HYDROGRAPHIC 

SURVEYING

NOAA Needs Better 

Cost Data and a 

Strategy for 

Expanding Private 

Sector Involvement in 

Data Collection

Report to Congressional Requesters

June 2017

GAO-17-510

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-510, a report to 

congressional requesters

June 2017

HYDROGRAPHIC SURVEYING

NOAA Needs Better Cost Data and a Strategy for 

Expanding Private Sector Involvement in Data 

Collection

What GAO Found

The Department of Commerce’s National Oceanic and Atmospheric 

Administration (NOAA) uses a three-step process to determine its hydrographic 

survey priorities, according to agency documents and officials. NOAA first 

identifies areas in greatest need of surveying by analyzing data such as seafloor 

depth, shipping tonnage, and the time elapsed since the most recent survey. 

Second, the agency evaluates the availability of funding resources as well as the 

availability and capability of NOAA and private sector hydrographic survey 

vessels. Third, NOAA develops an annual hydrographic surveying plan that 

identifies survey priorities. To help inform the first step in this process, NOAA is 

developing a model to take advantage of new mapping technologies. 

NOAA prepares an annual report comparing the cost of collecting its own 

hydrographic survey data to the cost of procuring data from the private sector but 

does not include all costs in its cost comparisons. Under its standard operating 

procedure, NOAA is to report the full cost of the hydrographic survey program, 

including equipment, maintenance, and administrative costs. GAO’s review of 

NOAA’s cost comparison reports from fiscal years 2006 through 2016, however, 

found that NOAA did not in all instances report complete or accurate cost data. 

For example, NOAA did not include the acquisition of a $24 million vessel in 

2012, and in some cases it did not report certain costs in the year to which those 

costs should be assigned. NOAA officials said they recognized the need to 

improve the agency’s tracking of costs, and they identified actions they intend to 

take but did not always provide information about specific steps to carry out 

these actions or associated time frames. For example, NOAA officials said they 

planned to implement an improved process in fiscal year 2019 for tracking the 

costs of capital assets such as vessels but did not identify specific steps to do 

so. They also said they plan to develop a system to better track maintenance 

costs but did not provide specific details or a time frame to do this. Without 

ensuring that its efforts to improve its cost comparison reports include actions to 

fully track asset and maintenance costs, NOAA may be unable to prepare cost 

comparison reports that reflect the full cost of its survey program, as specified in

the agency’s standard operating procedure. 

NOAA has taken steps to increase private sector involvement in its hydrographic 

data collection program but has not developed a strategy for expanding such 

involvement as required by law. For example, NOAA moved to a centralized 

process for competing and awarding contracts, which NOAA officials said 

reduced administrative costs and contract award time and allowed NOAA to 

increase the number of private sector firms under contract from five to eight. 

However, NOAA did not develop a strategy for expanding its use of the private 

sector to minimize duplication and take maximum advantage of private sector 

capabilities, as required by law. NOAA officials said the agency intends to 

develop such a strategy but must first make improvements in its approach to

comparing its own hydrographic survey costs to those of the private sector. 

However, NOAA officials did not provide specific information about how they 

intend to develop the strategy, what elements it will contain, or when it will be 

completed. Without developing such a strategy, NOAA may have difficulty

minimizing duplication and taking advantage of private sector capabilities. 

View GAO-17-510. For more information, 

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

or fennella@gao.gov. 

Why GAO Did This Study

NOAA is responsible for collecting 

hydrographic data—that is, data on the 

depth and bottom configuration of 

water bodies—to help create nautical 

charts. NOAA collects data using its 

fleet and also procures data from the 

private sector. The Hydrographic 

Services Improvement Act of 1998 

requires NOAA to acquire such data 

from the private sector “to the greatest 

extent practicable and cost-effective.” 

GAO was asked to review NOAA 

efforts to collect hydrographic data. 

This report examines (1) how NOAA 

determines its hydrographic survey 

priorities, (2) NOAA’s efforts to

compare the costs of collecting its own 

survey data to the costs of procuring 

such data from the private sector, and 

(3) the extent to which NOAA has 

developed a strategy for private sector 

involvement in hydrographic data 

collection. 

GAO analyzed relevant laws and 

agency procedures, NOAA cost

comparison reports from fiscal years 

2006 through 2016, and other NOAA 

information, such as hydrographic 

survey program priorities. GAO also 

interviewed NOAA officials and the 

eight survey companies that currently 

have contracts with NOAA. 

What GAO Recommends

GAO recommends that NOAA

(1) ensure that its efforts to improve its 

cost comparison reports include 

actions to fully track asset and 

maintenance costs and (2) develop a 

strategy for expanding private sector 

involvement in the hydrographic survey

program. NOAA agreed with GAO’s 

recommendations. 
Page i GAO-17-510 NOAA’s Hydrographic Survey Data

Letter 1

Background 4

NOAA Uses a Three-Step Process to Determine Its Hydrographic 

Survey Priorities and Is Developing a Model Aimed at Better 

Assessing Hydrographic Risks 10

NOAA’s Annual Report Compares the Cost of Collecting Its Own 

Survey Data to the Cost of Procuring Data from the Private 

Sector but Does Not Include All Costs 16

NOAA Has Taken Steps to Increase Private Sector Involvement in 

Data Collection, but Has Not Developed a Strategy for 

Expanding Such Involvement as Required by Law 20

Conclusions 23

Recommendations for Executive Action 24

Agency Comments 24

Appendix I National Oceanic and Atmospheric Administration Hydrographic Data 

Quality Standards and Review Process 26

Appendix II Comments from the Department of Commerce 30

Appendix III GAO Contact and Staff Acknowledgments 33

Figures

Figure 1: National Oceanic and Atmospheric Administration’s 

Hydrographic Survey Vessels 5

Figure 2: National Oceanic and Atmospheric Administration Ship 

Using Multibeam Sonar to Map the Sea Floor 7

Figure 3: National Oceanic and Atmospheric Administration Ship 

Using Side Scan Sonar to Map the Sea Floor 8

Figure 4: Overview of National Oceanic and Atmospheric 

Administration Process to Develop Annual Hydrographic 

Surveying Plan 11

Figure 5: Overview of National Oceanic and Atmospheric 

Administration Hydrographic Survey Acceptance Review 

Process 29

Contents
Page ii GAO-17-510 NOAA’s Hydrographic Survey Data

Abbreviations:

NOAA National Oceanic and Atmospheric Administration

HSSD Hydrographic Surveys Specifications and Deliverables

PPA Programs, Projects, and Activities

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Page 1 GAO-17-510 NOAA’s Hydrographic Survey Data

