FEDERAL

FISHERIES 

MANAGEMENT

Additional Actions 

Could Advance Efforts 

to Incorporate Climate 

Information into 

Management 

Decisions

Accessible Version

Report to Congressional Requesters

September 2016

GAO-16-827

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-827, a report to 

congressional requesters

September 2016

FEDERAL FISHERIES MANAGEMENT

Additional Actions Could Advance Efforts to 

Incorporate Climate Information into Management 

Decisions

What GAO Found

The Department of Commerce’s National Marine Fisheries Service (NMFS) and 

eight Regional Fishery Management Councils (Council) have general information 

on the types of effects climate change is likely to have on federally managed fish 

stocks but limited information on the magnitude and timing of effects for specific

stocks. They also face several challenges to better understand these effects, 

based on GAO’s analysis of NMFS and Council questionnaire responses, NMFS 

and Council documentation, and interviews with NMFS and Council officials. For 

example, NMFS officials said that northern rock sole may adapt to warming 

ocean temperatures more easily than other fish species, but it is unknown how 

such temperatures may affect the timing of the fish’s life cycle events, such as 

spawning. NMFS and Council officials identified several challenges to better 

understand potential climate change effects on fish stocks, including determining 

whether a change in a stock’s abundance or distribution is the result of climate 

change or other factors, such as overfishing in the case of Atlantic cod.

Atlantic Cod

NMFS developed a climate science strategy in 2015 to help increase the use of 

climate information in fisheries management. The strategy lays out a national 

framework to be implemented by NMFS’ regions but does not provide specific 

guidance on how climate information should be incorporated into the fisheries 

management process. An NMFS official said that developing such guidance has 

not been an agency priority, but as knowledge on climate change progresses 

there is a more pressing need to incorporate climate information into fisheries 

management decision making. Developing such guidance would align with 

federal standards for internal control and may help NMFS ensure consistency in 

how its regions and the Councils factor climate-related risks into fisheries 

management. In addition, NMFS has not developed agency-wide performance 

measures to track progress toward the strategy’s overall objectives, a leading 

practice. NMFS officials said they are waiting to finalize regional action plans for 

implementing the strategy before determining whether such measures may be 

necessary. GAO reviewed the proposed measures in NMFS’ draft regional action 

plans and found that they aligned with some key attributes of successful 

performance measures. But, most of the measures did not contain other key 

attributes, such as measurable targets. By incorporating key attributes when

developing performance measures and assessing whether agency-wide 

measures may also be needed, NMFS may be in a better position to determine 

the extent to which the objectives of its strategy overall are being achieved.

View GAO-16-827. For more information, 

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

or fennella@gao.gov.

Why GAO Did This Study

NMFS and the Councils manage 

commercial and recreational marine 

fisheries that are critical to the nation’s 

economy. The effects of climate 

change may pose risks to these 

fisheries that could have economic 

consequences for the fishing industry 

and coastal communities, according to 

the 2014 Third National Climate 

Assessment. 

GAO was asked to review federal 

efforts to address the effects of climate 

change on federal fisheries. This report 

examines (1) information NMFS and 

the Councils have about the existing 

and anticipated effects of climate 

change on federally managed fish 

stocks and challenges to better 

understand these effects and 

(2) efforts NMFS has taken to help it 

and the Councils incorporate climate 

information into fisheries management. 

GAO analyzed responses to its 

questionnaire from all NMFS regions 

and the Councils, analyzed seven 

nongeneralizable fish species selected 

to reflect variation in the potential 

effects of climate change, reviewed 

relevant documentation, and 

interviewed NMFS and Council 

officials.

What GAO Recommends

GAO recommends that NMFS 

(1) develop guidance on incorporating 

climate information into the fisheries 

management process and 

(2) incorporate key attributes of 

successful performance measures in 

the regional action plans and assess 

whether agency-wide measures for the 

climate science strategy may be 

needed. The agency agreed with 

GAO’s recommendations.
Letter 1

Page i GAO-16-827 Federal Fisheries Management

Background 6

NMFS and the Councils Have Limited Information on the 

Magnitude and Timing of Climate Change Effects on Fish 

Stocks 14

NMFS Developed a Strategy to Help Incorporate Climate 

Information into Fisheries Management, but It Is in the Early 

Stages of Implementation 24

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 31

Appendix I: Objectives, Scope, and Methodology 33

Appendix II: Key Attributes of Successful Performance Measures 37

Appendix III: Comments from the Department of Commerce 38

Appendix IV: GAO Contact and Staff Acknowledgments 41

GAO Contact 41

Staff Acknowledgments 41

Appendix V: Accessible Data 42

Agency Comment Letter 42

Accessible Text 45

Tables

Table 1: NOAA Fisheries Climate Science Strategy (Strategy) 

Priority Objectives 28

Table 2: Key Attributes of Successful Performance Measures 37

Accessible Text for Figure 2: General Steps in the Federal 

Fisheries Management Process 45

Figures

Figure 1: Boundaries of National Marine Fisheries Service (NMFS) 

Regions and the Regional Fishery Management Councils 

(Council) 8

Contents
Figure 2: General Steps in the Federal Fisheries Management 

Process 11

Page ii GAO-16-827 Federal Fisheries Management

Abbreviations

Council Regional Fishery Management Council

ISO International Organization for 

Standardization

Magnuson-Stevens Act Magnuson-Stevens Fishery Conservation 

and Management Act of 1976, as amended

NMFS National Marine Fisheries Service

NOAA National Oceanic and Atmospheric 

Administration

Strategy NOAA Fisheries Climate Science Strategy
Page iii GAO-16-827 Federal Fisheries Management

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-827 Federal Fisheries Management

441 G St. N.W.

Washington, DC 20548

September 28, 2016

The Honorable Sheldon Whitehouse

Ranking Member

Subcommittee on Fisheries, Water, and Wildlife

Committee on Environment and Public Works

United States Senate

The Honorable Robert Menendez

United States Senate

The Honorable Jeff Merkley

United States Senate

Commercial and recreational marine fisheries are critical to the nation’s 

economy, contributing approximately $100 billion to the U.S. gross 

domestic product and supporting more than 1.8 million jobs in 2014.1

These fisheries may be vulnerable to the increasing effects of climate 

change in the oceans—including physical changes such as warmer 

surface temperatures and chemical changes such as higher acidity 

levels—which could affect the abundance and distribution of fisheries, 

according to the U.S. Global Change Research Program’s 2014 Third 

National Climate Assessment.2 This assessment also reports that 

changes in the abundance and distribution of certain fisheries could have 

economic consequences for the communities and industries that depend 

on harvesting the affected fish, for example, by reducing the availability of 

some commercially and recreationally important fish species.

 

1National Marine Fisheries Service, Fisheries Economics of the United States, 2014, U.S. 

Department of Commerce, National Oceanic and Atmospheric Administration Technical 

Memorandum NMFS-F/SPO-163 (Silver Spring, Md: 2016). The information on gross 

domestic product and jobs includes data on commercial seafood harvesters, processors, 

dealers, wholesalers, distributors, importers, and retailers, as well as recreational fishing 

trips and fishing equipment for state and federally managed fisheries. For the purposes of 

this report, the terms fisheries and fisheries management refer to marine fisheries that are 

at least in part federally managed and include fish and invertebrate species, such as 

shellfish.

2

Jerry M. Melillo, Terese (T. C.) Richmond, and Gary W. Yohe, eds., Climate Change 

Impacts in the United States: The Third National Climate Assessment, U.S. Global 

Change Research Program (Washington, D.C.: 2014). 

Letter
The federal government serves as a financial backstop to the fishing 

industry by providing disaster assistance in the event of a fishery disaster. 

For example, a fishery disaster can be declared after the Secretary of 

Commerce determines that a commercial fishery failure under certain 

conditions has occurred.

Page 2 GAO-16-827 Federal Fisheries Management

3 The federal government provided more than 

$640 million in federal fishery disaster assistance from 2005 through

2015, according to Department of Commerce data.4 The effects of climate 

change could negatively affect fisheries and contribute to future fishery 

disasters, according to the Department of Commerce’s National Oceanic 

and Atmospheric Administration (NOAA).5 The effects of climate change, 

in general, may also increase the fiscal exposure to the federal 

government—limiting the federal government’s fiscal exposure by better 

managing climate change risks has been on our high-risk list since 2013, 

 

3Under provisions of the Magnuson-Stevens Act and the Interjurisdictional Fisheries Act, 

the federal government may provide fishery disaster assistance in certain circumstances. 

See 16 U.S.C. §§ 1861a(a), 1864, 4107(b), 4107(d). A commercial fishery failure occurs 

when commerce in, or revenue from commerce in, a fishery materially decreases or is 

markedly weakened due to a fishery resource disaster, such that those engaged in the 

fishery suffer severe economic hardship. There is no standing fund for fishery disaster 

relief, so when the Secretary determines that a fishery disaster has occurred, Congress is 

to decide whether, and how much, to appropriate in disaster assistance.

4This is the amount that was appropriated for federal fishery disaster assistance under 

sections 312(a) and 315 of the Magnuson-Stevens Act or sections 308(b) and 308(d) of 

the Interjurisdictional Fisheries Act, according to officials from the Department of 

Commerce’s National Oceanic and Atmospheric Administration.

5NOAA cited the potential for climate change to amplify conditions—such as harmful algal 

blooms and changes in ocean temperatures—that can negatively affect fish stocks as part 

of its justification for its 2016 proposal to establish a fund to improve the environmental 

and economic resilience of fisheries declared a disaster by the Secretary. See National 

Oceanic and Atmospheric Administration, Budget Estimates Fiscal Year 2017

(Washington, D.C.: 2016). 
in part, because of concerns about the increasing costs of federal disaster 

response and recovery assistance.

Page 3 GAO-16-827 Federal Fisheries Management

6

NOAA is the lead federal agency responsible for managing commercial 

and recreational marine fisheries. Specifically, the Magnuson-Stevens 

Fishery Conservation and Management Act of 1976, as amended

(Magnuson-Stevens Act), sets forth national standards for federal 

fisheries conservation and management.7 Under the act, NOAA’s National 

Marine Fisheries Service (NMFS) and eight Regional Fishery 

Management Councils (Council) are responsible for fisheries 

management and conservation in federal waters.8 NMFS generally serves 

as the lead agency—in collaboration with partners from the states, 

academia, and elsewhere—for developing scientific information on 

federally managed fish stocks, including through stock assessments—

reports that contain information on fish biology, abundance, and 

distribution.9 NMFS and the Councils then use this information to develop 

 

6GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013). 

