page 12 GAO-04-606 Pacific Groundfish Assessments

Darkblotched rockfish are found in the waters from Santa Catalina Island, 

California to the Bering Sea on soft bottom areas at about 29 to 549 meters 

deep. Commercial fishery concentrations are located off the coasts of 

California and Oregon. Darkblotched rockfish are caught primarily by 

commercial trawls and contribute to both commercial and recreational 

fishing. NMFS determined that darkblotched rockfish was overfished in 

2000, when the last full stock assessment was conducted; it was updated in 

2003. This update estimated the darkblotched rockfish biomass at 7,266 

metric tons in 2001.7

 Figure 4 shows a picture of a darkblotched rockfish.

Figure 4: Photograph of a Darkblotched Rockfish

7

The 2003 darkblotched update was not a full stock assessment, but rather updated the 2000 

darkblotched stock assessment by adding some additional data in order to estimate new 

biomass figures. The most recent estimate from this update is for 2001.

Source: Robert Lauth, Alaska Fisheries Science Center, NMFS.
Page 13 GAO-04-606 Pacific Groundfish Assessments

Yelloweye rockfish almost exclusively inhabit rocky areas from northern 

Baja, Mexico to the Aleutian Islands, Alaska. Yelloweye rockfish, found in 

depths ranging from 15 to 550 meters, are caught using both trawl nets and 

line gear and are highly prized by both commercial and recreational 

fishermen. Stock assessments for yelloweye rockfish were first conducted 

in 2001, and NMFS determined that the species was overfished in 2002. The 

2002 stock assessment estimated the yelloweye biomass at 2,325 metric 

tons in 2001.8

 Figure 5 shows a picture of a yelloweye rockfish.

Figure 5: Photograph of a Yelloweye Rockfish

Reliability of NMFS’ 

Pacific Groundfish 

Stock Assessments Is 

Questionable

The reliability of NMFS’ stock assessments is questionable for the Pacific 

hake and four rockfish species we reviewed, although they were based on 

the best information available at the time the assessments were conducted. 

The reliability of the stock assessments we reviewed is questionable 

because (1) four of the assessments did not have at least one 

NMFS-collected data source of sufficient scope and accuracy; (2) NMFS 

lacked a standard process for assessing the reliability of non-NMFS data 

used in all five assessments; and (3) for four of the assessments, the stock 

8

The most recent estimate of biomass for yelloweye from this stock assessment is for 2001.

Source: Robert Lauth, Alaska Fisheries Science Center, NMFS.
Page 14 GAO-04-606 Pacific Groundfish Assessments

assessment reports did not adequately identify the uncertainty of the 

biomass estimates. (See table 1.) To address these limitations, the 

Northwest Center plans to increase the scope and accuracy of its collected 

data, as additional funds become available; is implementing changes that 

will help ensure the reliability of non-NMFS data; and plans to update the 

stock assessment model to provide uncertainty ranges for the 2005 stock 

assessments.

Table 1: Stock Assessment Reliability Issues for Five Pacific Groundfish Species

Source: GAO analysis of information provided by NMFS.

a

NMFS-collected data are available for only the trawlable portion of the species’ habitat. 

Absence of NMFS Survey 

Data Adversely Affects the 

Assessments’ Reliability

Stock assessors use a variety of data, including NMFS data and non-NMFS 

data, in developing their assessments.9

 Two key pieces of NMFS survey 

data are the shelf and slope bottom trawl survey and the acoustic survey. 

Other NMFS data that assessors sometimes use include larval surveys (data 

for fish in their earliest stage) and recruitment surveys. The non-NMFS data 

assessors use include commercial catch data and recreational catch data.

A 2002 National Research Council report found that the inclusion of NMFS 

survey data was the best option for a reliable estimate of abundance 

because such surveys use an unbiased statistical design, control sampling 

locations, and provide for quality assurance.10 According to Northwest 

Species

NMFS-collected 

data available?

Standard data 

reliability testing 

conducted by NMFS?

Uncertainty ranges 

for biomass 

estimates provided?

Pacific hake Yes No Yes

Bocaccio Limiteda No No

Canary Limiteda No No

Darkblotched Limiteda No No

Yelloweye No No No

9

NMFS generally refers to its data as fishery-independent data and to non-NMFS data as 

fishery-dependent data.

10Science and Its Role in the National Marine Fisheries Service, National Research 

Council, National Academy Press, July 2002.
Page 15 GAO-04-606 Pacific Groundfish Assessments

Center officials, to obtain reliable results, each stock assessment should 

include at least one source of NMFS-collected data of sufficient scope and 

accuracy because such surveys are unbiased and scientifically designed. 

Northwest Center officials raised concerns about basing assessments 

solely on non-NMFS data such as commercial and recreational catch data. 

Catch data do not provide the species’ relative or absolute biomass, 

according to NMFS officials. For example, catch data alone is insufficient 

because 

• fishermen are not randomly sampling the ocean but are fishing areas 

that they are allowed to fish and they believe have the most fish; 

• fishing restrictions, such as a total allowable catch, can limit the 

amount of fish being caught; and 

• catch data have often been inaccurate for a variety of reasons, such 

as imprecise accounting for dead fish tossed back into the ocean. 

Although the assessors used several different data sources, four of the five 

assessments did not use NMFS survey data or the NMFS data used covered 

only a portion of the species’ habitats. In the yelloweye assessment, no 

NMFS survey data were available because yelloweye live almost 

exclusively in the rocky habitat that NMFS trawl surveys cannot cover. As a 

result, the yelloweye assessment was based solely on non-NMFS data. 

Similarly, the NMFS survey data used in the bocaccio, canary, and 

darkblotched assessments were limited in scope because the surveys were 

conducted only in trawlable waters. Bocaccio, canary, and darkblotched 

live in both the trawlable and untrawlable habitats. Using data from trawl 

surveys conducted from 1977 through 1998, NMFS reported in 2003 that 77 

percent of the survey area was trawlable and 23 percent was untrawlable.11

Lacking data on species in the 23 percent of the ocean floor that is 

untrawlable, the assessors estimated the overall biomass using the NMFS 

data collected from the trawlable areas. However, the abundance in the 

trawlable area is not representative of the abundance in the untrawlable 

area. The 2003 NMFS report also found that darkblotched groundfish are 

less abundant in untrawlable waters, while canary and bocaccio species 

are more abundant in untrawlable waters. As a result, some rockfish 

11Zimmermann, Calculations of Untrawlable Areas within the Boundaries of a Bottom 

Trawl Survey, NRC Research Press, July 2003.
Page 16 GAO-04-606 Pacific Groundfish Assessments

populations may be understated while others may be overstated. According 

to stock assessors, relying solely on survey data from trawlable waters 

increases the uncertainty of stock assessments. 