441 G St. N.W.

Washington, DC 20548

June 15, 2017

The Honorable John Thune

Chairman

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Bill Shuster

Chairman

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Dan Sullivan

United States Senate

Each year, the United States’ maritime transportation system moves 

2 billion tons of freight in and out of our nation’s ports. The National 

Oceanic and Atmospheric Administration (NOAA) within the Department 

of Commerce is responsible for collecting hydrographic data—that is, 

data on the depth and bottom configuration of water bodies. Such data 

support the creation of nautical charts, which, according to NOAA 

documents, are the foundation of safe ocean transportation of people and 

goods for commercial and recreational purposes. Within NOAA, the Office 

of Coast Survey collects hydrographic survey data using NOAA’s 

hydrographic survey fleet and also procures and oversees hydrographic 

surveying and related services from the private sector. NOAA conducts 

hydrographic surveys in U.S. territorial waters and the U.S. Exclusive 

Economic Zone, which generally extends 3 to 200 nautical miles 

offshore—an area of about 3.4 million square nautical miles.1

The Hydrographic Services Improvement Act of 1998,2 which was 

amended in 2002 and 2008,3 was intended to divide responsibility for 

 1

The United States has sovereign rights and jurisdiction over the U.S. Exclusive Economic 

Zone, including the right to manage natural resources and jurisdiction to protect and 

preserve the marine environment.

2

Pub. L. No. 105-384, tit. III, 112 Stat. 3451, 3454 (1998) (codified as amended at 33 

U.S.C. §§ 892-892d).

3

Hydrographic Services Improvement Act Amendments of 2002, Pub. L. No. 107-372, tit. 

I, 116 Stat. 3078, 3079-82 (2002); Hydrographic Services Improvement Act Amendments 

of 2008, Pub. L. No. 110-386, 122 Stat. 4106 (2008).

Letter
Page 2 GAO-17-510 NOAA’s Hydrographic Survey Data

hydrographic services between NOAA and the private sector, according 

to a House committee report.4 The act as amended requires NOAA to, 

among other things, acquire hydrographic survey data through contracts 

with private entities “to the greatest extent practicable and cost-effective”

and to issue standards for hydrographic data used by NOAA. In addition, 

the Ocean and Coastal Mapping Integration Act, enacted in 2009, 

required the NOAA Administrator to transmit a report to relevant 

congressional committees by July 28, 2009, that described the agency’s 

strategy for expanding contracting with the private sector to minimize 

duplication and take maximum advantage of private sector capabilities in 

fulfilling the agency’s mapping and charting responsibilities.5 According to 

NOAA officials, the congressional committee reports accompanying 

NOAA’s appropriations acts for fiscal years 2007 through 2016 provided 

about $342 million of the agency’s appropriation for the Hydrographic 

Survey Priorities/Contracts budget line item. According to NOAA officials, 

the most recent contracts were awarded in June 2014 to eight private 

sector hydrographic survey companies for a 5-year contract period.

You asked us to review NOAA’s efforts to collect hydrographic data, 

including its use of the private sector in doing so. This report examines 

(1) how NOAA determines its hydrographic survey priorities, (2) NOAA’s 

efforts to compare the costs of collecting its own hydrographic survey 

data to the costs of procuring such data from the private sector, and 

(3) the extent to which NOAA has developed a strategy for private sector 

involvement in hydrographic data collection.

To conduct our work, we reviewed relevant laws and agency procedures 

and interviewed NOAA officials as well as stakeholders selected because 

of their involvement in NOAA’s hydrographic survey program. The 

stakeholders we interviewed were the eight hydrographic survey 

companies that have contracts with NOAA as of the time of this report 

and the chairman of the Hydrographic Services Review Panel, a federal 

advisory committee that advises NOAA on matters related to 

hydrographic surveying. For context, in April 2016, we also observed a 

demonstration of the equipment used by one of the eight hydrographic 

survey contractors.

 4

H.R. Rep. No. 105-485, at 6 (1998). 

5

Pub. L. No. 111-11, tit. XII, subtit. B, 123 Stat. 991, 1426 (2009) (codified at 33 U.S.C. § 

3504(d)).
Page 3 GAO-17-510 NOAA’s Hydrographic Survey Data

To determine how NOAA sets its hydrographic survey priorities, we 

reviewed and analyzed NOAA documents, including its most recent 

management and strategic plan, prepared in 2015; standard operating 

procedures for developing priorities; and NOAA reports that describe 

previous and emerging survey priorities. We also interviewed officials 

from NOAA’s Office of Coast Survey about the agency’s priority-setting 

process.

To examine NOAA’s efforts to compare the costs of collecting its own 

hydrographic survey data to the costs of procuring such data from the 

private sector, we reviewed NOAA’s procedures for collecting and 

reporting cost information, including NOAA’s standard operating 

procedure for this activity.6 We also reviewed Office of Management and 

Budget Circular A-76, which provides guidance on comparing public and 

private sector costs, and reviewed reports prepared by the Department of 

Commerce Inspector General and the Hydrographic Services Review 

Panel on NOAA’s cost comparison methodologies.7 In addition, we 

obtained and analyzed cost comparison reports prepared by NOAA for 

fiscal years 2006 through 2016, which detail NOAA’s costs for 

hydrographic surveys conducted by the agency and the private sector, to 

determine the extent to which the reports complied with the agency’s 

standard operating procedure. We also compared the information in the 

reports to other NOAA information, including budget data from NOAA’s 

Management Analysis and Reporting System and data on ship usage and 

miles surveyed from NOAA’s Office of Marine and Aviation Operations, to 

identify any discrepancies. In cases in which we identified possible errors 

or discrepancies in the cost comparison reports, we interviewed officials 

from NOAA’s Office of Coast Survey and Office of Marine and Aviation 

Operations to obtain additional information. We determined that the 

information contained in the cost comparison reports was not in all cases 

complete or accurate, as described later in this report. We also 

interviewed officials from NOAA’s Office of Coast Survey and Office of 

 6

National Oceanic and Atmospheric Administration, Annual Hydrographic Survey Program 

Cost Report, Standard Operating Procedure (revised May 18, 2016). 

7

Office of Management and Budget, Circular No. A-76 Revised: Performance of 

Commercial Activities (Washington D.C.: May 29, 2003); Department of Commerce Office 

of Inspector General, National Oceanic and Atmospheric Administration: Process for 

Reducing The Critical Hydrographic Survey Backlog Lacks Key Management Controls,

STD-15120-3-0001 (Washington, D.C.: July 28, 2003); Hydrographic Services Review 

Panel, Findings and Recommendations: Hydrographic Survey Cost Analysis (Silver 

Spring, Md.: Sept. 28, 2005). 
Page 4 GAO-17-510 NOAA’s Hydrographic Survey Data

Marine and Aviation Operations to obtain information on any agency 

initiatives to improve cost data. We did not conduct a cost comparison 

study to independently determine whether it is more cost-effective for 

NOAA or the private sector to conduct hydrographic surveys because 

such a study was not within the scope of our review.