We updated the high-risk list again in 2015; see GAO, High-Risk Series: An Update, 

GAO-15-290 (Washington, D.C.: Feb. 11, 2015). We previously found that the federal 

government does not budget for the costs of supplemental appropriations for relief for 

major disasters, and that without proper budgeting and forecasting to account for such 

events, the government runs the risk of facing a large fiscal exposure at any time. The 

term fiscal exposure refers to the responsibilities, programs, and activities that may either 

legally commit the federal government to future spending or create the expectation for 

future spending. See GAO, Fiscal Exposures: Improving Cost Recognition in the Federal 

Budget, GAO-14-28 (Washington, D.C.: Oct. 29, 2013). Also, see GAO’s Federal Fiscal 

Outlook webpage (here). 

7Pub. L. No. 94-265, § 301(a) (1976) (codified as amended at 16 U.S.C. § 1851(a)).

8The Councils are supported by federal funds and generally comprise NMFS regional 

administrators, state officials, and members of the fishing industry and conservation 

groups as voting members, as well as other nonvoting members, such as officials from 

other federal agencies. The Magnuson-Stevens Act establishes requirements for the 

selection of certain voting members for each Council. NMFS provides guidance to the 

Councils on how they are to implement their fisheries management responsibilities.

9A fish stock refers to either one species or a complex of comparable species managed as 

an entity in a specific geographic area. When possible, NMFS uses biology to help identify 

a stock’s geographic boundaries, according to NMFS officials. In some cases, individual 

species are managed as multiple stocks, based on geographic location. For example, in 

the Alaska region, walleye pollock are managed as four separate stocks based on their 

geographic distribution in different areas of the Bering Sea and Gulf of Alaska. This report 

primarily uses the term fish stock since this is generally the unit of management for federal 

fisheries. In instances where we obtained information at the fish species level, we use the 

term species. 
and implement fishery management plans, which contain practices 

fisheries managers are to follow in managing each fishery and in setting 

annual catch limits.

Page 4 GAO-16-827 Federal Fisheries Management

10 Annual catch limits establish the limit on the amount 

of fish that can be harvested annually for specific fish stocks.

You asked us to review federal efforts to address the effects of climate 

change on federal fisheries management. This report examines 

(1) information NMFS and the Councils have about the existing and 

anticipated effects of climate change on federally managed fish stocks 

and challenges they face to better understand these effects and 

(2) efforts NMFS has taken to help it and the Councils incorporate climate 

information into the fisheries management process.

To examine information NMFS and the Councils have about the effects of 

climate change on federally managed fish stocks and challenges they 

face to better understand these effects, we reviewed scientific studies and 

other documentation prepared by NMFS, the Councils, and others such 

as academics. We also developed a questionnaire of open-ended 

questions, which we disseminated to the five NMFS regional offices and 

the eight Councils to obtain their views on the information they have 

about the effects of climate change on the fish stocks they manage and 

any challenges they face to better understand these effects, among other 

things. All five NMFS regions and the eight Councils responded.11 We 

analyzed their responses to identify key themes, which we attribute in this 

report to NMFS and Council officials. In addition, we analyzed a 

nongeneralizable sample of seven fish species as case studies.12 We 

selected the seven species to reflect a range of potential effects of 

climate change and variation in the value and volume of commercial 

 

10For the purposes of this report, the term fisheries managers refers to the different 

entities involved in making management decisions for federally managed fisheries, 

including NMFS and the Councils. In instances where a fishery occurs in both federal and 

state waters, NMFS and the Councils may also work with individual states or interstate 

regional bodies, such as the Atlantic States Marine Fisheries Commission, in the 

management of the fishery.

11NMFS’ regional offices and regional Fisheries Science Centers—which are responsible 

for conducting research and providing scientific advice, among other things—worked 

together to produce coordinated regional responses to the questionnaire.

12These case studies are intended to provide illustrative examples only and cannot be 

projected to the entire universe of fish species.
harvests, based on NMFS’ commercial fisheries data from 2008 to 2013. 

We assessed the reliability of these fisheries data and found them to be 

sufficiently reliable for the purpose of selecting case study species.

To examine efforts NMFS has taken to help it and the Councils 

incorporate climate information into the fisheries management process,

Page 5 GAO-16-827 Federal Fisheries Management

13

we analyzed the questionnaire responses provided by the NMFS regions 

and Councils and reviewed agency and Council documentation, such as 

the NOAA Fisheries Climate Science Strategy (Strategy).

14 We compared 

this information to leading practices in risk management and federal 

standards for internal control and assessed the Strategy against leading 

practices in strategic planning and performance measurement.15 For both 

objectives, we also interviewed officials from NMFS’ headquarters and 

two regions (Greater Atlantic and Alaska), as well as representatives from 

four Councils (New England, Mid-Atlantic, South Atlantic, and North 

 

13Our analysis of steps taken to incorporate climate information into the fisheries 

management process focused on the process for setting annual catch limits and related 

management actions. The Magnuson-Stevens Act requires the Councils to develop 

annual catch limits for each of their managed fisheries, and NMFS officials described this 

responsibility as a major part of the fisheries management process. According to NMFS 

officials, other fishery management actions (such as managing the conservation of fish 

habitat) may follow different processes, which we did not include in our analysis.

14Jason S. Link, Roger Griffis, and Shallin Busch, eds., NOAA Fisheries Climate Science 

Strategy, U.S. Department of Commerce, NOAA Technical Memorandum NMFS-F/SPO155 (Silver Spring, Md: 2015). The Strategy is available here.

15For leading practices in risk management, see International Organization for 

Standardization, ISO 31000 Risk Management—Principles and Guidelines (2009). The 

International Organization for Standardization (ISO) is a worldwide federation of national 

standards bodies. ISO 31000:2009 Risk management – Principles and guidelines is 

available here. For internal control standards, see GAO, Standards for Internal Control in 

the Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). We 

have revised and reissued our standards for internal control, with the new revision 

effective as of October 1, 2015. See GAO, Standards for Internal Control in the Federal 

Government, GAO-14-704G (Washington, D.C.: September 2014). For examples of 

leading practices in strategic planning and performance measurement, see GAO, Tax 

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

Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002); Executive Guide: Effectively 

Implementing the Government Performance and Results Act, GAO/GGD-96-118 

(Washington, D.C.: June 1996); and Agencies’ Annual Performance Plans Under the 

Results Act: An Assessment Guide to Facilitate Congressional Decisionmaking, 

GAO/GGD/AIMD-10.1.18 (Washington, D.C.: February 1998).
Pacific) and the Atlantic States Marine Fisheries Commission.

Page 6 GAO-16-827 Federal Fisheries Management

16 To obtain 

broader perspectives, we also interviewed representatives from 11 

stakeholder organizations selected to reflect geographic diversity and 

different types of involvement in fisheries management issues, including 

fishing industry groups, conservation groups, and a nonprofit serving 

Alaska Natives. Appendix I contains a more detailed description of our 

objectives, scope, and methodology.

We conducted this performance audit from November 2014 to September 

2016 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.

NMFS—operating through its headquarters, five regional offices, and six 

regional Fisheries Science Centers—and the eight Councils are 

responsible for managing approximately 470 fish stocks in federal waters 

across five geographic regions of the country (see fig. 1 for the NMFS 

region and Council boundaries).17 Federal waters generally extend from 3 

to 200 nautical miles off the coast of the United States.18 In fiscal year 

 

16We selected these entities for interviews because they are involved in managing 

fisheries in regions of the country that are expected to experience significant effects from 

climate change, according to NMFS documentation and our discussions with agency 

officials.

17The 470 fish stocks include some stock complexes where comparable species are 

managed together as one entity in a specific geographic area. In addition to NMFS’

fisheries management responsibilities, the agency is also responsible for, among other 

things, managing marine species listed as threatened or endangered under the 

Endangered Species Act. 

18Coastal states generally maintain responsibility for managing fisheries in waters that 

extend approximately 3 geographic miles from their coastlines. In the 1940s, the federal 

government authorized three interstate compacts, each creating a regional interstate 

marine fisheries commission to better utilize and protect fisheries within the consenting 

states’ jurisdictions. The three commissions represent the Atlantic, Gulf, and Pacific 

states, respectively. Legislation passed in the 1980s and 1990s gave the Atlantic States 

Marine Fisheries Commission some independent regulatory authority over some species. 

This commission is now directly involved in the management of more than 20 fish stocks 

in state waters, including some stocks that are concurrently managed by NMFS and the 

Councils in federal waters.

Background
2016, NMFS’ budget for its fisheries science and management activities, 

such as conducting stock assessments and developing fisheries 

management guidance, was approximately $536.7 million, according to 

NOAA budget documents.

Page 7 GAO-16-827 Federal Fisheries Management

19

 

19About $33.5 million of the approximately $536.7 million was provided to the Councils 

and the interstate marine fisheries commissions to support their operating costs.
Figure 1: Boundaries of National Marine Fisheries Service (NMFS) Regions and the Regional Fishery Management Councils 

Page 8 GAO-16-827 Federal Fisheries Management

(Council)

Note: The Western Pacific Council includes the Mariana Islands archipelago, American Samoa, and a 

range of remote island areas in the central and western Pacific not depicted on this map. Coastal 

states generally are responsible for managing fisheries in waters that extend approximately 3 

geographic miles from their coastlines, and NMFS and the Councils manage fisheries in federal 

waters.
NMFS has overall responsibility for collecting data on fish stocks and 

ocean conditions and for generating the scientific information necessary 

for the conservation, management, and use of marine resources.

Page 9 GAO-16-827 Federal Fisheries Management

20 The 

agency’s six regional Fisheries Science Centers are the primary entities 

responsible for performing this work, and they collaborate with a variety of 

partners, such as coastal states, academics, other nations, and members 

of the fishing industry in doing so. For many fish stocks, the regional 

Fisheries Science Centers analyze the collected data to conduct stock 

assessments to estimate, among other things, the size of the population 

of a fish stock (i.e., the stock’s abundance) and other population 

dynamics.21 In addition, stock assessments contain information on 

reference points that can be used to inform management decisions.22

NMFS provides the results of its stock assessments and other analyses, 

as appropriate, to the Councils for use in implementing their respective 

fisheries management responsibilities.

The Councils are responsible for a number of steps in the fisheries 

management process. In particular, the Councils develop and amend 

fishery management plans for fish stocks, based on guidelines developed 

by NMFS. Fishery management plans identify, among other things, the 

conservation and management measures that will be used to manage a 

fishery, such as fishing equipment restrictions, permitting policies, and 

restrictions on the timing or location of permissible fishing. The 

Magnuson-Stevens Act requires the conservation and management 

measures in fishery management plans to be based on the best scientific 

information available. The Councils submit proposed plans and plan 

amendments to NMFS, which is responsible for determining if they are 

 

20We previously reviewed NMFS’ recreational fisheries data collection efforts. See GAO, 

Recreational Fisheries Management: The National Marine Fisheries Service Should 

Develop a Comprehensive Strategy to Guide Its Data Collection Efforts, GAO-16-131 

(Washington, D.C.: Dec. 8, 2015). 