In contrast, the fifth groundfish species, Pacific hake, lives primarily in 

mid-water habitat; and so the concerns about the lack of NMFS data in 

rocky, untrawlable habitats are not applicable.

NMFS Lacks a Standard 

Process for Ensuring the 

Reliability of Non-NMFS 

Data Used in the Stock 

Assessments 

NMFS does not have a standard process for evaluating whether the 

non-NMFS data used in its stock assessments are reliable. We believe that 

certain internal control activities, such as a standard process for ensuring 

data reliability, can help ensure that information used to make management 

decisions is complete and accurate.12 Lacking a standard process, some 

assessors reviewed the quality of the raw non-NMFS data, while others did 

not. Assessors who reviewed for data quality found mistakes that they 

believed made some of the data unusable or that could have impaired the 

accuracy of the stock assessments. For example, the assessor for the 2002 

yelloweye stock assessment found numerous errors in the recreational 

catch data, such as attributing the catch from an entire fishing vessel to a 

single fisherman, and thus did not use the data because doing so could have 

resulted in overestimating the biomass. According to another stock 

assessor, commercial catch data frequently have inconsistencies. 

Specifically, the assessor said California, Oregon, and Washington require 

fishermen to enter catch and location information into logbooks, but 

logbooks are often incomplete and inaccurate. While the stock assessment 

review panels evaluated the assessments, the panels did not evaluate the 

quality of the raw data used in the assessments.

According to a Northwest Center official, several assessors have raised 

concerns about data quality and accessibility in feedback meetings. In 

response to these concerns, the Northwest Center official has recently 

begun assigning data stewards to each data set used in its assessments. 

Data stewards are responsible for helping assessors compile relevant data 

and for conducting quality assurance and quality control checks on the 

data. The Northwest Center plans to conduct a data quality workshop in 

July 2004 to formally establish the roles and responsibilities of the data 

stewards, with the intent of standardizing the data evaluation process.

12U.S. General Accounting Office, Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1, (Washington, D.C.: November 1999).
Page 17 GAO-04-606 Pacific Groundfish Assessments

Stock Assessments for Four 

Species Did Not Provide 

Uncertainty Estimates

In 1998, the National Research Council recommended that NMFS include 

realistic measures of uncertainty in its stock assessments.13 NMFS’ 2001 

stock assessment improvement plan also recognized the need to better 

quantify and communicate the uncertainty in assessments. In a review of 

the 2002 canary assessment, the stock assessment review panel 

recommended that standard estimates of uncertainty be included in future 

assessments because it is difficult to determine the reliability of the stock 

assessment without them.14 Similarly, we believe that estimates based on 

samples should have a range of uncertainty to show the amount of 

variability in the estimates.15 However, the bocaccio, canary, darkblotched, 

and yelloweye assessments did not present a measure of uncertainty 

associated with the biomass estimates. 

Without uncertainty ranges, it is difficult for regional councils and NMFS to 

know how much confidence they can have in relying on the estimates for 

determining stock abundance and hence for setting allowable harvests of 

the fish. For example, lacking uncertainty ranges, the 2002 bocaccio stock 

assessment estimated a bocaccio biomass of 2,914 metric tons in 2002. The 

2003 assessment of bocaccio biomass, however, estimated 6,506 metric 

tons in 2002—more than doubling the previous estimate because of 

additional and updated data. With such wide variations, it is important to 

provide uncertainty ranges, otherwise management may make 

inappropriate decisions.

While assessors told us that their stock assessments included some 

information about differences in estimated biomass when using different 

data sources (sensitivity analyses), the mathematical model that NMFS 

uses to estimate biomass (Stock Synthesis model) does not calculate 

uncertainty ranges. NMFS officials told us that NMFS is updating the model 

so that it can compute uncertainty ranges; NMFS expects to use the 

updated model for all 2005 stock assessments. The Pacific hake assessor 

used a mathematical model (AD Model Builder) that could compute 

13Improving Fish Stock Assessments, National Research Council, National Academy Press, 

1998.

14Canary Rockfish STAR Panel Meeting Report, Northwest Fisheries Science Center, May 7, 

2002.

15U.S. General Accounting Office, Quantitative Data Analysis: An Introduction, 

GAO/PEMD-10.1.11, (Washington, D.C.: May 1992).
Page 18 GAO-04-606 Pacific Groundfish Assessments

uncertainty ranges and included these ranges in the Pacific hake 

assessment report.

Some Recommended 

Stock Improvements 

Have Been 

Implemented, but 

Much Remains to be 

Done

NMFS has taken some steps recommended in the Marine Fisheries Stock 

Assessment Improvement Plan to improve the quantity, quality, and type of 

data used in Pacific groundfish stock assessments, but much remains to be 

done to make the assessments more reliable. The Northwest Center has 

concentrated most of its efforts on implementing recommendations aimed 

at obtaining more data. Recommendations aimed at increasing the types of 

data and improving their quality have not yet been fully implemented for a 

variety of reasons, such as staffing and funding limitations. In addition, 

other program priorities have precluded NMFS from implementing the 

recommendation to create a comprehensive plan that incorporates the 

improvement plan and related plans so that it can develop integrated 

program initiatives to improve stock assessments. 

The Northwest Center Has 

Taken Some Steps 

Recommended for 

Improving Stock 

Assessments

The October 2001 stock assessment improvement plan identified three 

scenarios (tiers) to consider when analyzing the resources needed to 

improve stock assessments. The three tiers of assessment improvements 

are as follows: 

• Tier 1—improve stock assessments using existing data without 

initiating new data collection programs.

• Tier 2—conduct baseline monitoring of species, which in most cases 

requires sampling the species at least every 1 to 3 years, and preferably 

at least every 1 to 2 years. 