To determine the extent to which NOAA has developed a strategy for 

private sector involvement in hydrographic data collection, we reviewed 

and analyzed requirements for such a strategy in the Ocean and Coastal 

Mapping Integration Act. We also examined agency contracting policies 

and strategic planning documents as well as agency documents 

describing NOAA’s use of contractors in hydrographic surveying, 

including the number of contractors and the amount of surveying 

conducted. In addition, we interviewed officials from NOAA’s Office of 

Coast Survey to obtain information on actions the agency has taken in 

response to the Ocean and Coastal Mapping Integration Act’s 

requirement to develop a strategy to expand contracting with the private 

sector for NOAA’s mapping and charting responsibilities. We then 

compared information contained in NOAA’s policies and strategic 

planning documents, as well as actions taken by NOAA, to this

requirement.

We conducted this performance audit from January 2016 to June 2017 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.

NOAA’s Office of Coast Survey provides navigational services intended to 

ensure the safe and efficient passage of maritime commerce through 

oceans and coastal waters within U.S. jurisdiction, and in the Great 

Lakes. In this capacity, the Office of Coast Survey develops, updates, and 

maintains more than 1,000 nautical charts—maps used for navigating 

waterways—containing information about water depth, the shape of the 

water body floor and coastline, the location of possible obstructions, and 

other physical features within these water bodies. According to NOAA 

documentation, nautical charts provide information critical to safe 

navigation, such as symbols that inform ship captains or recreational 

boaters if an area is shallow or has dangerous conditions that could 

imperil navigation. Hydrography is the science that informs the surveying 

Background
Page 5 GAO-17-510 NOAA’s Hydrographic Survey Data

methods for collecting the data used to create and update nautical charts. 

In addition, information collected through hydrographic surveying 

supports a variety of maritime functions such as port and harbor 

maintenance, beach erosion and replenishment studies, management of 

coastal areas, and offshore resource development.

NOAA operates four ships that predominantly support hydrographic 

surveys: the Fairweather, Ferdinand R. Hassler, Rainier, and Thomas 

Jefferson (see fig.1). The Hassler, commissioned in 2012, is the newest 

of the four vessels.

Figure 1: National Oceanic and Atmospheric Administration’s Hydrographic Survey 

Vessels

NOAA also procures and oversees hydrographic surveying and related 

services from the private sector. NOAA officials said the congressional 

committee reports accompanying NOAA’s appropriations acts for fiscal 

years 2007 through 2016 provided about $342 million of the agency’s 

appropriation for the Hydrographic Survey Priorities/Contracts budget line 

item. The most recent contracts were awarded in June 2014 to eight 

hydrographic survey companies for a 5-year period and are valued at up 
Page 6 GAO-17-510 NOAA’s Hydrographic Survey Data

to $250 million over this contract period based on NOAA documents.8 In 

addition, according to NOAA officials, NOAA works with other federal 

agencies to collect hydrographic survey data. For example, the U.S. Army 

Corps of Engineers provides such data for the federal harbor waterways 

that support the U.S. port system.

NOAA primarily uses two kinds of sonar for hydrographic surveying—

multibeam and side scan. Multibeam sonar measures the depth of the 

water by analyzing the time it takes sound waves to travel from a vessel 

to the bottom of the water body and back and provides detailed 

information about the water body floor. Multibeam sonar is generally used 

in areas such as the northeast United States and Alaska, where the water 

body floor is complex and often strewn with rocks. See figure 2 for an 

illustration of a NOAA ship using multibeam sonar.

 8

The final amount of the contracts will be determined by the value of individual 

hydrographic surveying task orders issued by NOAA during the contract period but cannot 

exceed $250 million.
Page 7 GAO-17-510 NOAA’s Hydrographic Survey Data

Figure 2: National Oceanic and Atmospheric Administration Ship Using Multibeam 

Sonar to Map the Sea Floor

In contrast, in relatively shallow flat areas like those along the mid-Atlantic 

coast, NOAA uses side scan sonar. Side scan sonar creates an image of 

the water body floor but does not determine depths. If NOAA finds a 

shipwreck or obstruction using side scan sonar, it will determine its depth 

using multibeam sonar. See figure 3 for an illustration of a NOAA ship 

using side scan sonar.
Page 8 GAO-17-510 NOAA’s Hydrographic Survey Data

Figure 3: National Oceanic and Atmospheric Administration Ship Using Side Scan 

Sonar to Map the Sea Floor

NOAA’s National Ocean Service is responsible for providing data, tools, 

and services that support mapping, charting, and maritime transportation 

activities, among other things. Within the National Ocean Service, the 

Office of Coast Survey directs the agency’s hydrographic surveying 

operations. In particular, it develops survey specifications, evaluates new 

technologies, and implements procedures for acquiring hydrographic 

survey data, processing the data, and producing nautical charts. Within 

the Office of Coast Survey, the Hydrographic Surveys Division is 

responsible for planning, managing, and supporting hydrographic 

surveying operations. This includes compiling, verifying, and certifying 

hydrographic data, as well as determining hydrographic survey priorities 

and issuing an annual hydrographic survey prioritization report. The 

Hydrographic Surveys Division coordinates with NOAA’s Office of Marine 

and Aviation Operations to plan and schedule NOAA vessels for 

hydrographic surveying. The Office of Marine and Aviation Operations 
Page 9 GAO-17-510 NOAA’s Hydrographic Survey Data

manages, operates, and maintains NOAA’s fleet of 16 ships, including the 

4 ships that predominantly support hydrographic surveying. According to 

NOAA officials, during fiscal years 2007 through 2016, NOAA expended 

about $303 million for its in-house hydrographic survey program.

The Hydrographic Surveys Division also works with the Hydrographic 

Services Review Panel, an external committee that advises NOAA on 

matters related to hydrographic services, including surveying. The review 

panel, which was required by the Hydrographic Services Improvement 

Act Amendments of 2002,9 is composed of 15 voting members appointed 

by the NOAA Administrator as well as several NOAA employees who are 

nonvoting members. Voting members must be especially qualified in one 

or more disciplines relating to hydrographic data and services, vessel 

pilotage, port administration, coastal management, fisheries 

management, marine transportation, and other disciplines as determined 

appropriate by the NOAA Administrator.10 The NOAA Administrator is 

required to solicit nominations for panel membership at least once a year; 

voting members serve a 4-year term,

11 and may be appointed to one 

additional term.12 The Director of the Office of Coast Survey serves as the 

designated federal officer.13

NOAA’s standards for hydrographic surveying are contained in a 

technical specifications document known as the Hydrographic Surveys 

Specifications and Deliverables.14 The document is updated annually by 

NOAA hydrographers and, according to NOAA officials, is also the 

standard on which many other hydrographic survey entities base their 

hydrographic surveying requirements. In addition, NOAA maintains a 

 9

Pub. L. No. 107-372, § 105, 116 Stat. 3078, 3080-81 (2002) (codified as amended at 33 

U.S.C. § 892c(c)(3)). 