21We previously reviewed NMFS’ fish stock assessment prioritization process. See GAO, 

Fish Stock Assessments: Prioritization and Funding, GAO-14-794R (Washington, D.C.: 

Sept. 19, 2014).

22Reference points provide targets, thresholds, and other decision criteria used in the 

fisheries management process, such as determining a numeric threshold that if exceeded 

would indicate that overfishing had occurred.
consistent with the Magnuson-Stevens Act and other applicable laws, and 

for issuing and enforcing final regulations to implement approved plans.

Page 10 GAO-16-827 Federal Fisheries Management

23

In implementing fishery management plans, the Councils are responsible 

for determining the maximum size of each fish stock’s allowable harvest.24

This is generally done by developing annual catch limits for each fish 

stock, that is, the amount of fish that can be harvested in the year. Figure 

2 presents an overview of the federal fisheries management process.

 

23The Magnuson-Stevens Act authorizes the Secretary of Commerce to approve,

disapprove, or partially approve proposed fishery management plans and plan 

amendments submitted by the Councils. The Secretary has subsequently delegated this 

responsibility to the NOAA Assistant Administrator for Fisheries.

24The Councils do this in consultation with their scientific and statistical committees, which 

are advisory bodies made up of members—such as federal and state employees, 

academics, and independent experts— who are required to have strong scientific or 

technical credentials and experience and are appointed by the Councils.
Figure 2: General Steps in the Federal Fisheries Management Process

Page 11 GAO-16-827 Federal Fisheries Management

Note: This figure presents the process for setting annual catch limits and related management 

actions. The processes followed for other fishery management actions (e.g., managing the 

conservation of fish habitat) may differ from the process depicted in this figure. For example, the 

types of data collected and analyzed may vary based on the specific action the data and analyses are 

intended to support.
According to the 2014 Third National Climate Assessment, a number of 

physical and chemical changes to the oceans have been observed or are 

expected to occur as a result of climate change, largely attributable to 

increasing concentrations of greenhouse gases in the atmosphere, such 

as carbon dioxide.

Page 12 GAO-16-827 Federal Fisheries Management

25 For instance, surface temperatures for the ocean 

surrounding the United States and its territories warmed by more than 0.9 

degrees Fahrenheit over the past century, according to the 2014 

assessment. Changes in ocean temperature have varied, with the oceans 

off the coasts of Alaska and parts of the northeastern United States, for 

example, warming more rapidly than other areas. The 2014 assessment 

notes that warming has several consequences and can lead to a number 

of other physical changes in the ocean, such as the thermal expansion of 

sea water, which may contribute to rising sea levels. Increases in ocean 

surface temperatures may also alter ocean circulation by reducing the 

vertical mixing of water that brings nutrients to the surface and oxygen to 

deeper waters, which could affect the availability of nutrients and oxygen 

for marine life in different locations, according to the 2014 assessment.

Increasing levels of carbon dioxide in the atmosphere have also 

contributed to chemical changes in the oceans. According to the National 

Research Council, scientists estimate that the world’s oceans have 

absorbed approximately 30 percent of the carbon dioxide emitted by 

human activities over the past 200 years.26 As atmospheric 

concentrations of carbon dioxide increase, the amount of carbon dioxide 

in the oceans also increases. The increased uptake of atmospheric 

carbon dioxide is resulting in chemical changes in the oceans, including a 

decrease in the average pH of surface ocean waters (making seawater 

more acidic) and a reduction in the availability of minerals needed by 

many marine organisms to build shells and skeletons, according to the 

National Research Council. These chemical changes, known as ocean 

 

25Melillo, Richmond, and Yohe, Third National Climate Assessment. The primary 

greenhouse gases in Earth’s atmosphere are water vapor, carbon dioxide, methane, 

nitrous oxide, and ozone.

26National Research Council, Ocean Acidification: A National Strategy to Meet the 

Challenges of a Changing Ocean (Washington, D.C.: 2010). The National Research 

Council is now known as the National Academies of Sciences, Engineering, and Medicine. 

Climate Change Effects on 

Ocean Environments
acidification, may pose risks for some marine species and ecosystems.

Page 13 GAO-16-827 Federal Fisheries Management

27

For the purposes of this report, our discussion of the effects of climate 

change refers to both physical and chemical changes in the oceans.

Broadly defined, risk management is a strategic process for helping 

decision makers assess risk, allocate finite resources, and take action 

under conditions of uncertainty, such as when faced with incomplete 

information or unpredictable outcomes that may have negative impacts. 

Risk management is an inherent part of fisheries management, as 

fisheries managers often make decisions based on incomplete data and 

in the face of uncertainty. Accounting for the potential effects of climate 

change injects an additional source of uncertainty and risk into the 

fisheries management process. The federal government has recognized 

the need to account for climate change risks in its planning and programs 

and has called on agencies to take certain actions. For example, the 

President issued Executive Order 13653 in 2013, directing federal 

agencies to develop or update comprehensive climate change adaptation 

plans that among other things identify climate-related impacts on and 

risks to an agency’s ability to accomplish its missions, operations, and 

programs and describe the actions the agency will take to manage 

climate risks.28 Subsequently, the Department of Commerce’s 2014 

Climate Change Adaptation Strategy set a goal to incorporate climate 

information in the department’s resource management programs and 

policies and to take action to reduce vulnerabilities and increase 

resilience of marine and coastal natural resources.29

We have previously reported on risk management in the context of 

climate change and identified risks that climate change may pose in a 

variety of areas relevant to the federal government, such as infrastructure 

 

27See GAO, Ocean Acidification: Federal Response Under Way, but Actions Needed to 

Understand and Address Potential Impacts, GAO-14-736 (Washington, D.C.: Sept. 12, 

2014).

2878 Fed. Reg. 66,819 (Nov. 6, 2013).

29Department of Commerce, Department of Commerce Climate Change Adaptation 

Strategy (Washington, D.C.: 2014).

Risk Management as a 

Strategy for Managing 

Climate-Related Risks to 

Fisheries
and federal supply chains.

Page 14 GAO-16-827 Federal Fisheries Management

30 We found that leading risk management 

guidance recommends a sequence of activities that begins, in part, with 

identifying risks. Specifically, the International Organization for 

Standardization’s standards on risk management recommend that 

organizations such as federal agencies develop, implement, and 

continuously improve a framework for integrating risk management into 

their overall planning, management, reporting processes, and policies.31

These standards also state, among other things, that risk management 

should be a part of decision making and that it should be based on the 

best available information.

We found that NMFS and the Councils have general information about 

the types of effects climate change is likely to have on federally managed 

fish stocks, but information about the magnitude and timing of effects for 

specific fish stocks is limited, based on the responses NMFS and the 

Councils provided to our questionnaire, our analysis of NMFS and 

Council documentation, and our interviews with NMFS and Council 

officials. In addition, NMFS and the Councils identified several challenges 

they face to better understand the effects of climate change, such as 

determining the extent to which a change in a fish stock’s abundance or 

distribution is caused by climate change, natural variation in the oceans, 

or other human or environmental factors.

 

30See, for example, GAO, Climate Change: Future Federal Adaptation Efforts Could 

Better Support Local Infrastructure Decision Makers, GAO-13-242 (Washington, D.C.: 

Apr. 12, 2013), and Federal Supply Chains: Opportunities to Improve the Management of 

Climate-Related Risks, GAO-16-32 (Washington, D.C.: Oct. 13, 2015). 

31International Organization for Standardization, ISO 31000 Risk Management—Principles 

and Guidelines (2009). In addition, federal standards for internal control direct agencies to 

assess the risks they face from both external and internal sources, and to identify, 

analyze, and respond to relevant risks—including changes in external environmental 

conditions—associated with achieving agency objectives. See GAO/AIMD-00-21.3.1. We 

have revised and reissued our standards for internal control, with the new revision 

effective as of October 1, 2015. See GAO-14-704G.

NMFS and the 

Councils Have 

Limited Information 

on the Magnitude and 

Timing of Climate 

Change Effects on 

Fish Stocks
Through our analysis, we found that NMFS and the Councils have 

general information about the types of effects climate change is likely to 

have on fish stocks, but information about the magnitude and timing of 

effects for specific fish stocks is limited. In general, the types of effects 

climate change is likely to have include changes in fish stock abundance 

and distribution and the timing or location of biological events such as 

spawning (the process by which fish reproduce), according to NMFS and 

Council officials. These effects will not be uniform across fish stocks but 

rather will likely vary, with the abundance of some stocks being negatively 

affected and the abundance of other stocks increasing or not being 

affected, according to NMFS documentation. Similarly, potential shifts in 

distribution will vary, as some fish stocks may respond to changing ocean 

temperatures by moving north or to deeper waters in search of the water 

temperatures they are accustomed to, but shifts in other directions may 

occur as well. Some NMFS and Council officials said that changes in the 

timing and location of biological events are also expected to vary between 

fish stocks. For example, some fish stocks may spawn at different times 

or in different locations under warmer ocean conditions.

In some instances, the abundance or distribution of fish stocks may shift 

in response to changes in ocean habitats occurring because of a 

changing climate. For example, reductions in seasonal sea ice cover and 

warmer ocean surface temperatures may open up new habitats in polar 

regions that could lead to shifts in distribution for some fish species, 

according to the 2014 Third National Climate Assessment. Furthermore, 

warming ocean temperatures and higher acidity levels also affect the 

health of coral reefs, which provide essential habitat for many fish 

stocks.

Page 15 GAO-16-827 Federal Fisheries Management

32 The 2014 assessment reported, for example, that scientific 

research indicated that 75 percent of the world’s coral reefs were under 

threat from the effects of climate change and local stressors, such as 

overfishing, nutrient pollution, and disease. When water is too warm, 

corals will expel the algae living in their tissues, causing the coral to turn 

completely white—this phenomenon, known as coral bleaching, can 

cause coral to die or become more susceptible to disease, which can 

subsequently decrease their capacity to provide shelter and other 

resources for reef-dependent fish and other ocean life, according to the 

2014 assessment.

 

32For additional information on the effects of higher ocean acidity levels, see GAO-14-736.

NMFS and the Councils 

Have Limited Information 

on the Magnitude and 

Timing of Climate Change 

Effects on Fish Stocks
We found that NMFS and the Councils have limited scientific information 

about the magnitude and timing of potential climate change effects for 

most fish stocks they manage. For example, officials from one Council 

reported that they have very little scientific information specific to how 

climate change is currently affecting the fish stocks in their region, or how 

those stocks may be affected in the future, with the exception of some 

anecdotal information. NMFS and Council officials explained that 

scientific information is often lacking to quantify the magnitude and timing 

of effects for most individual fish stocks and that their ability to project 

future effects at the stock level is generally limited. For instance, NMFS 

and Council officials in the Alaska region reported that they have 

information sufficient to project potential climate change effects on 

abundance for 3 of the 35 primary fish stocks they manage in their 

region.