• Tier 3—implement “next generation” stock assessments by explicitly 

incorporating ecosystem considerations, such as multispecies 

interactions and environmental effects in assessments.

The improvement plan also made a number of recommendations to 

improve stock assessments. The recommendations fall into the following 

four categories:

• Data collection—pursue new initiatives to expand data collection 

efforts that at a minimum bring stock assessment science to Tier 2. In 

addition, continue to develop partnerships and cooperative research 
Page 19 GAO-04-606 Pacific Groundfish Assessments

programs with other entities, such as state agencies, commercial and 

recreational fishing organizations, and individuals to improve the 

quantity, quality, and type of data collected. 

• Communication—educate constituents about NMFS’ strategies for 

improving stock assessments.

• Training—implement comprehensive training and staff development 

programs for NMFS’ analytical and quantitative staff, and augment 

existing programs that support graduate students interested in stock 

assessment science. 

• Planning—develop integrated program initiatives by preparing a 

comprehensive plan that combines the improvement plan with its 

complementary plans.

Improvement in the quantity of data collected for use in stocks 

assessments is a key component to achieving Tier 2 status. The 

improvement plan states that as the quantity of the data increases, the 

assessments become more reliable because the data cover a longer period 

of time, producing better population trend information. Northwest Center 

officials said that the quality of the data improves with more frequent 

surveys and more randomly selected survey locations that, over the long 

term, provide a better understanding of the variability inherent in the 

population distribution and abundance. A better sense of trends and 

variability allow for improved short-term predictions of the status of the 

species. 

The Northwest Center has concentrated most of its efforts on 

implementing improvements in data quantity, such as more frequent 

acoustic, and shelf and slope bottom trawl surveys. The following illustrate 

some of the actions the Northwest Center took in 2003 to improve data 

quantity:16

• Increased the frequency of the Pacific hake acoustic survey from 

triennially to biennially. Beginning in 2003, the survey was restructured 

into a single, integrated survey with Northwest Center and Canadian 

officials jointly planning all survey elements. Officials from the 

16The Southwest Center also took some independent and joint actions with the Northwest 

Center to improve data quantity.
Page 20 GAO-04-606 Pacific Groundfish Assessments

Northwest Center and Canada now jointly conduct all of the acoustic 

surveys.

• Increased the frequency of the groundfish shelf and slope bottom trawl 

survey from triennially to annually, leveraging available resources by 

cooperatively working with the fishing industry. Specifically, contracting 

with private commercial fishing vessels to conduct the surveys. 

According to Northwest Center officials, working collaboratively with 

the fishing industry has afforded fishermen the opportunity to become 

stakeholders in the data collection process.

• Extended the geographic range of the groundfish shelf and slope bottom 

trawl survey. The surveys are now coastwide from Cape Flattery, 

Washington to the Mexican border, adding over 300 more miles along 

the southern California coast. Previous surveys ended at Morro Bay, 

California.

Efforts continue to communicate the strategies needed to improve stock 

assessments and to augment existing programs aimed at developing future 

stock assessment scientists. For example, through the Pacific Fishery 

Management Council, Northwest Center staff meet with their constituents, 

such as representatives from state agencies and the fishing industry, to 

discuss groundfish management issues. In addition, the Northwest Center 

organized a series of public meetings to discuss new initiatives that affect 

the stock assessment program. For example, the Northwest Center held 

public meetings in several communities along the Pacific coast to discuss 

implementation of the Observer Program—a program designed to collect 

information about discarded fish for the non-hake west coast groundfish 

fleets.17

Finally, the Northwest Center now participates in NMFS’ National Sea 

Grant program to augment a Northwest Center-supported graduate study 

program at the University of Washington that trains stock assessment 

scientists. The Sea Grant program provides fellowships for students 

interested in marine research, such as stock assessment methodology and 

marine resource economics. The Northwest Center plans to employ two 

Sea Grant students during the summer of 2004. 

17Pacific hake has a separate observer program. Discards are the amount of fish 

unintentionally caught and not retained on the fishing vessel. Discard information is 

collected for use in assessing the mortality for a number of groundfish species.
Page 21 GAO-04-606 Pacific Groundfish Assessments

Further Actions Are Needed 

to Improve Stock 

Assessments 

While the Northwest Center has implemented some recommendations 

aimed at improving stock assessments, it has not yet fully implemented 

many others. These recommendations include collecting additional types 

of data, such as ecosystem and recruitment information; improving data 

quality, such as calibrating survey vessel equipment; and increasing training 

opportunities for Northwest Center staff. Also, NMFS has not acted on the 

task force recommendation to combine the improvement plan and its 

complimentary plans into a comprehensive plan that provides integrated 

program initiatives. 

According to the improvement plan, additional types of data will allow 

NMFS to further test and validate model assumptions, thereby increasing 

the reliability of the stock assessments. The improvement plan further 

states that information derived from ecosystem research and recruitment 

surveys is essential if assessments are to meet the national standards of 

“next generation” assessments or Tier 3 status. According to Northwest 

Center officials, ecosystem information and coastwide recruitment surveys 

are two of the most critical data sets needed to ensure continuous 

improvement of groundfish stock assessments. The Northwest Center 

conducts ecosystem research as part of its Science for Ecosystem-based 

Management Initiative. Understanding the complex ecological 

relationships between fish and the environment within which they exist 

provides a better understanding of the effects of the ecosystem on the 

groundfish fisheries and the scientific knowledge needed to make informed 

ecosystem-based management decisions. Although research is ongoing to 

develop ecosystem information, only a limited amount of the data is 

collected and used in stock assessments. For example, ecosystem data are 

collected during shelf and slope bottom trawl surveys as time and 

resources allow. However, this information is not widely incorporated into 

stock assessments. For the five species we reviewed, only the boccacio 

assessment used ecosystem data—information on the temperature of the 

ocean’s surface. 

According to Northwest Center officials, the collection of ecosystem data 

is limited because the relatively small size of the commercial vessels used 

in the shelf and slope bottom trawl surveys cannot support the number of 

researchers needed to effectively conduct comprehensive ecosystem 

research and collection activities. Furthermore, the implementation of 

comprehensive ecosystem research and data collection programs is 

contingent upon the funding of a dedicated research vessel for west coast 

surveys. Northwest Center officials said they are to receive a dedicated 
Page 22 GAO-04-606 Pacific Groundfish Assessments

research vessel sometime during calendar years 2008 or 2009, at the 

earliest. 