1033 U.S.C. § 892c(c)(1)(A).

1133 U.S.C. § 892c(c)(2)(A). 

1233 U.S.C. § 892c(c)(2)(B). 

13The designated federal officer is the NOAA official responsible for ensuring the 

Hydrographic Services Review Panel adheres to certain requirements in the Federal 

Advisory Committee Act. For example, among other things, the designated federal officer 

approves the committee meetings and must ensure that meeting minutes are certified 

within 90 calendar days.

14Department of Commerce, National Oceanic and Atmospheric Administration, National 

Ocean Service Hydrographic Surveys Specifications and Deliverables (March 2016). 
Page 10 GAO-17-510 NOAA’s Hydrographic Survey Data

quality assurance program for all hydrographic survey data submitted by 

the private sector and NOAA hydrographers. The quality assurance 

program includes three main review procedures intended to ensure that 

hydrographic data submitted to NOAA meet quality standards: the Rapid 

Survey Assessment, Survey Acceptance Review, and Final Survey 

Review. See appendix I for additional information about NOAA’s data 

quality standards and review process.

NOAA uses a three-step process to determine its hydrographic survey 

priorities. In addition, in an effort to improve its priority setting, NOAA is 

developing a model to better assess hydrographic risks to ships.

NOAA Uses a ThreeStep Process to 

Determine Its 

Hydrographic Survey 

Priorities and Is 

Developing a Model 

Aimed at Better 

Assessing 

Hydrographic Risks
Page 11 GAO-17-510 NOAA’s Hydrographic Survey Data

According to NOAA’s standard operating procedure and NOAA officials, 

NOAA uses a three-step process to determine its hydrographic survey 

priorities. Under this process, NOAA (1) identifies the areas in greatest 

need of surveying, (2) evaluates resources, including funding and vessel 

availability, and (3) develops an annual hydrographic surveying plan, 

which identifies the resulting hydrographic survey priorities. The plan 

specifies the locations, vessels, and schedules for NOAA hydrographic 

survey projects and the locations and time frames for private sector 

hydrographic survey projects. (See fig. 4.)

Figure 4: Overview of National Oceanic and Atmospheric Administration Process to Develop Annual Hydrographic Surveying 

Plan

NOAA first identifies the areas the agency considers to be in the greatest 

need of a hydrographic survey, using an approach it developed in 1994 

called NOAA Hydrographic Survey Priorities, according to NOAA’s 

standard operating procedure and NOAA officials. NOAA identifies areas 

of “navigational significance” based on depth, draft of ships,15 and 

potential for dangers to marine navigation. NOAA then determines which 

of these navigationally significant areas are in greatest need of surveying 

by considering (1) shipping tonnage and trends, (2) age and quality of 

 15The draft of a ship is the distance between the water surface and the lowest point of a 

ship and determines the minimum depth of water a ship can safely navigate. 

NOAA Uses a Three-Step 

Process that Considers 

Survey Needs and 

Resource Availability to 

Determine Hydrographic 

Survey Priorities

Quantifying and Identifying 

Needs
Page 12 GAO-17-510 NOAA’s Hydrographic Survey Data

surveys in the area, (3) seafloor depth, (4) potential for unknown dangers 

to navigation due to environmental or human influences, and (5) requests 

for surveys from stakeholders such as pilot associations16 and the U.S. 

Coast Guard, and requests received through NOAA’s regional navigation 

managers.17 Through this process, NOAA designates high-priority areas 

in any of four categories:

• Critical areas. Areas that NOAA identified in 1994 as experiencing 

such circumstances as high shipping traffic or hazardous material 

transport or having a significant number of survey requests from 

users.18

• Emerging critical areas. Areas in the Gulf of Mexico and Alaska that 

NOAA identified after 1994 that met the critical area definition but that 

NOAA chose to designate in a separate category from the 1994 

critical areas for tracking purposes.

• Resurvey areas. Areas that NOAA identified as requiring recurring 

surveys because of changes to seafloors, use by vessel traffic, or 

other reasons.

• Priority 1-5 areas. Areas that do not fall into any of the three 

categories above are subdivided into five priority areas based on the 

date of the most recent survey and the level of usage by vessels.

Until 2012, according to NOAA’s standard operating procedure, NOAA 

used the results of its approach for identifying areas most in need of 

surveying to publish annual hydrographic survey prioritization reports—a 

component of the overall hydrographic surveying plan. However, NOAA 

officials said they found this approach increasingly outdated because it 

did not reflect changing ocean and shipping conditions or take advantage 

of available technology. These officials said they are in the process of 

developing a new methodology (described later in this report) to help 

identify areas that need surveys. According to NOAA officials, they have 

 16Pilot associations are trade associations of professional maritime pilots. 

17NOAA’s navigation managers, stationed in port areas along U.S. coasts and the Great 

Lakes, work directly with pilots, mariners, port authorities, and recreational boaters. They 

help identify navigational challenges facing the marine transportation system and provide 

resources and services to promote safe and efficient navigation.

18In 1994, NOAA examined the 3.4 million square nautical miles of the U.S. Exclusive 

Economic Zone for navigational significance and determined that approximately 500,000 

square nautical miles of this zone are navigationally significant. Of those significant areas, 

NOAA identified approximately 43,000 square nautical miles as critical areas.
Page 13 GAO-17-510 NOAA’s Hydrographic Survey Data

continued to update computerized mapping files and reports related to 

hydrographic survey priorities since 2012 but have not published new 

hydrographic survey prioritization reports. However, these officials said 

they will provide information to the public upon request.

According to NOAA’s standard operating procedure and NOAA officials, 

once NOAA identifies its highest priority areas, the agency compares its 

priorities to those identified by external stakeholders through NOAA’s 

navigation managers and its Integrated Ocean and Coastal Mapping 

program.19 NOAA officials said this input helps them understand potential 

economic and safety issues, among other things, that may affect 

hydrographic survey priorities. NOAA officials said they look to find areas 

of intersection between areas identified through the NOAA Hydrographic 

Survey Priorities process and those compiled by NOAA’s navigation 

managers and external stakeholders. NOAA’s standard operating 

procedure states that when determining which areas to survey, NOAA 

generally gives precedence to survey areas identified through the NOAA

Hydrographic Survey Priorities process, but stakeholder input may shape 

survey priorities in unusual cases, such as when hurricane-related 

requests indicate the need for an immediate resurvey.

According to NOAA’s standard operating procedure and NOAA officials, 

NOAA estimates the amount of funds it expects to be available to conduct 

surveys and develops a preliminary survey plan that seeks to maximize 

in-house and contractor resources. Once funds are appropriated, NOAA 

modifies its preliminary plan to reflect the amounts available for NOAA 

fleet operations and survey contracting. NOAA also evaluates survey 

requirements and in-house and contractor ship availability and capability. 