Page 16 GAO-16-827 Federal Fisheries Management

33 And, as reflected in the examples below, for those stocks where 

they are able to project potential effects, they are uncertain about the full 

range of effects those stocks might experience.

· Northern rock sole. NMFS officials in the Alaska region said that 

their research on northern rock sole has shown that the juvenile fish 

may have increased odds of surviving to become adults under warmer 

ocean conditions, which could have a positive effect on their 

abundance. NMFS officials said that the research indicates that 

northern rock sole can adjust their diets to survive in a variety of 

habitats and therefore may be able to adapt to ecosystem changes 

such as warming ocean temperatures more easily than other fish 

species. In general, NMFS and Council officials from the Alaska 

region said that they do not anticipate the effects of climate change on 

the abundance of northern rock sole to be significant, but 

acknowledged that it is unknown how warming ocean conditions may 

affect the timing or location of the fish’s life cycle events, such as 

spawning.

 

33The three fish stocks are northern rock sole, red king crab, and walleye pollock. The 

NMFS Alaska region has several efforts under way to better understand the effects of 

climate change on the fish stocks it manages in the region, including research projects 

and evaluations of potential fisheries management strategies that could be used under 

changing ocean conditions, according to agency officials.

Northern Rock Sole

The northern rock sole is a flatfish with both 

eyes on one side of its head. Northern rock sole 

live on the ocean floor and prefer a sandy or 

gravel ocean bottom. In the United States, 

northern rock sole are found from the Puget 

Sound through the Bering Sea and the Aleutian 

Islands. Northern rock sole are cooperatively 

managed by the National Marine Fisheries 

Service’s (NMFS) Alaska region and the North 

Pacific Fishery Management Council. In 2014, 

the commercial harvest for the rock sole fishery 

(which includes northern rock sole and southern 

rock sole) was valued at approximately $18.2 

million, according to NMFS data.

Sources: NMFS documentation (text); http://www.fishwatch.gov/

(image). | GAO-16-827
· Walleye pollock. NMFS officials in the Alaska region said that they 

can project some future effects of warming ocean temperatures on the 

abundance of walleye pollock. For instance, the officials told us that 

research indicates warming ocean temperatures could lead to a 

mismatch between the size of the pollock population and the 

availability of food sources for pollock to consume. Unusually warm 

winters in the Alaska region in the early 2000s caused seasonal ice to 

retreat earlier and farther than normal, which led to reductions in the 

amount of zooplankton available for young pollock to eat, according to 

NMFS officials. When young fish do not have sufficient food in their 

first year of life, the likelihood they will survive is reduced, and 

according to NMFS officials, the reduction in zooplankton led to a 

reduction in the pollock population. The officials did not attribute the 

warmer ocean temperatures during this time to climate change, but 

they said this event helped them forecast potential future climate 

effects by providing an opportunity to observe how pollock respond to 

changes in the environment similar to those anticipated from climate 

change. However, NMFS officials we interviewed said that making 

further predictions about the magnitude of potential climate change 

effects on the abundance and distribution of pollock is difficult 

because of the limited amount of climate-related information specific 

to the species. Agency officials told us that additional research is 

under way to better understand the effects of warmer ocean 

temperatures on pollock.

To better understand which fish species may be most vulnerable to 

climate change, NMFS initiated an effort to systematically assess the 

vulnerability of marine species to a changing climate. Specifically, in 

2015, NMFS developed a methodology for conducting climate 

vulnerability assessments for marine species using a combination of 

quantitative data, qualitative information, and expert opinion. The agency 

has used this methodology to complete an assessment for marine fish 

and invertebrate species that commonly occur in the Greater Atlantic 

region, which it published in February 2016.

Page 17 GAO-16-827 Federal Fisheries Management

34 As of August 2016, NMFS 

 

34Jonathan A. Hare et al., “A Vulnerability Assessment of Fish and Invertebrates to 

Climate Change on the Northeast U.S. Continental Shelf,” PLOS One, vol. 11, no. 2 

(2016). Invertebrates are species that do not have a backbone, including shellfish such as 

lobsters and crabs. Since this assessment was performed at the species level, the results 

for an individual species may apply to multiple fish stocks in instances where a species is 

managed as more than one stock. The results of this assessment are not generalizable to 

all fish and invertebrate species in this region or elsewhere.

Walleye Pollock

Walleye pollock are a member of the cod 

family and have a speckled coloring that helps 

them blend with the seafloor to avoid 

predation. They are a schooling fish distributed 

broadly in the North Pacific Ocean and in the 

Bering Sea, with the largest concentrations in 

the United States being found in the eastern 

Bering Sea. Walleye pollock are cooperatively 

managed by the National Marine Fisheries 

Service’s (NMFS) Alaska region and the North 

Pacific Fishery Management Council. The 

pollock fishery is the largest commercial 

fishery by volume in the United States, and in 

2014, its commercial harvest was valued at 

approximately $399.9 million, according to 

NMFS data.

Sources: NMFS documentation (text); 

http://www.fishwatch.gov/ (image). | GAO-16-827 
had climate vulnerability assessments under way for species in its other 

four regions, according to agency officials.

Page 18 GAO-16-827 Federal Fisheries Management

35 The assessment in the 

Greater Atlantic region found that approximately half of the 82 species 

assessed in the region were estimated to have a high or very high 

vulnerability to climate change, with the other half having low or moderate 

vulnerability.36 The assessment defined climate vulnerability as the extent 

to which the abundance or productivity of a species could be affected by 

climate change and natural long-term variability in ocean conditions.37

Similarly, more than half of the species were estimated to have a high or 

very high potential to shift their distribution in response to projected 

changes in the climate. The assessment also provided a summary of the 

existing scientific knowledge about the expected effects on different 

species in the region but did not quantify the magnitude of the expected 

effects for individual species. NMFS officials told us that the assessment 

was not designed to provide that type of quantitative information. Instead, 

the officials said the information provided by the assessments could be 

used to help determine which species should be the subject of additional 

research to help quantify potential climate effects in the future. The 

vulnerability assessment completed in the Greater Atlantic region 

provides illustrations of the range of ways that species may be affected by 

climate change, as reflected in the following examples.

 

35The officials said that they expect to publish the results of these assessments in 2017 or 

2018, depending on the region.

36The assessment noted that the level of certainty for the estimates of species’ climate 

vulnerability varied between species, ranging from very high to low. The assessment 

generally focused on modeled changes in surface ocean conditions (i.e., changes in the 

upper 10 meters of the ocean). Changes in bottom ocean conditions are not as well 

understood, but may be important for some bottom-dwelling species, according to NMFS 

officials.

37The assessment estimated that some vulnerable species will be negatively affected by 

climate change and that others will experience neutral or positive effects. 
· Atlantic cod. According to the NMFS climate vulnerability 

assessment, the abundance of Atlantic cod is likely to be negatively 

affected by warming ocean temperatures in the Northeast. 

Specifically, the assessment indicated that warmer ocean 

temperatures may be linked with a lower number of juvenile cod that 

survive and grow to a size sufficient to enter the fishery each year. 

The assessment also found that continued ocean warming could 

produce less-favorable habitat conditions for cod in the southern end 

of its range. Atlantic cod have experienced a decline in abundance in 

recent decades, and warming ocean temperatures may have 

contributed to this decline, according to NMFS and Council officials in 

the Greater Atlantic region. The officials further indicated, however, 

that the extent to which changing temperatures played a role in the 

cod decline is unclear because it is difficult to isolate this factor from 

other contributing factors, such as overfishing.

Page 19 GAO-16-827 Federal Fisheries Management

38

 

38As a result of the decline in abundance of Atlantic cod and other groundfish stocks in the 

Northeast, the Department of Commerce determined in 2012 that a commercial fishery 

failure had occurred in the Northeast Multispecies Groundfish Fishery. In fiscal year 2014, 

Congress appropriated $75 million for fishery disaster assistance in the United States, and

NMFS obligated $32.8 million of that amount for the declared fishery disaster in the 

Northeast Multispecies Groundfish Fishery. Groundfish are fish that live on, in, or near the 

bottom of the body of water they inhabit. Thirteen groundfish species are managed under 

the Northeast Multispecies Groundfish Fishery, including Atlantic cod, Atlantic halibut, and 

yellowtail flounder.

Atlantic Cod

Atlantic cod have a large head, blunt snout, 

and a distinct barbel (a whisker-like organ, like 

on a catfish) under the lower jaw. Cod live 

near the ocean floor along rocky slopes and 

ledges and prefer to live in cold water. In the 

United States, cod range from the Gulf of 

Maine to Cape Hatteras, North Carolina, and 

are most commonly found off the coast of 

Cape Cod, Massachusetts, and in the western 

Gulf of Maine. Cod are cooperatively 

managed by the National Marine Fisheries 

Service’s (NMFS) Greater Atlantic region and 

the New England Fishery Management 

Council. In 2014, the Atlantic cod commercial 

harvest was valued at approximately $9.4 

million, according to NMFS data. Atlantic cod 

have been an important commercial fish stock 

based on the historical volume and value of 

the fish caught in the Northeast.

Sources: NMFS documentation (text); 

http://www.fishwatch.gov/ (image). | GAO-16-827
· Black sea bass. The distribution of the northern stock of black sea 

bass, historically found in the Mid-Atlantic, has shifted northward in

recent decades, according to NMFS officials in the Greater Atlantic 

region. This trend is likely to continue as ocean temperatures warm 

and become more favorable for the fish, according to the NMFS 

climate vulnerability assessment. The assessment also indicated that 

the abundance of black sea bass in more northern areas will likely 

increase as temperatures warm and more spawning occurs. 

According to NMFS and Council officials and other fisheries 

stakeholders, changes in the abundance and distribution of black sea 

bass could present a challenge for fisheries managers because 

commercial fishing rights have been allocated to states based on 

historical catch data that may not reflect where the fish are found in 

the future.

Page 20 GAO-16-827 Federal Fisheries Management

Black Sea Bass

Black sea bass are usually black with a 

slightly paler belly and a dorsal fin that is 

marked with a series of white spots and 

bands. Black sea bass commonly inhabit rock 

bottoms near pilings, wrecks, and jetties. 

Along the East Coast, black sea bass are 

divided into two fish stocks for management 

purposes. The stock found north of Cape 

Hatteras, North Carolina, is cooperatively 

managed by the National Marine Fisheries 

Service’s (NMFS) Greater Atlantic region, the 

Mid-Atlantic Fishery Management Council, 

and the Atlantic States Marine Fisheries 

Commission. The southern stock is 

cooperatively managed by NMFS, the South 

Atlantic Fishery Management Council, and the 

Atlantic States Marine Fisheries Commission. 