Better recruitment information for Pacific groundfish is also needed 

because such information provides an early predictor of fish abundance, 

especially for species such as hake, where there is a great variation in 

recruitment. Northwest Center officials said that current recruitment 

surveys are limited because existing funds support only yearly surveys in 

selected areas. To achieve the best early predictions of stock status, these 

officials said, recruitment surveys should be coastwide and conducted 

twice a year. According to Northwest Center officials, 13 full-time staff are 

needed to expand these and other high-priority data collection efforts, such 

as surveys in untrawlable habitat and expanded acoustic surveys.

The lack of quality data was identified in the improvement plan as an 

impediment to producing reliable stock assessments. For example, when 

equipment on different survey vessels are not calibrated, the data are not 

comparable, and trends may not be accurately determined. The Northwest 

Center is continuing its efforts to calibrate survey vessel equipment. 

The improvement plan also recommended that NMFS provide additional 

training to ensure that qualified NMFS staff are available now and in the 

future to conduct stock assessments and related activities. For example, 

the plan recommended the development of a comprehensive training 

program and more professional developmental opportunities for NMFS’ 

scientific staff. Northwest Center officials said they try to meet the training 

and professional development needs of their scientific staff. However, to 

date they have focused on developing external training programs, such as 

the University of Washington graduate program, to develop stock 

assessment scientists for the future and have yet to develop a 

comprehensive training program for in-house stock assessment scientists.

Finally, the improvement plan recommended that NMFS prepare a 

comprehensive plan that combines the improvement plan with other 

complementary plans, such as the NOAA Fisheries Data Acquisition Plan 

and the NMFS Social Sciences Plan. A comprehensive plan would allow 

NMFS to better integrate and coordinate program initiatives for improving 

stock assessments. For example, the acquisition plan—the key 

complementary plan to the improvement plan—identifies the need for 

fishery research vessels to satisfy NMFS’ data collection needs. Although 

the improvement plan includes the number of staff that would participate 

in data collection surveys, it does not contain the capital and operating 
Page 23 GAO-04-606 Pacific Groundfish Assessments

costs of the research vessels. Similarly, the staffing requirements for 

augmenting the social sciences capabilities of NMFS to conduct economic 

analyses is represented in the sciences plan and not in the stock 

improvement plan. A NMFS official said that other program priorities, such 

as conducting more stock assessments and improving data collection 

activities, have precluded them from developing a comprehensive plan. 

Remaining 

Improvements 

Estimated to Cost at 

Least $8.9 Million

According to NMFS funding and budget requests, the Northwest Center 

needs at least $8.9 million to complete ongoing and planned improvements 

to the stock assessments for Pacific groundfish. However, the actual cost of 

implementing remaining improvements to Pacific groundfish stock 

assessments may be even higher because the Northwest Center’s budget 

requests primarily reflect the amount of money the Center believed it could 

realistically obtain, rather than the actual cost of the improvements.

Remaining Improvements 

Are Estimated to Cost at 

Least $8.9 Million, but 

Estimate Is Likely 

Understated

According to NMFS, the Northwest Center needs at least $8.9 million to 

complete ongoing and planned improvements for Pacific groundfish stock 

assessments: $2.6 million that NMFS’ Northwest Center requested but did 

not receive between fiscal years 2001 to 2003 and $6.3 million the Center 

requested for fiscal years 2004 and 2005. Specifically, as shown in table 2, 

the Northwest Center records have identified the following funding needs 

• $7.7 million to improve the types of data used, including $2.4 million for 

surveys of untrawlable waters, $2.1 million to expand acoustic and 

recruitment surveys, and $3.2 million to collect ecosystem data; and

• $1.2 million to improve the quality of data used in stock assessments, 

including $600,000 to enhance the calibration of vessel equipment; 

$525,000 to develop and implement methods to collect information on 

stock identification, structure, and movement; and $75,000 to 

standardize trawl survey procedures.
Page 24 GAO-04-606 Pacific Groundfish Assessments

Table 2: Pacific Groundfish Stock Assessment Improvement Funds Requested and Received by Data Type and Quality, Fiscal 

Years 2001-2005

Dollars in millions

Category Requested Funded

Unfunded 

requests

Types of data used

 Surveys for untrawlable waters

 Nearshore surveys (2003) $1.10 $.50 $.60

 Untrawlable habitat surveysa (2003) .30 .20 .10

 Longline groundfish fishing tag surveysa (2003) .40 0 .40

 Augment trawl survey in nearshore (2004) .51 N/A .51

 Fixed-gear survey (2004) .78 N/A .78

 Subtotal 2.4 

 Expand acoustic and recruitment surveys

 Recruitment surveys (2003) .40 .20 .20

 Acoustic studies of Southern California bight rockfisha (2003) .20 0 .20

 Coastwide augmentation of recruitment survey by Southwest Fisheries 

 Science Center (2004)

.45 N/A .45

 Acoustic surveys in inaccessible habitat (2005) 1.25 N/A 1.25

 Subtotal 2.1

 Ecosystem data

 Coastwide observing system (2003) .80 .60 .20

 West coast observing systema,b (2003) .46 .20 .26

 Habitat-specific resource surveys and fishing gear impacts (2004) 1.45 N/A 1.45

 Ecosystem studies of ocean productivity and climate impacts (2004) 1.28 N/A 1.28

 Subtotal 3.2

Total 7.7

Quality of data used

 Fishing survey vessel calibration (2003) .60 0 .60

 Trawl standardization (2003) .45 .38 .08

 Stock identification, structure, and movement (2004) .53 N/A .53

Total 1.2

Other

 Stock assessment training and coordination (2003) .35 .15 .20

 Stock assessment traininga,b (2003) .30 .50 -.20

 Stock assessment training (2003) .29 .29 0

 Stock assessment training (2002) .29 .29 0

 Stock assessment training (2001) .29 .29 0
Page 25 GAO-04-606 Pacific Groundfish Assessments

Source: GAO analysis of NMFS data.