As NOAA obligates funds for in-house surveys and for contracts, it refines 

and finalizes the actual amount of surveying to be conducted by both inhouse and contractor hydrographers.

According to NOAA’s standard operating procedure and NOAA officials, 

based on an evaluation of the identified hydrographic survey needs, 

available funding, and vessel availability and capability, NOAA develops a 

hydrographic surveying plan for the coming year. NOAA evaluates the 

mix of available NOAA and private sector vessels to meet the highestranked survey needs with available funding. NOAA also engages offices 

 19The Integrated Ocean and Coastal Mapping program coordinates with internal and 

external stakeholders to develop mapping standards and techniques, improve data 

management and access, and implement cooperative projects. 

Evaluating Resource 

Availability

Developing and Approving 

Plan
Page 14 GAO-17-510 NOAA’s Hydrographic Survey Data

within NOAA to coordinate hydrographic survey ship schedules to 

accommodate other agency projects and plans. For example, NOAA 

officials said they may use hydrographic survey ships to accommodate 

the testing of new types of equipment, such as unmanned surface 

vehicles. Once the surveying plan is developed, it is submitted to the 

Chief of the Hydrographic Surveys Division for approval, according to 

NOAA’s standard operating procedure.

When we began our review, NOAA officials told us they did not have 

written procedures documenting how the Hydrographic Surveys Division 

is to develop its annual hydrographic surveying plan. In response to our 

review, NOAA issued a standard operating procedure in September 2016 

documenting how the division is to develop the plan.20

NOAA is developing a model intended to better assess hydrographic risks 

as part of its effort to identify areas most in need of hydrographic 

surveys—the first step in NOAA’s process for creating the hydrographic 

surveying plan. According to NOAA officials, the model is aimed at 

addressing several limitations they found with the agency’s existing 

approach for identifying areas most in need of surveys. For example, they 

said the existing approach does not account for such changes as:

• the emergence of new ports and subsequent changes in waterway 

traffic patterns;

• seafloor changes from weather and oceanic processes, and the 

resulting need for some areas to be surveyed more often than others; 

and

• sizes and capabilities of ships, with many of them having deeper 

drafts since NOAA developed its plan in 1994.

In addition, NOAA officials noted that the existing approach has focused 

on large container ships and oil tankers and not the many smaller vessels 

(e.g., fishing vessels and recreational boats) that also rely on NOAA 

hydrographic survey data to navigate safely.

 20National Oceanic and Atmospheric Administration, Hydrographic Surveying Plan, 

Standard Operating Procedure (initial release September 15, 2016). 

NOAA is Developing a 

Model to Better Assess 

Hydrographic Risks to 

Help Inform Prioritization 

Decisions
Page 15 GAO-17-510 NOAA’s Hydrographic Survey Data

According to NOAA documents, the new model—which NOAA refers to 

as a “hydrographic health” model—will help NOAA identify survey needs 

by taking advantage of new technologies and more precise information 

about weather and oceanic processes. For example, agency officials said 

that with the advent of a Global Positioning System-based technology 

known as the Automatic Identification System, NOAA has data on the 

actual paths of vessels equipped with this technology, including when and 

where vessels have travelled as well as their length, width, and draft.21

The new model also analyzes information that is similar to what NOAA 

currently uses, such as (1) areas of shallow seafloor depth, 

(2) unsurveyed areas, (3) known or reported discrepancies on the 

nautical chart for an area, (4) reported accidents, (5) stakeholder 

requests, and (6) established national priorities.

NOAA officials said they completed a test of the new hydrographic health 

model in 2016 for coastal waters in the southeastern United States—

including coastal Alabama, Florida, and Georgia—and solicited feedback 

on the model from internal stakeholders. NOAA also presented the model 

at an international hydrographic conference in May 2016 and began using 

the model in the second quarter of fiscal year 2017. NOAA officials said 

the agency is preparing to submit a paper describing this model to an 

international hydrographic journal for peer review in the second quarter of 

fiscal year 2018. NOAA officials said they will incorporate the peer review 

feedback into the model in the third quarter of fiscal year 2018.22 NOAA 

also plans to release periodic reports describing the state of the 

hydrographic health of the nation’s waters after the model is fully 

implemented, according to the standard operating procedure.

 21The International Maritime Organization’s International Convention for the Safety of Life 

at Sea requires the Automatic Identification System to be fitted aboard international 

voyaging ships with a gross tonnage of 300 tons or more, and all passenger ships 

regardless of size.

22We did not assess the merits of the proposed model or its related testing because doing 

so was not within the scope of our review. 
Page 16 GAO-17-510 NOAA’s Hydrographic Survey Data

NOAA prepares an annual report that compares the cost of collecting its 

own hydrographic survey data to the cost of procuring such data from the 

private sector. According to NOAA’s standard operating procedure for 

conducting this cost analysis, the purpose of the analysis is to track and 

report the full cost of the hydrographic survey program, detailing costs for 

all activities that directly or indirectly contribute to the program.23

Specifically, NOAA’s standard operating procedure for preparing the 

annual cost comparison report states that the report should include, by 

fiscal year, all costs that directly or indirectly contribute to conducting 

hydrographic surveys, regardless of funding sources.

According to NOAA’s standard operating procedure, to create the report, 

NOAA annually obtains data on survey costs for the previous fiscal year 

from the various NOAA offices involved in collecting hydrographic survey 

data. These offices collect cost data from staffing and financial data 

systems and enter the information into a spreadsheet, according to NOAA 

officials and NOAA’s standard operating procedure. NOAA 

documentation indicates these data include direct costs NOAA incurs to 

collect hydrographic data using its own ships; these direct costs include 

equipment and maintenance, labor, and fuel. In addition, according to 

NOAA officials and NOAA’s standard operating procedure, NOAA obtains 

data on indirect costs, such as administrative costs apportioned to the 

hydrographic survey program and amounts paid to the private sector for 

conducting surveys.

In 2005, NOAA began reporting hydrographic survey costs in an annual 

cost comparison report in response to a 2003 recommendation from the 

Department of Commerce Office of Inspector General that NOAA track 

and report the full costs of its survey program.24 In addition, in 2005, the 

Hydrographic Services Review Panel recommended that NOAA use 

actual costs rather than estimates and “reasonably follow” Office of 

Management and Budget Circular A-76 guidelines to calculate the cost 

 23National Oceanic and Atmospheric Administration, Annual Hydrographic Survey 

Program Cost Report, Standard Operating Procedure (revised May 18, 2016). 

24Department of Commerce Office of Inspector General, National Oceanic and 

Atmospheric Administration: Process for Reducing The Critical Hydrographic Survey 

Backlog Lacks Key Management Controls, STD-15120-3-0001 (Washington, D.C.: July 

28, 2003.)