In 2014, the black sea bass commercial 

harvest was valued at approximately $8.6 

million, according to NMFS data.

Sources: NMFS and Atlantic States Marine Fisheries 

Commission documentation (text); http://www.fishwatch.gov/

(image). | GAO-16-827
· American lobster. The overall effect of climate change on lobster 

abundance is estimated to be neutral, as population decreases in the 

southern portion of its range have been offset by increases in the 

north, according to the NMFS climate vulnerability assessment. NMFS 

officials in the Greater Atlantic region said that these population 

changes are believed to be driven in large part by warming ocean 

temperatures. Specifically, officials said that as ocean conditions in 

southern New England have become less favorable to lobsters 

because of increasing ocean temperatures, the abundance of the 

southern stock has declined.

Page 21 GAO-16-827 Federal Fisheries Management

39 In contrast, the abundance of the 

northern stock has increased as temperature changes in the Gulf of 

Maine (where waters are generally colder) have produced more 

favorable conditions for lobster. NMFS has not been able to quantify 

the magnitude of expected future changes in lobster abundance in the 

region, however, in part because it is difficult to accurately forecast 

changes in ocean temperatures more than a few months out, 

according to agency officials. Additionally, NMFS officials indicated 

that changing ocean conditions can affect the timing of biological 

events in the lobster’s life cycle, which may subsequently alter the 

seasonal abundance of the stocks in a way that may cause 

disruptions to the fishing industry. For instance, in 2012, warmer-thanusual ocean temperatures in the Gulf of Maine resulted in American 

lobsters growing to market size earlier than usual, according to NMFS 

documentation. As a result, lobsters were harvested early, but some 

lobster processing facilities were not yet ready to receive them, which 

led to an abundance of supply for the fishermen and a drop in the 

market price they received for their harvest.

 

39In response to declining lobster populations in southern New England, in recent years

the Secretary of Commerce has issued a number of regulations and the Atlantic States 

Marine Fisheries Commission has imposed measures, such as closed seasons in certain 

areas, more stringent standards about the size of harvestable lobsters, and reductions in 

the number of traps allowed for harvesting. 

American Lobster

The American lobster is a crustacean with a 

large shrimp-like body with eight legs and two 

claws. Lobster live on the ocean floor and are 

most abundant in coastal waters from Maine 

through New Jersey, and offshore from Maine 

through North Carolina. The lobster fishery 

has northern and southern stocks that are 

cooperatively managed by the National Marine 

Fisheries Service’s (NMFS) Greater Atlantic 

region and the member states of the Atlantic 

States Marine Fisheries Commission. In 2014, 

lobster’s commercial harvest was valued at 

approximately $567.3 million, which made it 

one of the most economically valuable 

fisheries in the country that year, according to 

NMFS data.

Sources: NMFS and Atlantic States Marine Fisheries 

Commission documentation (text); http://www.fishwatch.gov/

(image). | GAO-16-827
Through the questionnaire responses and our interviews, NMFS and 

Council officials identified several challenges to better understand the 

existing and anticipated effects of climate change on fish stocks as well 

as efforts they are taking to address some of these challenges, including:

· Understanding how climate change may affect fish stocks. NMFS 

and most of the Councils indicated that a significant challenge they 

face is better understanding the relationship between changes in 

ocean conditions and the processes that drive how fish will react to 

those changes. NMFS officials explained that it can be difficult, for 

instance, to understand how water temperature changes may affect 

the biology of specific fish stocks or may indirectly affect their habitat 

and interactions with other species within that habitat. Officials from 

one NMFS region said that they do not have a sufficient 

understanding of the processes that drive fish stock productivity—

including their birth, growth, and death rates—in their region, or how 

those processes may be affected by climate change. Officials from 

several other NMFS regions and Councils shared similar views and 

noted that this challenge limits their ability to understand the overall 

effects that climate change may have on different fish stocks.

· Availability of baseline data. NMFS and several of the Councils 

reported that insufficient baseline data at times limit their ability to 

predict the effects of various changes in the climate on fish stocks. 

Baseline data include oceanographic information, such as water 

temperature in different regions and depths; information about a fish 

stock, such as temperature preference and spawning history; and 

ecological information, such as the type of plants or animals available 

as a food source for a particular stock or its role in a food web. For 

example, NMFS officials told us that sea surface temperature data are 

widely available in most regions but that data on subsurface 

temperatures are limited. The officials attributed the difference in the 

availability of these two types of data to the ability to use satellites to 

measure sea surface temperatures, whereas the collection of 

subsurface temperature data is more difficult and requires 

measurements to be taken directly from the ocean. NMFS officials 

said that the lack of subsurface temperature data limits their ability to 

research and determine potential effects of changing temperatures on 

bottom-dwelling fish stocks, such as the American lobster. The 

officials told us that NOAA has increased its efforts to utilize 

technologies such as ocean gliders—autonomous underwater 

vehicles used to collect ocean data—to track subsurface ocean 

conditions and collect additional baseline data. For example, in 2014 

NOAA partnered with other scientists to launch two ocean gliders in 

Page 22 GAO-16-827 Federal Fisheries Management

NMFS and the Councils 

Identified Several 

Challenges to Better 

Understand the Effects of 

Climate Change on Fish 

Stocks
the Gulf of Alaska to collect data for 5 months on water temperature, 

salinity, and dissolved oxygen, among other things.

· Distinguishing between climate change and other factors. It can 

be challenging to determine whether a change in a fish stock’s 

abundance or distribution is caused by climate change; natural 

variation in the oceans; or other human or environmental factors, such 

as overfishing or pollution, according to NMFS and some Council 

officials. Isolating the effects of climate change from other factors is 

difficult, and the complexities of trying to understand the ways in 

which these factors interact also present challenges, according to the 

officials. For example, NMFS officials in the Greater Atlantic region 

said that populations of summer flounder have increased in recent 

years after experiencing significant declines from overfishing in the

1970s and 1980s, and that summer flounder are being found in 

greater numbers in northern areas, such as the Gulf of Maine. The 

officials said that changes in fishing levels are likely driving the 

increase in summer flounder abundance and their increased presence 

in northern areas, but also suggested that warming ocean 

temperatures may have played a role.

· Modeling capabilities. NMFS and most of the Councils identified 

limitations in climate and fisheries modeling capabilities as a 

challenge to better understand the effects of climate change on 

fisheries. For example, according to NMFS officials, one important 

step to improving the ability to project the effects of climate change on 

specific fish stocks will be to downscale global ocean climate models, 

such as models of changes in ocean temperatures, to more regional 

and local levels that can then be used to assess climate effects on the 

fish stocks that inhabit those locations.

Page 23 GAO-16-827 Federal Fisheries Management

40 Agency officials described 

this type of information as foundational knowledge that is generally 

not yet available across the NMFS regions, in part because it is 

resource intensive to develop. The officials said that NMFS considers 

the development of downscaled climate models that can be used to 

support fisheries management to be a critical need, and that efforts 

are under way to develop such models in some NMFS regions. For 

example, NMFS is funding a project to help downscale global climate 

models for some of the major rivers and estuaries in the Northeast, 

 

40In this context, downscaling involves, among other things, adding finer spatial detail to 

global climate models of projected changes in ocean conditions. 

Summer Flounder

Summer flounder are flatfish, with both eyes 

located on the left side of the body when 

viewed from above, with the dorsal fin facing 

up. Adult summer flounder spend most of their 

lives on or near the seafloor, burrowing into 

the sand. In the United States, summer 

flounder are found from the Gulf of Maine 

through North Carolina. The stock is 

cooperatively managed by the National Marine 

Fisheries Service’s (NMFS) Greater Atlantic 

region, the Mid-Atlantic Fishery Management 

Council, and the Atlantic States Marine 

Fisheries Commission. Summer flounder are 

one of the most sought after commercial and 

recreational fish along the Atlantic coast, and 

in 2014, the commercial harvest was valued at 

approximately $32.3 million, according to 

NMFS data.

Sources: NMFS, Mid-Atlantic Fishery Management Council, 

and Atlantic States Marine Fisheries Commission 

documentation (text); http://www.fishwatch.gov/ (image). | 

GAO-16-827
such as the Chesapeake Bay, that are crucial habitats for many 

commercial, recreational, and protected species.

· Resources. NMFS and most of the Councils identified constrained 

resources as a challenge to expanding climate-related data collection 

and analysis efforts. For instance, according to NMFS officials at one 

Fisheries Science Center, developing climate science for fisheries 

management requires extensive new modeling to assess and project 

current and future fishery conditions, including how fish stock 

abundance and distribution may change under changing physical and 

chemical ocean conditions. However, the officials said that staff 

capacity to conduct this work is limited because of existing modeling 

demands for stock assessments. Similarly, officials from one Council 

told us that additional staff and resources would be required to 

incorporate climate-related information into their work.

NMFS has developed a strategy to help it and the Councils incorporate 

climate information—such as information on changes in ocean 

temperatures and acidity levels and the risks to fish stocks associated 

with those changes—into the fisheries management process, but is in the 

early stages of implementing the strategy. Through our analysis, we 

found that NMFS and the Councils have generally not incorporated 

climate information into the fisheries management process to date 

because the information they have on the effects of climate change on 

most fish stocks has not been sufficient. However, recognizing the 

importance of further developing climate information and incorporating it 

into the fisheries management process, NMFS published its NOAA 

Fisheries Climate Science Strategy in August 2015.

Page 24 GAO-16-827 Federal Fisheries Management

41 The Strategy is 

intended to support efforts by the agency and its partners to increase the 

production, delivery, and use of climate information in managing fish and 

other living marine resources. According to the Strategy, failing to 

adequately incorporate climate change considerations into fisheries 

management and conservation efforts could cause those efforts to be 

ineffective, produce negative results, or miss opportunities. Determining 

how information on the effects of climate change can be incorporated into 

 

41Link, Griffis, and Busch, NOAA Fisheries Climate Science Strategy. The Strategy

applies to all of the living marine resources under NMFS’ responsibility, including federally 

managed fish and shellfish, protected marine mammals, and species listed as threatened 

or endangered under the Endangered Species Act.

NMFS Developed a 

Strategy to Help 

Incorporate Climate 

Information into 

Fisheries 

Management, but It Is 

in the Early Stages of 

Implementation
the fisheries management process is a key question that NMFS must 

address, according to the Strategy.

The Strategy lays out a national framework that is to be regionally tailored 

and implemented. NMFS officials said that the agency’s regions 

(including its regional offices and regional Fisheries Science Centers) will 

have primary responsibility for implementing the Strategy, and those 

offices are in the process of developing regional action plans to describe 

how they will do so. NMFS has directed its regions to develop regional 

action plans that identify specific actions each region will take over the 

next 5 years to implement the Strategy and include the region’s 

assessment of its priorities and available resources, among other things. 