Notes: These figures exclude the cost of constructing a new fishing research vessel, which is currently 

designated to be home ported at and used primarily by the Northwest Center for surveys of fish 

species, such as Pacific groundfish. This vessel has not yet been funded and construction has not yet 

begun.

The amounts requested by the Northwest Center in fiscal years 2004 and 2005 are preliminary budget 

requests.

a

Includes funding for the Southwest Fisheries Science Center assistance to the Northwest Center’s 

Pacific groundfish stock assessment improvement program.

b

Represents requests and funding for all marine species—not Pacific groundfish alone. NMFS was 

unable to identify what portion of these funds went solely to groundfish.

The Northwest Center did not receive its full funding request, in part, 

because NMFS did not receive all the funding it had requested. Between 

fiscal years 2001 and 2003, NMFS received $20.6 million (80 percent of its 

request) in additional funding to implement improvements for all marine 

stock assessments. NMFS allocated $3.6 million (58 percent of funds the 

Northwest Center requested) to the Northwest Center for improving 

Pacific groundfish stock assessments, resulting in a $2.6 million shortfall in 

the Center’s request. This shortfall occurred in part because of NMFS’ need 

to balance the requests of its six science centers against its program 

priorities and the available funds.18 According to NMFS officials, their goal 

is to achieve parity among the science centers in terms of their capability to 

conduct scientific work, such as stock assessments.

Estimated Costs May 

Understate Actual Cost of 

Remaining Improvements

The $8.9 million needed to implement remaining recommended 

improvements is probably understated because the Northwest Center’s 

budget requests primarily reflect the amount of money the Center officials 

believed they could realistically obtain, rather than the amount the 

improvements would actually cost, according to NMFS officials. The 

Northwest Center’s budget requests for fiscal years 2004 and 2005 are 

preliminary requests submitted before the Northwest Center received its 

Total 0

Total unfunded requests 8.9

(Continued From Previous Page)

Dollars in millions

Category Requested Funded

Unfunded 

requests

18The sixth science center, the Pacific Islands Fisheries Science Center, opened in 2003.
Page 26 GAO-04-606 Pacific Groundfish Assessments

fiscal year 2003 funding.19 Consequently, the Northwest Center will likely 

submit revised budget requests for fiscal years 2004 and 2005 that account 

for both its unfunded needs from fiscal years 2001 through 2003 and items 

that were unexpectedly funded in fiscal year 2003. Moreover, the fiscal year 

2004 and 2005 preliminary budget requests do not incorporate any 

unanticipated problems or data gaps that have developed since the 

Northwest Center submitted its preliminary requests.

According to NMFS officials, NMFS’ science centers, including the 

Northwest Center, primarily make and justify their funding requests in 

response to how much money Congress appropriates. After Congress 

passes NMFS’ budget, NMFS asks its science centers to reassess and detail 

how much new money each needs to implement science center programs, 

such as marine stock assessment improvements. According to NMFS 

officials, it is unrealistic for a science center to request more funds than are 

available in its appropriation, even if it needs more. While NMFS’ 

Northwest Center requested $6.2 million to implement improvements to 

Pacific groundfish stock assessments between fiscal years 2001 and 2003, 

NMFS’ 2001 West Coast Groundfish Research Plan estimated that almost 

twice as much money would be needed—approximately $11.7 million in 

new funding—to implement top-priority improvements to Pacific 

groundfish stock assessments.

NMFS is now updating its plan and cost estimates for improving Pacific 

groundfish stock assessments. Using key findings from its December 2003 

review of the groundfish program, the Northwest Center plans to update its 

groundfish research plan, last published in 2001. According to NMFS, the 

updated groundfish research plan should be completed in late 2004 and is 

designed to (1) provide a comprehensive framework for Pacific groundfish, 

(2) identify some of the greatest information gaps, and (3) provide 

guidance for setting priorities on work to fill these gaps. In addition, the 

updated plan will estimate how much such improvements will cost.

Conclusions Stock assessments are the key to effectively managing fisheries. They 

provide estimates of the species population, which NMFS uses to set 

19In light of the delayed congressional appropriation of fiscal year 2004 funds, NMFS has not 

yet determined the precise amount of money available to its science centers. As a result, as 

of April 2004, NMFS had not yet asked the Northwest Center to update its preliminary 

requests for fiscal year 2004 funds.
Page 27 GAO-04-606 Pacific Groundfish Assessments

harvest limits that allow for sustainability and/or recovery of the species. 

While stock assessment results often change from assessment report to 

assessment report, the more types of information used in the assessments, 

such as recruitment surveys and ecosystem studies, and the greater the 

accuracy and quality of the data, such as scientifically designed and 

collected data, the more reliable the assessment results. However, the 

Pacific groundfish assessments we reviewed did not (1) use scientifically 

designed and collected NMFS data of sufficient scope and accuracy, such 

as survey data on the abundance of groundfish residing in rocky, 

untrawlable habitats; (2) subject the non-NMFS data used to a standard 

process for assessing its reliability; and/or (3) identify the uncertainties of 

the assessments total biomass estimates. As a result, the reliability of the 

five assessments is questionable. Without reliable assessments, fishery 

managers may reach erroneous conclusions and take actions that could 

adversely affect the fishing industry economically or adversely affect the 

recovery and sustainability of the fishery resources. Moreover, without a 

comprehensive, integrated improvement plan, funding requests and 

planned actions to improve the stock assessments may not be coordinated, 

jeopardizing successful and timely implementation of assessment 

improvements.

Recommendations for 

Executive Action

To improve the reliability of Pacific groundfish stock assessments, we 

recommend that the Secretary of Commerce require the Director of 

National Marine Fisheries Service to take the following four actions:

• Continue efforts to collect more types of data, such as data obtained 

from surveys in rocky, untrawlable waters, recruitment surveys, and 

ecosystem studies, for groundfish assessments where reliable data are 

now lacking.

• Establish a standard approach that requires that non-NMFS data used in 

stock assessments be evaluated for its reliability, and continue efforts to 

implement the task force’s recommendations to improve data quality.

• Require that stock assessment reports clearly present the uncertainties 

in the assessments, such as the margin of error associated with species 

biomass estimates.

• Develop a comprehensive plan that integrates the NMFS stock 

assessment improvement plan with other NMFS plans to ensure that 
Page 28 GAO-04-606 Pacific Groundfish Assessments

stock assessment improvement actions and budget requests are 

coordinated.