NOAA’s Annual 

Report Compares the 

Cost of Collecting Its 

Own Survey Data to 

the Cost of Procuring 

Data from the Private 

Sector but Does Not 

Include All Costs
Page 17 GAO-17-510 NOAA’s Hydrographic Survey Data

comparison; these guidelines state, among other things, that capital 

assets should be depreciated in cost estimates.25

Based on our review of NOAA’s cost comparison reports for fiscal years 

2006 through 2016, NOAA did not in all instances report complete or 

accurate cost data for its hydrographic survey program. Specifically, 

NOAA did not include the complete cost of the hydrographic survey 

program for the following activities:

• Vessel acquisition. NOAA did not include the 2012 acquisition cost 

of a NOAA survey vessel (the Hassler) in its cost comparison reports 

from fiscal years 2012 through 2016. According to NOAA 

documentation, this vessel cost $24.3 million, and NOAA officials 

agreed that they should include the acquisition cost of NOAA vessels 

in cost comparison reports and that such costs should be 

depreciated.26 NOAA officials said they have not included such costs 

in annual cost comparison reports because depreciation costs are 

tracked in NOAA’s property management system but not in NOAA’s 

budget tracking system. These officials said they are uncertain 

whether these two systems can be linked because they are separate 

databases managed by different NOAA offices.

• Major vessel maintenance. NOAA did not include the cost of major 

maintenance performed in 2010 on the hydrographic survey vessel 

Rainier in its cost comparison reports from fiscal years 2010 through 

2016. According to NOAA officials, the agency spent $13.7 million in 

support of maintenance for the Rainier. NOAA officials acknowledged 

 25Depreciation is the decline in value of a capital asset and represents the cost of 

ownership and consumption of an asset’s useful life. Office of Management and Budget 

Circular No. A-76 (May 29, 2003, revised) provides that when developing a cost 

comparison, agency and public reimbursable sources shall use the Useful Life and 

Disposal Value Table to calculate residual value, and the Federal Accounting Standards 

for Property, Plant and Equipment to establish depreciation schedules, rates of 

depreciation, and other related guidance. Circular A-76, however, is specific to conducting 

competitions between public agencies and the private sector, and the moratorium on 

executive agencies conducting public-private competitions under Circular A-76 or any 

other provision of law or regulation, enacted through the Omnibus Appropriations Act, 

2009, remains in effect. See Pub. L. No. 111-8, div. D, tit. VII, § 736, 123 Stat. 524, 689-

90 (2009). 

26According to the Department of Commerce’s Fiscal Year 2016 Agency Financial Report, 

NOAA has a “capitalization threshold” of $200,000, meaning that NOAA should depreciate 

asset expenditures of $200,000 or more. Department of Commerce, Office of Financial 

Management, Agency Financial Report, Fiscal Year 2016 (Washington, D.C.: November 

2016).
Page 18 GAO-17-510 NOAA’s Hydrographic Survey Data

that such costs should be reflected in NOAA’s cost comparison 

reports and that such costs should be depreciated. NOAA officials 

explained that they allocate annual maintenance and repair costs 

associated with the hydrographic survey program according to the 

number of days a ship is at sea conducting surveys. In this case, they 

said because the Rainier was in port the entire year undergoing 

repairs, they did not include these capital improvement costs in the 

cost comparison report.

• Contract administration for private sector hydrographers. NOAA 

did not include in its cost comparison reports for fiscal years 2006 

through 2016 contract administration costs for managing private 

sector hydrographers working under contract to the agency. NOAA’s 

standard operating procedure for conducting the annual cost analysis 

specifies that the agency should include the costs associated with 

contract management and monitoring. NOAA officials said these costs 

were not included in the reports in part because they did not have the 

software to track contract administration costs. NOAA officials 

acknowledged that they should include such costs in the cost 

comparison report.

In addition to incomplete costs for some activities, we also noted that 

NOAA did not accurately report certain costs of the hydrographic survey 

program in the year to which those costs should be assigned.

• Equipment, repair, and maintenance costs. NOAA includes 

equipment, repair, and maintenance costs in the hydrographic survey 

cost comparison report for the year in which such costs are reported 

in NOAA’s financial system. However, as with major vessel 

maintenance costs previously discussed, NOAA officials 

acknowledged that these costs should be depreciated. As a result of 

this practice, NOAA’s hydrographic survey costs may appear 

artificially high during years in which NOAA incurs large equipment, 

repair, and maintenance costs. NOAA officials said they recognize 

that reporting equipment, repair, and maintenance costs in the year 

they are incurred does not accurately represent agency costs.

• Cost and performance data for survey work conducted by the 

private sector. NOAA does not track cost data in a way that allows 

the agency to link the cost for private sector surveys to the amount of 

survey work conducted. For example, in the cost comparison report 

for fiscal year 2014, NOAA included funds that were obligated for two 

contractors to conduct survey work, but the report showed that these 

contractors did not survey any nautical miles during that year. NOAA 

officials explained that they obligated funds in fiscal year 2014 to pay 
Page 19 GAO-17-510 NOAA’s Hydrographic Survey Data

for the contract survey work, but the contractors did not begin the 

work until fiscal year 2015. These officials stated that they record 

contractor costs in the year in which the obligation occurs, and they 

record the miles surveyed in the year in which the surveying occurs. 

However, the 2014 cost per square nautical mile may appear 

artificially high because costs were recorded without including 

corresponding mileage surveyed. In contrast, the 2015 cost per 

square nautical mile may appear artificially low because survey miles 

were recorded, but the costs for conducting those surveys were not 

included in the 2015 report. NOAA officials acknowledged that their 

current method for tracking contractor costs and work performed 

needs improvement. They explained that the data inaccuracies arise 

in part from NOAA’s current process for tracking contractor cost and 

performance through manual entry of data into multiple spreadsheets.

Furthermore, we found that NOAA uses a single measure—cost per 

square nautical mile surveyed—to compare its own survey costs to those 

of its contractors. However, in 2005, the Hydrographic Services Review 

Panel concluded that a single cost measure, such as the cost per square 

nautical mile, should not be used as the primary factor to determine the 

relative cost-effectiveness of NOAA and private sector efforts to collect 

hydrographic data. The panel recommended that NOAA consider a wider 

variety of measures to help provide additional insight. NOAA officials 

acknowledged that the cost per square nautical mile was not a 

comprehensive measure of cost-effectiveness and that having additional 

measures would improve the accuracy of cost comparisons to account for 

factors such as region and water depth.

As a result of the concerns we identified, during our review, NOAA 

officials began identifying actions they would take to improve NOAA’s 

cost data. In some instances, officials identified specific steps and 

associated time frames to carry out these actions. For example, NOAA 

officials said they started using new project management software in 

fiscal year 2017 to help track contract administration costs for inclusion in 

future cost comparison reports. In addition, to allow NOAA to better link 

the costs for private sector surveys to the amount of survey work 

conducted, NOAA officials said they plan to develop a new database by 

March 2018; this database would help eliminate the need for manual data 

entry and allow NOAA to track survey cost and performance data for 

various time frames and regions. To improve NOAA’s ability to compare 

its own survey costs to those of contractors, NOAA officials said they 

were in the process of developing additional survey measures beyond 

cost per square nautical mile that could include a new “survey complexity 

rating” designed to account for factors such as region and water depth. 
Page 20 GAO-17-510 NOAA’s Hydrographic Survey Data

Officials said they expect to have these additional measures in place by 

October 2018.