As of July 2016, four of NMFS’ five regions had released draft versions of 

their regional action plans for public comment, and agency officials said 

that they expect all of the regions to finalize their plans by October 2016. 

The officials said that NMFS headquarters has provided input on the draft 

plans and will work with the NMFS Science Board to review and approve 

the final plans.

Page 25 GAO-16-827 Federal Fisheries Management

42

The Strategy recognizes the importance of incorporating climate 

information into the fisheries management process but does not provide 

specific guidance on how this is to be done. For example, the Strategy 

notes the importance of factoring climate information into stock 

assessments but does not include specific guidance on how such 

information should be incorporated into developing the assessments. 

Historically, fish stock assessments primarily considered the effects of 

fishing when estimating the abundance of individual fish stocks and have 

not accounted for ecosystem factors, including effects from changes in 

the climate. This traditional approach has been effective for assessing 

present and historical abundance levels but may not be effective in 

forecasting future levels because it does not account for effects related to 

changing environmental conditions, according to NMFS documentation. 

NMFS and Council officials said that factoring climate information more 

widely into stock assessments in the future will be important, given the 

changing climate conditions and particularly because stock assessments 

often provide the scientific basis for management decisions, including 

 

42The NMFS Science Board is made up of the NMFS Chief Science Advisor, the Director 

of Science and Technology, and the science directors from each of the regional Fisheries 

Science Centers.
setting annual catch limits. The Strategy also states that including 

climate-related data to inform reference points (the limits or targets used 

to guide management decisions), where appropriate, is critical to avoid 

misaligned management targets for fish stocks, but the Strategy does not 

provide specific guidance on how this is to be done. In addition, the 

Strategy calls for NMFS to complete climate vulnerability assessments for 

all regions as an initial priority action but does not specify how NMFS 

regions and the Councils should use the results of the assessments to 

inform management decisions or incorporate them into the fisheries 

management process.

Page 26 GAO-16-827 Federal Fisheries Management

43

Without developing guidance on how climate information is to be 

incorporated into specific aspects of the fisheries management process, 

NMFS does not have reasonable assurance that all of its regions and the 

Councils will consistently factor climate-related risks into fisheries 

management. Under federal standards for internal control, agencies are 

to clearly document internal controls, and the documentation is to appear 

in management directives, administrative policies, or operating manuals.44

In addition, according to the International Organization for 

Standardization, for risk management to be effective, it is important for 

information on risks to be included as a part of decision making.45

Moreover, developing guidance would be consistent with actions NMFS 

has taken for other parts of its mission, according to the agency’s Climate 

Change Coordinator. The official noted that in January 2016, NMFS 

developed guidance on using climate change information in the agency’s 

Endangered Species Act decisions, which could serve as a model for the 

fisheries management process.46 The guidance provides direction on how 

climate information should be incorporated into Endangered Species Act 

 

43The Strategy states that these assessments are important tools to help identify species 

at higher risk in a changing climate, as well as some reasons for these risks and key 

information needs to better understand the risks.

44GAO/AIMD-00-21.3.1. We have revised and reissued our standards for internal control, 

with the new revision effective as of October 1, 2015. See GAO-14-704G.

45See International Organization for Standardization, ISO 31000 Risk Management—

Principles and Guidelines (2009).

46NMFS subsequently revised this guidance in June 2016. See National Marine Fisheries 

Service, Revised Guidance for Treatment of Climate Change in NMFS Endangered 

Species Act Decisions, NMFS Memorandum (Silver Spring, Md: June 17, 2016). 
management decisions and what types of climate information should be 

used, among other things. NMFS has not yet developed similar guidance 

for fisheries management because doing so was not previously 

considered to be an immediate priority given the agency’s limited 

information on the anticipated effects of climate change on fish stocks 

and the near-term focus of most fisheries management decisions, 

according to NMFS’ Climate Change Coordinator. The official said, 

however, that as knowledge about the effects of climate change on 

fisheries has progressed over time, NMFS has found an increased and 

more pressing need to begin preparing for these effects in the near term. 

By developing guidance on how the NMFS regions and Councils are to 

incorporate climate information into different parts of the fisheries 

management process, NMFS may help ensure consistency in how its 

regions and the Councils factor climate-related risks into fisheries 

management decision making.

In addition, the Strategy lays out overall objectives to help identify the 

agency’s climate information needs and help better ensure effective 

management in a changing climate, but does not contain agency-wide 

performance measures to track progress in achieving the Strategy’s 

objectives. Specifically, the Strategy lays out seven interrelated, priority 

objectives (see table 1).

Page 27 GAO-16-827 Federal Fisheries Management
Table 1: NOAA Fisheries Climate Science Strategy (Strategy) Priority Objectives

Page 28 GAO-16-827 Federal Fisheries Management

Objective Description

Identify reference points for managing 

living marine resources that appropriately 

incorporate climate information

The Strategy describes reference points as the thresholds upon which living marine 

resource management decisions are made, and cites the importance of incorporating 

climate information into reference points as a critical part of responding to the effects of 

climate change on fisheries. 

Identify robust strategies for managing 

living marine resources under changing 

climate conditions

The Strategy calls for NMFS to help identify management strategies that will be effective 

under a wide range of future ocean conditions and to evaluate the strengths and 

weaknesses of alternative approaches to managing living marine resources in the face of 

a changing climate.

Design adaptive decision processes that 

can incorporate and respond to changing 

climate conditions

This objective focuses on, among other things, developing fisheries management decision 

processes that are adaptive and flexible under changing conditions and identifying where 

and how climate information could best be incorporated into those processes.

Identify future states of ecosystems, living 

marine resources, and the human 

communities that depend on them in a 

changing climate

In this objective, the Strategy cites the importance of developing robust, model-based 

projections of future ocean conditions and the ways in which changing conditions will 

affect ecosystems (marine, coastal, and freshwater), living marine resources, and human 

communities.

Identify the mechanisms of climate 

change impacts on ecosystems, living 

marine resources, and the human 

communities that depend on them

The Strategy calls for steps to be taken, such as conducting research and vulnerability 

assessments, to, among other things, better understand how and why climate change can 

affect ecosystems, living marine resources, and dependent human communities, and to 

help identify species at higher risk in a changing climate.

Track trends in ecosystems, living marine 

resources, and the human communities 

that depend on them and provide early 

warning of change

This objective focuses on the importance of (1) monitoring the characteristics of marine 

and coastal ecosystems, living marine resources, and human communities; (2) developing 

physical, biological, and socioeconomic indicators for tracking trends related to climate 

change and for providing early warning of climate change impacts; and (3) regularly 

reporting on climate-related monitoring data and indicators, such as through ecosystem 

status reports.

Build and maintain the science 

infrastructure needed to fulfill NMFS’

mandates (such as its responsibilities 

under the Magnuson-Stevens Fishery 

Conservation and Management Act of 

1976, as amended) under changing 

climate conditions

The Strategy cites the need to improve, and in some cases expand, NMFS’ scientific 

infrastructure—including staffing, computing systems, and partnerships with entities such 

as state agencies and academia—to successfully implement the Strategy.

Legend:

NMFS: National Marine Fisheries Service

NOAA: National Oceanic and Atmospheric Administration

Source: GAO analysis of the NOAA Fisheries Climate Science Strategy. | GAO-16-827

According to NMFS officials, the agency recognizes the potential benefit 

of developing a comprehensive set of agency-wide performance 

measures for the Strategy, but it has not specified when or how it may do 

so because it is first focusing on completing the regional action plans. 

NMFS has directed its regions to include performance measures in their 

regional action plans outlining how they will implement the Strategy, and 

agency officials told us that once the regional action plans are finalized in 

October 2016, NMFS plans to revisit whether to develop agency-wide 
performance measures for the Strategy. We have previously reported on 

the importance of agencies using performance measures to track 

progress in achieving their goals and to inform management decisions.

Page 29 GAO-16-827 Federal Fisheries Management

47

Moreover, the Government Performance and Results Act of 1993, as 

amended, requires federal agencies to establish performance goals and 

related performance measures to track progress in annual agency 

performance plans, among other things.48 While these requirements apply 

at the departmental level (e.g., Department of Commerce), we have 

previously found that they also serve as leading practices in component 

agencies, such as at NMFS, to assist with planning for individual 

programs or initiatives that are particularly challenging.49 This is also in 

line with federal standards for internal control, which identify the 

establishment and review of performance measures as a control activity 

that can help ensure that management’s directives are carried out and 

that actions are taken to address risks, among other things.50

According to NMFS guidance, the regional action plans are to identify 

performance measures to document progress in implementing the 

Strategy at the regional level. In reviewing the four draft regional action 

plans that had been released as of July 2016, we found that three of the 

draft plans contained proposed performance measures. Specifically, we 

found that the measures each of the three regions proposed included 

some key attributes of successful performance measures that we have 

previously identified, such as being aligned with the Strategy’s objectives 

and having limited overlap (see app. II for the full list of key attributes).51

However, most of the measures did not contain other key attributes. For 

 

47For example, see GAO, Managing for Results: Enhancing Agency Use of Performance 

Information for Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 

2005), and GAO-16-131.

4831 U.S.C. § 1115(b).

49For example, see GAO-16-131. In addition, we have previously found that leading public 

sector organizations seek to establish clear hierarchies of performance goals and 

measures that link the goals and measures for each organizational level to successive 

levels, and that doing so can help federal agencies successfully measure their 

performance. See GAO/GGD-96-118 and GAO/GGD/AIMD-10.1.18.

50GAO/AIMD-00-21.3.1. We have revised and reissued our standards for internal control, 

with the new revision effective as of October 1, 2015. See GAO-14-704G.

51For more information on the key attributes, see GAO-03-143.
example, nearly all of the proposed measures contained in the three draft 

plans did not include measurable targets, another key attribute of 

successful performance measures. In some cases, the proposed 

measures identified quantitative data to be tracked—such as the number 

of stock assessments or annual catch limits that include climate 

information—but there were no numerical targets identified that could 

serve as a means for assessing progress. We have previously found that 

including measurable targets in performance measures helps in 

assessing whether performance is meeting expectations.

Page 30 GAO-16-827 Federal Fisheries Management

52 NMFS officials 

said that they recognized the importance of developing meaningful 

performance measures. By incorporating key attributes associated with 

successful performance measures in the final performance measures 

developed for the plans and assessing whether agency-wide performance 

measures may also be needed, NMFS may be in a better position to 

determine the extent to which the objectives of the Strategy overall are 

being achieved.