Agency Comments and 

Our Evaluation

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

review and comment. We received a written response from the Under 

Secretary of Commerce for Oceans and Atmosphere that included 

comments from the National Oceanic and Atmospheric Administration 

(NOAA). NOAA generally agreed with the report’s accuracy and concurred 

with the reports recommendations. However, NOAA said it was concerned 

about the report’s conclusion—that the reliability of stock assessments is 

questionable for the five species reviewed—because it could be 

misconstrued to infer that the assessments are unreliable for use in 

managing the west coast groundfish fishery. In this regard, NOAA provided 

additional comments to show the usefulness of the assessments, even if 

some of the input data used in the assessments contained errors. We stand 

by our conclusions that the five stock assessments we reviewed were 

questionable because the input data were insufficient and/or potentially 

inaccurate and that four of the assessment reports did not present the 

uncertainties associated with the biomass estimates. Nonetheless, we 

added language to the report to address NOAA’s concern. Specifically, we 

expanded upon the fact that NMFS used the best information available at 

the time the stock assessments were conducted by adding information on 

the importance of the assessments to effectively manage the fisheries. 

Without these stock assessments, NMFS and fishery managers would have 

very limited information on which to base fishery management decisions. 

NOAA agreed with the report recommendation to continue collecting more 

types of data for groundfish assessments where reliable data are now 

lacking. NOAA said that the reliability of stock assessments will be 

improved if NMFS survey efforts are expanded and additional NMFS 

fishery data are collected. NOAA said NMFS places a priority on these 

improvements and will continue efforts to address this and other 

recommendations to improve the collection of fishery data as funding 

becomes available.

NOAA also agreed with the report recommendation to establish a standard 

approach to evaluate the reliability of non-NMFS data used in stock 

assessments and continue efforts to improve data quality. NMFS said, 

through its west coast fishery science centers, it participates on 

interagency data committees, to develop quality assurance protocols and to 

assess the quality of non-NMFS data. NOAA agreed that it is important to 
Page 29 GAO-04-606 Pacific Groundfish Assessments

ensure that these interagency data committees continue to highlight the 

need for standardized quality control procedures for the collection of data.

NOAA agreed with the report recommendation to clearly present the 

uncertainties in the stock assessments. NOAA said that quantifying 

uncertainty of stock assessments is important to sound decision-making by 

providing more information about the assessment, although this 

quantification does not reduce the uncertainty in the assessment itself. 

While the methods used and the completeness of the uncertainty 

characterization varied from assessment to assessment, NOAA said it is 

desirable to have both a quantitative analysis of model uncertainty and an 

evaluation of the consequences of alternative model scenario.

Finally, NOAA agreed with the report recommendation to develop a 

comprehensive plan that integrates the stock assessment plan with other 

NMFS plans to ensure that improvement actions and budget initiatives are 

coordinated. NOAA said that while much remains to be done, long-term 

planning efforts and coordination among field and headquarters are 

ongoing, and NOAA is committed to these actions.

NOAA’s comments and our detailed responses are presented in appendix II 

of this report. NOAA also provided technical comments that we 

incorporated in this report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 7 days from the 

report date. At that time, we will send copies of this report to the Secretary 

of Commerce and the Director of the National Marine Fisheries Service. We 

will also provide copies to others upon request. In addition, the report will 

be available at no charge on the GAO Web site at http://www.gao.gov.
Page 30 GAO-04-606 Pacific Groundfish Assessments

If you or your staff have any questions about this report, please call me at 

(202) 512-3841 or Keith Oleson at (415) 904-2218. Key contributions to this 

report are listed in appendix III.

Anu K. Mittal

Director, Natural Resources 

 and Environment
Page 31 GAO-04-606 Pacific Groundfish Assessments

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

We reviewed National Marine Fisheries Service (NMFS) stock assessments 

for five species of Pacific groundfish: Pacific hake (Pacific whiting) as well 

as four types of rockfish—bocaccio, canary, darkblotched, and yelloweye. 

Specifically, for these five species you asked us to (1) assess the reliability 

of NMFS’ stock assessments, (2) identify which relevant recommendations 

from the stock assessment improvement plan have been implemented and 

which have not, and (3) identify the estimated costs associated with 

planned and ongoing improvements to groundfish stock assessments. We 

did not review the stock assessments of any of the other west coast Pacific 

groundfish species, thus the information contained in this report pertains 

to the five species we reviewed unless stated otherwise.

For all three objectives, we reviewed key laws and agency reports and 

interviewed officials from NMFS, including officials from the Northwest 

Fisheries Science Center, which has lead responsibility for conducting 

Pacific groundfish stock assessments with assistance from other west 

coast science centers.

To assess the reliability of the Pacific hake, bocaccio, canary, darkblotched, 

and yelloweye stock assessments, we examined methodological and 

administrative documents developed by NMFS and others to support the 

groundfish data collection, maintenance, and assessment process. We 

reviewed the controls over stock assessment data, the types of fish 

population surveys used, and recent Pacific groundfish stock assessment 

studies (2002 and 2004 studies for Pacific hake, 2002 and 2003 studies for 

bocaccio, 2002 study for canary, 2000 and 2003 studies for darkblotched, 

and 2001 and 2002 studies for yelloweye). We examined whether and to 

what extent NMFS has processes and procedures in place to ensure the 

reliability of data used in the Pacific groundfish stock assessments. We 

reviewed the stock assessment reports and determined whether they 

articulated the level of uncertainty in the assessment model estimates. We 

interviewed an array of government officials and fisheries experts, 

including the Oregon Department of Fish and Wildlife, the Washington 

Department of Fish and Wildlife, the California Department of Fish and 

Game, the Pacific Fishery Management Council, the Pacific States Marine 

Fisheries Commission, environmental groups, and industry associations, as 

well as fishermen and academics. We did not simulate NMFS’ stock 

assessment models nor evaluate the mathematical and statistical 

methodologies used in the models for Pacific hake, bocaccio, canary, 

darkblotched, and yelloweye.
Appendix I

Objectives, Scope, and Methodology

Page 32 GAO-04-606 Pacific Groundfish Assessments

To identify the relevant recommendations to improve stock assessments 

that NMFS has implemented and has not implemented, we reviewed 

agency reports on marine fisheries stock assessments, strategic planning, 

and data collection. We also interviewed officials from the Oregon 

Department of Fish and Wildlife, the Washington Department of Fish and 

Wildlife, the California Department of Fish and Game, the Pacific Fishery 

Management Council, and the Pacific States Marine Fisheries Commission 

as well as environmental groups, industry associations, fishermen, and 

academics. 