However, NOAA officials could not yet identify the steps or associated 

time frames for carrying out other actions to improve the completeness 

and accuracy of cost data. For example, to help improve NOAA’s process 

for tracking depreciation costs of capital assets—such as vessel 

acquisition or equipment, repair, and maintenance—NOAA officials said 

they planned to implement an improved process in fiscal year 2019 but 

did not identify the specific steps to implement this process. In addition, to 

account for ships that are in port undergoing major maintenance, NOAA 

officials said they plan to develop a tracking system to help ensure such 

maintenance costs are included in NOAA’s cost comparison reports, but 

they did not provide additional specific details or identify when they intend 

to implement such a system. For these recently identified actions, NOAA 

officials explained that it was uncertain how NOAA would proceed 

because identifying and implementing certain steps requires the 

coordination of multiple offices within NOAA such as the Office of Coast 

Survey, Office of Marine and Aviation Operations, and Office of the Chief 

Administrative Officer. Without ensuring that its efforts to improve its cost 

comparison reports include actions to fully track capital asset depreciation 

costs and account for ships in port undergoing major maintenance, NOAA 

may be unable to prepare cost comparison reports that reflect the full cost 

of its hydrographic survey program, as called for in the agency’s standard 

operating procedure.

NOAA has taken steps aimed at increasing private sector involvement in 

its hydrographic data collection program, such as streamlining its 

contracting process and increasing communication with contractors. 

However, NOAA has not developed a strategy for expanding its use of 

the private sector as required by a 2009 law.

NOAA Has Taken 

Steps to Increase 

Private Sector 

Involvement in Data 

Collection, but Has 

Not Developed a 

Strategy for 

Expanding Such 

Involvement as 

Required by Law
Page 21 GAO-17-510 NOAA’s Hydrographic Survey Data

According to NOAA officials, NOAA has taken several steps to increase 

private sector involvement in its hydrographic data collection program. 

For example, NOAA developed a centralized process for competing and 

awarding contracts in 2003, which NOAA officials said reduced 

administrative costs and contract award time. Before this change, NOAA 

awarded contracts to individual contractors at the regional level, which 

required expending resources to process each individual contract. As a 

result of implementing a centralized process for competing and awarding 

contracts, NOAA officials said they increased the number of private sector 

firms under contract, from five during the 2003-2008 contract period to 

eight during the current 2014-2019 contract period. However, NOAA 

officials said they have not awarded task orders for surveys to all eight 

private sector firms in the same fiscal year because of NOAA’s 

appropriation, which has remained mostly flat during the current contract 

period.

NOAA also took steps to increase communication with contractors, 

according to NOAA officials. For example, starting in 2005, NOAA has 

invited hydrographic survey contractors to its annual field procedures 

workshop, which brings together officials from NOAA’s headquarters, field 

offices, and quality assurance processing branches, among others. The 

purpose of the workshop is to discuss updates to hydrographic survey 

requirements and new hydrographic survey technologies. Also, since 

2005, according to NOAA officials, contracting officer representatives 

have improved their communication with contractors through the various 

stages of the contract and survey activities by answering contractors’

questions regarding project requirements, expected deliverables, data 

processing, and unanticipated challenges that may occur when 

conducting surveys.

In addition, NOAA officials said that in 2010, the agency implemented 

procedures for obtaining contractor input on changes to its hydrographic 

survey technical specifications document, the Hydrographic Surveys 

Specifications and Deliverables. The document is updated annually, and 

contractors are asked to provide input through their respective contracting 

officer representatives. Staff review input to determine whether to include 

the recommended action in the annual technical specifications update. 

According to NOAA officials, participants discuss recommended changes 

at meetings held during the annual field procedures workshop.

NOAA Has Taken Several 

Steps to Increase Private 

Sector Involvement in 

Data Collection
Page 22 GAO-17-510 NOAA’s Hydrographic Survey Data

NOAA has not developed a strategy for expanding its use of the private 

sector in its hydrographic survey data collection program, as required by 

law. Specifically, the Ocean and Coastal Mapping Integration Act required 

the NOAA Administrator to transmit a report to relevant congressional 

committees by July 28, 2009, that described the agency’s strategy for 

expanding contracting with the private sector to minimize duplication and 

take maximum advantage of private sector capabilities in fulfilling NOAA’s 

mapping and charting responsibilities. NOAA officials could not provide us 

any documentation indicating what information the agency provided to 

Congress in response to this statutory requirement.

In 2010, NOAA issued its Ocean and Coastal Mapping and Contracting 

Policy, which states that the policy was developed in response to the 

act.27 However, rather than describing a strategy for expanding 

contracting with the private sector, as required by the 2009 law, the policy 

states that it is NOAA’s intent to contract with the private sector for ocean 

and coastal mapping services when the agency determines it is costeffective to do so and funds are available. NOAA officials acknowledged 

that the contracting policy does not meet the statutory requirement that 

the agency develop a strategy for expanding contracting with the private 

sector.

NOAA officials said the agency is limited in its ability to expand private 

sector contracting because of congressional direction on the use of the 

agency’s appropriations. Specifically, NOAA’s hydrographic survey 

program is supported by two separate funding elements, known as 

“Programs, Projects, and Activities” (PPA), within NOAA’s Operations, 

Research, and Facilities appropriation account. One PPA is for private 

sector hydrographic data collection,28 and the other is for general 

operations, maintenance, and repair of NOAA’s entire fleet of ships, 

including the hydrographic survey vessels.29 According to NOAA officials, 

the agency has limited authority to reprogram funds between these two 

PPAs without congressional notification and agreement that such 

 2775 Fed. Reg. 2109 (Jan. 14, 2010). According to the policy, ocean and coastal mapping 

includes hydrographic services as well as the acquisition, processing, and management of 

physical, biological, geological, chemical, and archaeological characteristics and 

boundaries of ocean and coastal areas.

28National Ocean Service’s Hydrographic Survey Priorities/Contracts PPA.

29Office of Marine and Aviation Operations’ Marine Operations and Maintenance PPA. 

NOAA Has Not Developed 

a Strategy for Expanding 

Its Use of the Private 

Sector in Data Collection
Page 23 GAO-17-510 NOAA’s Hydrographic Survey Data

reprogramming is warranted. To propose a reprogramming of funds, 

NOAA officials said they would need to evaluate the prioritization of all 

fleet missions. In addition, NOAA officials said they would have to 

continue to fund fixed operational costs and agency expenses for NOAA’s

entire fleet even if operations funds were reprogrammed to hydrographic 

data acquisition contracts.