Changing environmental conditions in the oceans, such as warming 

temperatures, could affect the abundance and distribution of federally 

managed fisheries in ways that may pose risks to the communities and 

industries that depend on harvesting the affected fish. Such risks also 

have potential implications for the federal government’s fiscal exposure 

because commercial fishery failures may result in the federal government 

providing fishery disaster assistance. NMFS has taken steps to help it 

and the Councils better understand how climate change may affect the 

fish stocks they manage, even as they face challenges related to the 

availability of data and resources, among others. Recognizing the 

importance of incorporating climate considerations into the fisheries 

management process, NMFS has also developed its NOAA Fisheries 

Climate Science Strategy to help increase the production, delivery, and 

use of climate information. However, NMFS is in the early stages of 

implementing the Strategy and has not developed guidance to specify 

how climate information is to be incorporated into different parts of the 

fisheries management process, such as in developing stock assessments 

or reference points. Developing such guidance would align with federal 

standards for internal control and may help NMFS ensure consistency in 

 

52GAO-03-143.

Conclusions
how its regions and the Councils factor climate-related risks into fisheries 

management decision making.

Additionally, NMFS has directed its regions to include performance 

measures in their regional action plans outlining how they will implement 

the Strategy, but the proposed measures in the draft plans we reviewed 

did not include some key attributes of successful performance measures, 

such as containing measurable targets. Moreover, NMFS has not 

developed agency-wide performance measures to assess progress in 

meeting the Strategy’s overall objectives, instead choosing to wait to 

complete the regional action plans before determining whether such 

measures may be necessary. By incorporating key attributes associated 

with successful performance measures in the final performance measures 

developed for the plans and assessing whether agency-wide performance 

measures may also be needed, NMFS may be in a better position to 

determine the extent to which the objectives of the Strategy overall are 

being achieved.

To help NMFS and the Councils incorporate climate information into the 

fisheries management process and better manage climate-related risks, 

we recommend that the Secretary of Commerce direct NOAA’s Assistant 

Administrator for Fisheries to take the following two actions:

· Develop guidance to direct the NMFS regions and Councils on how 

climate information should be incorporated into different parts of the 

fisheries management process.

· In finalizing the regional action plans for implementing the NOAA 

Fisheries Climate Science Strategy, (1) incorporate the key attributes 

associated with successful performance measures in the final 

performance measures developed for the plans and (2) assess 

whether agency-wide performance measures may be needed to 

determine the extent to which the objectives of the Strategy overall 

are being achieved, and develop such measures, as appropriate, that 

incorporate the key attributes of successful performance measures.

We provided a draft of this report for review and comment to the 

Department of Commerce. In written comments (reproduced in appendix 

III), the Department of Commerce and NOAA agreed with our 

recommendations. NOAA stated that the report provides a good summary 

of climate-related effects on the nation’s fishery resources and the 

challenges to understanding and responding to climate effects in fisheries 

management. NOAA agreed with our recommendation to develop

Page 31 GAO-16-827 Federal Fisheries Management

Recommendations for 

Executive Action

Agency Comments

and Our Evaluation
guidance on how climate information should be incorporated into different 

parts of the fisheries management process, and outlined several ongoing 

and planned efforts to help address the recommendation. For example, 

NOAA stated that NMFS recently released a policy and related agency 

directives intended to help clarify if and when fishing allocations may 

need to be reviewed or adjusted, such as when fish stocks shift 

distribution in response to a changing climate. 

In addition, NOAA agreed with our recommendation to incorporate key 

attributes associated with successful performance measures in the final 

performance measures included in the regional action plans for the 

Strategy and to assess whether agency-wide performance measures for 

the Strategy may be needed. NOAA stated that NMFS will review the 

draft regional action plans and take action to ensure that the performance 

measures in the final plans include key attributes of successful measures. 

Following completion of the regional action plans, NOAA indicated that 

NMFS will also assess the need for agency-wide measures to track and 

evaluate achievement of the Strategy’s objectives and will develop such 

measures as appropriate. NOAA also provided technical comments, 

which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Commerce, 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 members who made key 

contributions to this report are listed in appendix IV.

Anne-Marie Fennell

Director, Natural Resources and Environment

Page 32 GAO-16-827 Federal Fisheries Management
Appendix I: Objectives, Scope, and 

Methodology

This report examines (1) information the National Marine Fisheries 

Service (NMFS) and the Regional Fishery Management Councils 

(Council) have about the existing and anticipated effects of climate 

change on federally managed fish stocks and challenges they face to 

better understand these effects and (2) efforts NMFS has taken to help it 

and the Councils incorporate climate information into the fisheries 

management process. For both objectives, to understand the legal 

framework for fisheries management in the United States, we reviewed 

the Magnuson-Stevens Fishery Conservation and Management Act of 

1976, as amended, which governs marine fisheries management in 

federal waters, including both commercial and recreational fishing.

Page 33 GAO-16-827 Federal Fisheries Management

1 We 

also reviewed our past work on fisheries management, climate change 

adaptation, and risk management.2

To examine information NMFS and the Councils have about the effects of 

climate change on federally managed fish stocks and the challenges they 

face to better understand these effects, we reviewed scientific studies and 

documentation prepared by NMFS, the Councils, and others such as 

academics. These documents included studies about the existing and 

anticipated effects of climate change on the ocean and particular fish 

stocks and key fisheries management documents, such as stock 

assessments and fisheries management plans. We also developed a 

questionnaire of open-ended questions about the information NMFS and 

the Councils have on the effects of climate change on the fish stocks they 

manage and any challenges they face to better understand these effects, 

among other things. We disseminated the questionnaire to the regional 

administrator of each NMFS region and the executive director of each 

Council. All five regions and eight Councils responded to the 

 

1Pub. L. No. 94-265 (1976) (codified as amended at 16 U.S.C. §§ 1801-1884). 

2See, for example, GAO, Recreational Fisheries Management: The National Marine 

Fisheries Service Should Develop a Comprehensive Strategy to Guide Its Data Collection 

Efforts, GAO-16-131 (Washington, D.C.: Dec. 8, 2015); Climate Change: Future Federal 

Adaptation Efforts Could Better Support Local Infrastructure Decision Makers, 

GAO-13-242 (Washington, D.C.: Apr. 12, 2013); Ocean Acidification: Federal Response 

Under Way, but Actions Needed to Understand and Address Potential Impacts, 

GAO-14-736 (Washington, D.C.: Sept. 12, 2014); and Federal Supply Chains: 

Opportunities to Improve the Management of Climate-Related Risks, GAO-16-32 

(Washington, D.C.: Oct. 13, 2015).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

questionnaire.

Page 34 GAO-16-827 Federal Fisheries Management

3 To characterize officials’ views presented in the 

questionnaire responses, two analysts analyzed the narrative responses 

to these questions and identified key themes. In describing these 

responses in the report, we attribute the information to NMFS and Council 

officials.

We conducted interviews, either in person or by telephone, with officials 

from two NMFS regions (Greater Atlantic and Alaska) and representatives 

of four Councils (New England, Mid-Atlantic, South Atlantic, and North 

Pacific) and the Atlantic States Marine Fisheries Commission about their 

understanding of the effects of climate change on fish stocks and any 

challenges they face to better understand these effects. We selected 

these entities to interview because they are involved in managing 

fisheries in regions of the country that are expected to experience 

significant effects from climate change, according to NMFS 

documentation and our discussions with agency officials. We also 

interviewed representatives from 11 stakeholder organizations 

representing fishing, conservation, and Alaska Native interests to obtain a 

broader range of views on the existing and anticipated effects of climate 

change on fish stocks and the efforts of NMFS and the Councils to better 

understand these effects. We selected these entities to reflect geographic 

diversity and different types of involvement in fisheries management 

issues.

We analyzed a nongeneralizable sample of seven fish species as case 

studies from NMFS’ Greater Atlantic and Alaska regions. These species 

were the American lobster, Atlantic cod, black sea bass, northern rock 

sole, spiny dogfish, summer flounder, and walleye pollock. We selected 

these species to reflect variation in the value and volume of commercial 

harvests, based on NMFS’ commercial fisheries data from 2008 to 2013, 

and a range of potential effects of climate change. We assessed the 

reliability of NMFS’ commercial fisheries data and found the data to be 

sufficiently reliable for the purpose of selecting our case study species. 

The case study species are intended to provide illustrative examples and 

cannot be generalized to the entire universe of fish species. For each of 

our case study species, we reviewed applicable stock assessments and 

 

3NMFS’ regional offices and regional Fisheries Science Centers worked together to 

produce coordinated regional responses to the questionnaire.
Appendix I: Objectives, Scope, and 

Methodology

fisheries management plans. We also obtained written information from 

the applicable NMFS Fisheries Science Centers and Councils in the 

regions on the extent to which each species is expected to change its 

distribution, abundance, or the timing or location of biological events as a 

result of the effects of climate change. In addition, we interviewed NMFS 

scientists involved in studying our case study species at NMFS’ Alaska 

Fisheries Science Center and the Northeast Fisheries Science Center. 

We used the information collected through these case studies to provide 

examples in the report.

To examine the efforts NMFS has taken to help it and the Councils 

incorporate climate information into the fisheries management process, 

we analyzed the questionnaire responses provided by the NMFS regions 

and Councils and reviewed agency and Council documentation, including 

planning documents, analyses, and reports with information on the 

fisheries management process. As part of our interviews with officials 

from NMFS’ headquarters, regional offices, and regional Fisheries 

Science Centers, as well as representatives from the Councils and 

nonfederal stakeholders, we discussed the steps taken to assess climaterelated risks to fisheries and the extent to which climate information has 

been incorporated into different parts of the fisheries management 

process. We focused our analysis on the process for setting annual catch 

limits and related management actions, because developing these limits 

is required for all fisheries managed by the Councils and NMFS considers 

it a major part of the fisheries management process.

Page 35 GAO-16-827 Federal Fisheries Management

4

In performing this work, we examined NMFS’ NOAA Fisheries Climate 

Science Strategy (Strategy) to assess the agency’s plans for increasing 

the production, delivery, and use of climate information for managing 

fisheries and other marine resources. In doing so, we first reviewed the 

draft Strategy (released in January 2014) and stakeholder comments on 

the Strategy submitted during the public comment period. We used this 

analysis to help identify potential issues stakeholders had about the 

Strategy’s design and proposed implementation, and to develop follow-up 

questions for NMFS and Council officials. We reviewed the final version 

of the Strategy after it was released in August 2015 and assessed the 

 

4According to NMFS, other fishery management actions (such as determining essential 

fish habitat) may follow different processes, which we did not assess in this report.
Appendix I: Objectives, Scope, and 

Methodology

Strategy—as well as the four draft regional action plans for implementing 

the Strategy that had been released as of July 2016—against leading 

practices in agencies’ strategic planning and performance measurement 

identified in our previous work based on the requirements of the 

Government Performance and Results Act of 1993, as amended.