To determine the estimated costs associated with NMFS’ planned and 

ongoing improvements to Pacific groundfish stock assessments, we 

reviewed relevant budget requests and funding documents for fiscal years 

2001 through 2005 and interviewed National Oceanic and Atmospheric 

Administration officials. We did not evaluate the accuracy of NMFS’ budget 

requests for specific project items but rather used the amounts NMFS 

requested for these project items to estimate the total additional costs of 

implementing the planned and ongoing improvements to Pacific groundfish 

stock assessments.

We conducted our review from May 2003 through April 2004 in accordance 

with generally accepted government auditing standards.
Page 33 GAO-04-606 Pacific Groundfish Assessments

Appendix II

Comments From the Department of 

Commerce ApendxiI

Note: GAO comments 

supplementing those in 

the report text appear 

at the end of this 

appendix.
Appendix II

Comments From the Department of 

Commerce

Page 34 GAO-04-606 Pacific Groundfish Assessments

See comment 1.

See comment 2.

See comment 3.

See comment 4.

See comment 5.

See comment 6.

See comment 7.

See comment 8.

See comment 9.

Page numbers in the draft 

report may differ from those 

in this report.
Appendix II

Comments From the Department of 

Commerce

Page 35 GAO-04-606 Pacific Groundfish Assessments

See comment 10.

See comment 2.

See comment 11.

See comment 12.

See comment 2.

See comment 6.

See comment 13. 

See comment 14.

See comment 15.

See comment 16.

See comment 17.

See comment 18.

See comment 19.
Appendix II

Comments From the Department of 

Commerce

Page 36 GAO-04-606 Pacific Groundfish Assessments

See comment 19.

See comment 20.

See comment 7.

See comment 21.

See comment 2.

See comment 22.

See comment 23.

See comment 24.

See comment 25.

See comment 26.

See comment 27.

See comments 7 and 21.

See comment 28.
Appendix II

Comments From the Department of 

Commerce

Page 37 GAO-04-606 Pacific Groundfish Assessments

See comment 29.

See comment 30.

See comment 31.

See comment 32.

See comment 6.

See comment 33.

See comment 19.

See comment 34.

See comment 35.
Appendix II

Comments From the Department of 

Commerce

Page 38 GAO-04-606 Pacific Groundfish Assessments

See comment 36.

See comment 37.

See comment 38.
Appendix II

Comments From the Department of 

Commerce

Page 39 GAO-04-606 Pacific Groundfish Assessments

See comment 39.

See comment 40.
Appendix II

Comments From the Department of 

Commerce

Page 40 GAO-04-606 Pacific Groundfish Assessments
Appendix II

Comments From the Department of 

Commerce

Page 41 GAO-04-606 Pacific Groundfish Assessments
Appendix II

Comments From the Department of 

Commerce

Page 42 GAO-04-606 Pacific Groundfish Assessments

The following are GAO comments on NOAA’s letter dated May 13, 2004.

GAO Comments 1. We added clarifying language to the scope and methodology section of 

the report to clearly identify the species and activities covered by the 

review.

2. We revised the report to show the publication date. 

3. We revised the report accordingly. 

4. We revised the report to clearly show that NMFS has not collected 

enough ecosystem data and that the frequency and range of 

recruitment surveys are limited. The statement does not address 

untrawlable habitat.

5. We revised the report to clarify that NMFS “generally uses” NMFS’s 

staff or contracts with outside experts.

6. We revised the report to more clearly differentiate between NMFS as a 

whole and NMFS’ Northwest Center in particular. We made similar 

revisions, as appropriate, throughout the report.

7. We revised the report to specify “bottom” trawl survey. We made similar 

changes, as appropriate, throughout the report.

8. We revised the report to include the year and scope of the task force 

review.

9. We revised the report to indicate that the Northwest Center is 

responsible for coordinating groundfish stock assessments.

10. We revised the report to include the citation. 

11. We revised the report to include the date and citation of the National 

Research Council report.

12. The NMFS data used in the bocaccio, canary, and darkblotched 

assessments were limited because NMFS conducted its surveys in 

trawlable waters only. NMFS data were not available for untrawlable 

waters, which these species also inhabit. For this reason, we did not 

revise the report.
Appendix II

Comments From the Department of 

Commerce

Page 43 GAO-04-606 Pacific Groundfish Assessments

13. We revised the report to clarify the shared responsibilities of the 

Northwest and Southwest Centers. 

14. We revised the report to include NOAA’s recommended definition of 

stock abundance. 

15. We revised the report to include larval fish. 

16. We revised the report to clarify the role of the review panel. 

17. We revised the report to more explicitly distinguish the five species 

related to our report from other overfished Pacific groundfish. 

18. We revised the report to more clearly describe the distribution of 

Pacific hake. 

19. Bocaccio survey data for untrawlable habitats, as stated in comment 

12, was unavailable. For this reason, we did not change the report.

20. NOAA commented that highly standardized protocols are used for 

collecting non-NMFS data (fishery dependent data) for rockfish. We 

found that although NMFS does have collection and quality assurance 

procedures for state-collected non-NMFS data, NMFS does not check 

or have a standard process to verify that these data have been reviewed 

for reliability. As discussed in our report, some assessors chose to 

review the raw data, while others did not. Assessors who voluntarily 

reviewed raw non-NMFS data found mistakes that either made some of 

the data unusable or could have impaired the accuracy of the stock 

assessments. For these reasons, we did not change the report.

21. We revised the punctuation accordingly.

22. We revised the report to clarify that Pacific hake live in mid-water 

habitat.

23. The footnote placement and citation are in accordance with GAO 

guidelines. For this reason, we did not change the report.

24. We believe that our report has addressed this issue. By referring to the 

West Coast Groundfish Research Plan by its complete title, we 

adequately distinguish between the two reports. For this reason, we did 

not change the report.
Appendix II

Comments From the Department of 

Commerce

Page 44 GAO-04-606 Pacific Groundfish Assessments

25. We changed “health” to “stock abundance.”

26. The footnote placement is repositioned in report.

27. We revised the report to include assessment “improvements.”

28. As indicated in our report, we illustrate some of the actions that the 

Northwest Center took to improve data quantity and did not intend to 

provide a comprehensive list of all actions conducted to improve data 

quantity coast wide. However, we added footnote 16 to clarify the 

actions taken by the Southwest Center.

29. The example we provided is not intended to be a comprehensive list of 

all ecosystem research conducted on the west coast. Instead, it 

illustrates the type of work the Northwest Center is conducting and the 

opportunities for improving ecosystem research. For this reason, we 

did not change the report.

30. After reviewing the report we believe no change is required because of 

subject-verb agreement.

31. We added clarifying language.

32. We believe that table 2 notes “a” and “b” in our report already 

adequately address this issue. Annotations for projects that do not 

separate out groundfish funds occur only in items that are annotated as 

Southwest Center projects. For this reason, we did not change the 

report.

33. We changed “survivability” to “sustainability.”

34. We changed “survivability” to “sustainability” and added fishery 

“resources” for clarification.

35. NOAA commented that GAO does not adequately convey the different 

degrees of precision associated with the stock assessments and GAO’s 

conclusion that the reliability of the five assessments we reviewed is 

questionable and could easily be misconstrued to mean all these 

assessments are an unreliable basis for management of the west coast 

groundfish fishery. NOAA also commented that the five assessments 

GAO reviewed all passed scientific review and are serving as the basis 

for formal status determination and fishery management. Our report 
Appendix II

Comments From the Department of 

Commerce

Page 45 GAO-04-606 Pacific Groundfish Assessments

acknowledges that stock assessments are scientifically reviewed and 

are a key tool for managing fisheries. However, we found the reliability 

of the five assessments questionable for the three reasons we 

highlighted in our report, and we recommended actions on how to 

improve the reliability of the stock assessments. We added clarification 

to the report to show that stock assessments are a key tool for 

managing fisheries and are important in making decisions about setting 

harvest levels and developing plans to rebuild overfished stocks. 

NOAA also commented that quality assurance for non-NMFS data is not 

absent. As stated in our response number 20, we found that although 

NMFS does have collection and quality assurance procedures for statecollected non-NMFS data, NMFS does not check or have a standard 

process to verify that these data have been reviewed for reliability. As 

discussed in our report, some assessors chose to review the raw data, 

while others did not. Assessors who voluntarily reviewed raw nonNMFS data found mistakes that either made some of the data unusable 

or could have impaired the accuracy of the stock assessments. For 

these reason, we did not change the report.

36. NOAA commented that it is more pertinent to focus on the degree of 

standardization of the survey data than the source. By categorizing data 

as NMFS data and non-NMFS data, we were not implying that nonNMFS organizations could not conduct useful fishery-independent 

surveys. We categorized the data in this manner because NMFS 

currently conducts nearly all of the fishery-independent surveys and 

non-NMFS organizations collect most of the fishery-dependent data. 

Footnote 7 in the report states that NMFS generally refers to its data as 

fishery-independent data and to non-NMFS data as fishery-dependent 

data. For these reasons, we did not change the report.

37. We believe the Pacific hake biomass estimates are questionable 

because the assessment used non-NMFS data that NMFS did not check 

or subject to standard data reliability testing. Assessors who reviewed 

raw non-NMFS data for other stock assessments found mistakes that 

either made some of the data unusable or could have impaired the 

accuracy of the stock assessments. For this reason, we did not change 

the report.

38. NOAA commented that bocaccio, canary, and darkblotched 

assessments all obtain adequate abundance trend information from the 

NMFS bottom trawl surveys. NOAA also commented that although 
Appendix II

Comments From the Department of 

Commerce

Page 46 GAO-04-606 Pacific Groundfish Assessments

bottom trawl survey cannot access the roughest habitat, it is useful as 

an index of relative changes in the overall abundance. As stated in our 

report, we found that the NMFS survey data used in these assessments 

were limited in scope because the surveys were conducted only in 

trawlable areas. Assessors estimated overall biomass using the NMFS 

data collected from the trawlable area, which has a different abundance 

rate than the untrawlable area. Stock assessors commented that relying 

on survey data from trawlable waters only increases the uncertainty of 

stock assessments. For these reasons, we did not change the report.

39. As noted in our report, the National Research Council found that the 

inclusion of NMFS survey data was the best option for a reliable 

estimate of abundance because such surveys use an unbiased statistical 

design, control sampling locations, and provide for quality assurance. 

Northwest Center officials said that to obtain reliable results, each 

stock assessment should include at least one source of NMFS-collected 

data of sufficient scope and accuracy because such surveys are 

unbiased and scientifically designed. NMFS data were unavailable for 

the yelloweye assessment. Northwest Center officials also raised 

concerns about basing assessments solely on non-NMFS data such as 

commercial and recreational catch data. Catch data do not provide the 

species’ relative or absolute biomass, according to NMFS officials. 

Catch data alone are insufficient because fishermen are not randomly 

sampling the ocean, but are fishing areas that they are allowed to fish 

and they believe have the most fish; fishing restrictions, such as a total 

allowable catch, can limit the amount of fish being caught; and catch 

data have often been inaccurate for a variety of reasons, such as 

imprecise accounting for dead fish tossed back into the ocean. For 

these reasons, we did not change the report.

40. NOAA commented that the doubling of estimated bocaccio biomass in 

2003 was due to factors that would not be addressed in a standard 

statistical analysis. Although a standard statistical analysis may not 

fully address the doubling of an estimate, an assessment without an 

uncertainty range does not quantify and communicate any of the 

uncertainty. For this reason, we did not change the report.
Page 47 GAO-04-606 Pacific Groundfish Assessments

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Keith W. Oleson, (415) 904-2218

Staff 

Acknowledgments

In addition to the person named above, Leo G. Acosta, Kristine N. Braaten, 

Allen T. Chan, David Dornisch, Alan Kasdan, Robert Marek, Cynthia C. 

Norris, Carol Herrnstadt Shulman, and Tama R. Weinberg made key 

contributions to this report.

(360345)
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