Page 36 GAO-16-827 Federal Fisheries Management

5 We 

also compared NMFS’ efforts to incorporate information on climaterelated risks in the fisheries management process to leading risk 

management guidance developed by the International Organization for 

Standardization and GAO’s Standards for Internal Control in the Federal 

Government.

6

 

5For examples of leading practices, see GAO, Tax Administration: IRS Needs to Further 

Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: 

Nov. 22, 2002); Executive Guide: Effectively Implementing the Government Performance 

and Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996); and Agencies’

Annual Performance Plans Under the Results Act: An Assessment Guide to Facilitate 

Congressional Decisionmaking, GAO/GGD/AIMD-10.1.18 (Washington, D.C.: February 

1998). For Government Performance and Results Act of 1993, as amended, see 5 U.S.C. 

§ 306; 31 U.S.C. §§ 1115-1116.

6See International Organization for Standardization, ISO 31000 Risk Management—

Principles and Guidelines (2009), and GAO, Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). We have 

revised and reissued our standards for internal control, with the new revision effective as 

of October 1, 2015. See GAO, Standards for Internal Control in the Federal Government, 

GAO-14-704G (Washington, D.C.: September 2014).
Appendix II: Key Attributes of Successful 

Performance Measures

Measuring performance allows organizations to track the progress they 

are making toward their goals and gives managers critical information on 

which to base decisions for improving their programs. Table 2 presents a 

summary of nine key attributes of successful performance measures 

identified in our prior work, including the potentially adverse 

consequences if they are missing.

Page 37 GAO-16-827 Federal Fisheries Management

1 All attributes are not equal, and failure 

to have a particular attribute does not necessarily indicate that there is a 

weakness in that area or that the measure is not useful; rather, it may 

indicate an opportunity for further refinement.

Table 2: Key Attributes of Successful Performance Measures

Attributes Definitions

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 do 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 could be confusing and misleading to users.

Measurable target Measure has a numerical goal. Cannot tell 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 are inconsistent and add 

uncertainty.

Core program 

activities

Measure covers the activities that an entity is 

expected to perform to support the intent of the 

program.

Not enough information is available in core program areas 

for managers and stakeholders.

Limited overlap Measure should provide new information beyond 

that provided by other measures.

Manager may have to sort through redundant, costly 

information that does not add value.

Balance Balance exists when a suite of measures ensures 

that an organization’s various priorities are covered.

Lack of balance could create skewed incentives when 

measures overemphasize some goals.

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.

Source: GAO | GAO-16-827

Note: The information in this table was drawn from GAO, Tax Administration: IRS Needs to Further 

Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 

2002).

 

1For more information on these attributes, see GAO, Tax Administration: IRS Needs to 

Further Refine Its Tax Filing Season Performance Measures, GAO-03-143 (Washington, 

D.C.: Nov. 22, 2002).

Appendix II: Key Attributes of Successful 

Performance Measures
Appendix III: Comments from the Department 

of Commerce

Page 38 GAO-16-827 Federal Fisheries Management

Appendix III: Comments from the 

Department of Commerce
Appendix III: Comments from the Department 

of Commerce

Page 39 GAO-16-827 Federal Fisheries Management
Appendix III: Comments from the Department 

of Commerce

Page 40 GAO-16-827 Federal Fisheries Management
Appendix IV: GAO Contact and Staff 

Acknowledgments

Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov

In addition to the contact named above, Alyssa M. Hundrup (Assistant 

Director), Stephen D. Secrist (Assistant Director), Mark Braza, Alicia 

Puente Cackley, John Delicath, Heather Dowey, Karen Howard, 

Benjamin T. Licht, Dan C. Royer, Jeanette M. Soares, Levine Thomas, 

Joseph Dean Thompson, Jason Trentacoste, Sarah Veale, and Joshua 

Wiener made key contributions to this report.

Page 41 GAO-16-827 Federal Fisheries Management

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Appendix V: Accessible Data

Page 42 GAO-16-827 Federal Fisheries Management

THE DEPUTY SECRETARY OF COMMERCE

Washington, D.C. 20230

September 16, 2016

Ms. Anne-Marie Fennell

Director, Natural Resources and Environment

U.S. Government Accountability Office

441 G Street, NW

Washington, DC 20548

Dear Ms. Fennell:

Thank you for the opportunity to review and comment on the Government 

Accountability Office's (GAO) draft report titled: Federal Fisheries 

Management: Additional Actions Could Advance Efforts to Incorporate 

Climate Information into Management Decisions (GAO-16-827). The 

Department of Commerce agrees with GAO's recommendations and has 

enclosed the National Oceanic and Atmospheric Administration's 

programmatic comments to the draft report.

If you have any questions, please contact me or Steve Haro, Assistant 

Secretary for Legislative and Intergovernmental Affairs, at (202) 482-

3663.

Sincerely,

Bruce H. Andrews

Appendix V: Accessible Data

(361621)

Agency Comment 

Letter

Text of Appendix III: 

Comments from the 

Department of Commerce

Page 1
Appendix V: Accessible Data

Enclosure

Department of Commerce

National Oceanic and Atmospheric Administration Response to the GAO 

Draft Report Titled

Federal Fisheries Management: Additional Actions Could Advance Efforts 

to Incorporate Climate Information into Management Decisions

(GAO-16-827, September 2016)

General Comments

The report on Federal efforts to address the effects of climate change on 

Federal fisheries management provides a good summary of climaterelated effects on the Nation's valuable fishery resources and the 

significant challenges to understanding and responding to climate effects 

in fisheries management. The report's summary of existing efforts and 

overall findings is well-informed and thorough based on input from the 

National Oceanic and Atmospheric Administration's (NOAA) National 

Marine Fisheries Service (NMFS), Regional Fisheries Management 

Councils (Councils), and others.

NOAA Response to GAO Recommendations

The draft GAO report states, "To help NMFS and the Councils incorporafe 

climate information into the fisheries management process and better 

manage climate-related risks, we recommend that the Secretary of 

Commerce direct NOAA's Assistant Administrator for Fisheries to take the 

following two actions:"

Recommendation 1: "Develop guidance to direct the NMFS Regional 

Offices (Regions) and Councils on how climate information should be 

incorporated into different parts of the fisheries management process."

NOAA Response: NMFS supports this recommendation and looks 

forward to building on current efforts to produce, deliver, and use climaterelated information in fisheries management in partnerships with Councils 

and Commissions. Ongoing and planned efforts that reflect this goal and 

the regionally specific and diverse characteristics of our Nation's fisheries 

include:

Page 43 GAO-16-827 Federal Fisheries Management

Page 2
Appendix V: Accessible Data

· NMFS recently released a Fisheries Allocation and Review Policy and 

two complementary procedural directives intended to clarify when and 

how the eight regional fishery management councils will determine 

whether and when allocations of the fishery resources should be 

reviewed. This policy will help guide Councils and Regions as they 

determine if or how allocations need to be adjusted such as when fish 

stocks shift distribution in response to a changing climate.

· NMFS recently developed a national framework for prioritizing stock 

assessments in each region. This document clarifies how results from 

the climate vulnerability assessments can info,rm the stock 

assessment prioritization process.

· NMFS proposed updated guidance on how to meet the requirements 

of National Standard 1 of the Magnuson-Stevens Act that 

includes information on incorporating ecosystem and environmental 

considerations into management.

· NMFS is working to determine how to incorporate climate change into 

habitat restoration and protection activities including, but not limited 

to, the designation of essential fish habitat (EFH), EFH consultations, 

and on-the-ground habitat restoration projects.

· NOAA's revised NAO 216-6 Companion Manual will provide advice on 

incorporating climate information into NEP A analyses, consistent with 

the Council on Environmental Quality's newly finalized guidance 

document.

Through all of these activities, NMFS will continue to work with the 

Councils, Commissions, and others to identify how best to incorporate 

climate-related information into the fisheries management process.

Recommendation 2: "In finalizing the regional action plans for 

implementing the NOAA Fisheries Climate Science Strategy, (1) 

incorporate the key attributes associated with successful performance 

measures in the final performance measures developed for the plans, and 

(2) assess whether agency-wide performance measures may be needed 

to determine the extent to which the objectives of the Strategy overall are 

being achieved, and develop such measures, as appropriate, that 

incorporate the key attributes of successful performance measures."

NOAA Response: NMFS supports this recommendation. Performance 

measures are a key part of the regional action plans. NMFS will review 

the draft regional action plans and take appropriate action to ensure 

performance measures in the final plans include key attributes of 

successful measures. Following completion of the regional action plans, 

Page 44 GAO-16-827 Federal Fisheries Management

Page 3
Appendix V: Accessible Data

NMFS will assess the need for agency-wide measures to track and 

evaluate achievement of the Strategy objectives, and develop such 

measures as appropriate incorporating key attributes of successful 

performance measures.

Accessible Text for Figure 2: General Steps in the Federal Fisheries Management 

Page 45 GAO-16-827 Federal Fisheries Management

Process

Data collection

The National Marine Fisheries Service (NMFS) and a number of partners 

(such as the fishing industry, state agencies, and academia) conduct 

research and collect data on fish stocks and ocean conditions on an 

ongoing basis to support scientific analyses and to help evaluate the 

results of management actions. Types of data collected can include:

· Catch data – the amount of fish removed from a stock by fishing.

· Abundance data – the number or weight of fish in a stock. 

· Biological data – information on fish size, age, growth, mortality, 

reproductive rates, and other biological information.

· Ecosystem data – information on habitats, species interactions (such 

as predator-prey relationships), physical ocean parameters (such as 

ocean temperature), and other environmental information.

Analysis

NMFS and the Regional Fishery Management Councils (Council) analyze 

data on fish stocks and ocean conditions to develop scientific information 

for use in fisheries management. Such analyses are often performed as 

part of stock assessments (reports that analyze fish population dynamics) 

and produce key information such as:

· Estimates of stock abundance, mortality, reproduction, and 

distribution.

· Determinations of stock status, such as whether a stock is overfished 

(its population size is too low) or has experienced overfishing (its 

harvest rate is too high).

· Reference points, which are limits and targets that are used to guide 

management decisions and assess the status of stocks. For example, 

Accessible Text
Appendix V: Accessible Data

the overfishing limit identifies the catch level above which overfishing 

would occur.

Management actions

NMFS and the Councils use the scientific information from stock 

assessments and other analyses to help inform management actions 

related to harvesting federally managed fish stocks, including: 

· Setting annual catch limits (the amount of fish that can be harvested 

in a year).

· Amending fishery management plans, which, among other things, 

identify management measures (such as fishing season closures or 

restrictions on the number of fish that individuals can catch) to prevent 

catch from exceeding the annual catch limit.

· Determining how to allocate fish stock harvests among fishermen 

(such as dividing a stock’s annual catch limit between the commercial 

and recreational sectors or among various gear groups within a 

fishery).

Page 46 GAO-16-827 Federal Fisheries Management
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