NOAA officials said the agency intends to develop a strategy describing 

how it plans to expand private sector involvement in the hydrographic 

data collection program—which the Ocean and Coastal Mapping 

Integration Act required the agency to submit in a report to relevant 

congressional committees in 2009—and it will use the 2010 Ocean and 

Coastal Mapping and Contracting Policy to guide this effort. These 

officials said the agency must first implement its planned improvements in 

collecting both NOAA and private sector hydrographic survey costs; once 

NOAA has a more accurate basis on which to compare costs, the agency 

will assess the extent to which it can expand its use of the private sector 

and develop a strategy accordingly. These officials said that if their 

analysis indicates the agency should expand its use of the private sector 

beyond what is currently possible given agency appropriations, the 

agency will request changes to its appropriations to allow it more flexibility 

in expanding its use of the private sector. However, NOAA officials did not 

provide specific information about how they intend to develop the 

strategy, what elements it will contain, or when it will be completed. 

Without developing such a strategy, NOAA may have difficulty minimizing 

duplication and taking maximum advantage of private sector capabilities 

in fulfilling NOAA’s mapping and charting responsibilities.

Recognizing the importance of nautical charts to help ensure safe 

passage of people and goods through the nation’s waterways, NOAA has 

taken steps to improve its ability to set priorities for collecting 

hydrographic data. NOAA also prepares annual reports that compare the 

costs of NOAA conducting its own hydrographic surveys to the costs of 

contracting for such surveys. NOAA’s standard operating procedure 

requires the agency to track and report all costs for the hydrographic 

survey program. However, NOAA has not determined how it will track 

depreciation costs of capital assets or established time frames to improve 

its tracking of major maintenance costs for vessels. Without ensuring that 

its efforts to improve its cost comparison reports include actions to fully 

track capital asset depreciation costs and account for ships in port 

undergoing major maintenance, NOAA may be unable to prepare cost 

comparison reports that reflect the full cost of its hydrographic survey 

Conclusions
Page 24 GAO-17-510 NOAA’s Hydrographic Survey Data

program, as called for by the agency’s standard operating procedure. In 

addition, NOAA was required by law to develop a strategy for expanding 

its use of the private sector in its hydrographic survey program, but it has 

not done so and has not provided specific information on how and when it 

will. Without such a strategy, NOAA may have difficulty minimizing 

duplication and taking maximum advantage of private sector capabilities 

in fulfilling NOAA’s mapping and charting responsibilities.

We recommend that the Secretary of Commerce direct the NOAA 

Administrator to take the following two actions:

• ensure that NOAA’s efforts to improve its cost comparison reports 

include actions to fully track capital asset depreciation costs and 

account for ships in port undergoing major maintenance in 

accordance with its standard operating procedure, and

• develop a strategy for expanding NOAA’s use of the private sector in 

its hydrographic survey program, as required by law.

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

review and comment. NOAA, responding on behalf of Commerce, stated 

in its written comments (reproduced in app. II) that it agreed with our two 

recommendations. Regarding our recommendation related to improving 

NOAA’s cost comparison reports, NOAA agreed that its cost estimates 

should include the depreciation costs of new vessels once they are 

operational and stated that it will work to obtain an accurate depreciation 

schedule. NOAA also stated that it will take steps to improve its tracking 

and reporting of depreciation costs for equipment and repair and 

maintenance, including its accounting for ships in port undergoing major 

maintenance. Regarding our recommendation that NOAA develop a 

strategy for expanding its use of the private sector in hydrographic 

surveying, NOAA stated that the agency will develop such a strategy 

once it improves its approach for comparing its hydrographic survey costs 

to those of the private sector. NOAA also provided one technical 

comment, which we incorporated.

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.

Recommendations for 

Executive Action

Agency Comments 
Page 25 GAO-17-510 NOAA’s Hydrographic Survey Data

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

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

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made key 

contributions to the report are listed in appendix III.

Anne-Marie Fennell

Director, Natural Resources and Environment
Appendix I: National Oceanic and Atmospheric 

Administration Hydrographic Data Quality 

Standards and Review Process

Page 26 GAO-17-510 NOAA’s Hydrographic Survey Data

The National Oceanic and Atmospheric Administration (NOAA) has 

issued standards—known as the Hydrographic Surveys Specifications 

and Deliverables (HSSD)1

—for all hydrographic survey data collected by 

both private sector contractors and NOAA staff. NOAA maintains a quality 

assurance program for these data that includes three main review 

procedures (described below). The HSSD standards for conducting 

hydrographic surveys are based in part on the International Hydrographic 

Organization’s Standards for Hydrographic Surveys.2 These standards 

pertain to hydrographic surveys that are intended for harbors, harbor 

approach channels, inland navigation channels, and coastal areas of high 

commercial traffic density, and they generally pertain to shallower areas 

less than 100 meters in depth.

According to NOAA officials, the HSSD has been reviewed annually since 

its initial publication in 2000, and NOAA has procedures in place to obtain 

suggestions from private sector contractors regarding changes to the 

HSSD. For example, at its annual field procedures workshop, NOAA 

conducts a session on data quality review standards and practices, and it 

solicits recommendations for changes to the HSSD from both NOAA staff 

and private sector hydrographers. According to NOAA officials, 

contractors submitted fewer than 10 recommendations in 2016 but 

submitted more than 30 recommendations in 2017. All recommended 

changes to the HSSD are reviewed by the Office of Coast Survey’s 

Hydrographic Surveys Division, Operations Branch. Recommendations 

are then forwarded to the Office of Coast Survey Board of Hydrographers 

for review, and the survey board submits its recommendations to the 

Chief of the Hydrographic Surveys Division for final approval. NOAA’s 

hydrographers test the feasibility of many significant changes to the 

HSSD before they are put into practice by private sector hydrographers. 

In June 2016, NOAA approved a new position specifically to oversee and 

coordinate efforts related to hydrographic specifications, recommended 

procedures, and training. According to NOAA officials, they intend to fill 

the position in August 2017.

NOAA officials said the HSSD is also the standard on which many other 

international hydrographic entities base their hydrographic surveying 

 1

Department of Commerce, National Oceanic and Atmospheric Administration, National 

Ocean Service Hydrographic Surveys Specifications and Deliverables (March 2016). 

2

The International Hydrographic Organization is an intergovernmental consultative and 

technical organization that was established to support safety of navigation and the 

protection of the marine environment.

Appendix I: National Oceanic and 

Atmospheric Administration Hydrographic 

Data Quality Standards and Review Process
Appendix I: National Oceanic and Atmospheric 

Administration Hydrographic Data Quality 

Standards and Review Process

Page 27 GAO-17-510 NOAA’s Hydrographic Survey Data

requirements and is widely utilized by the hydrographic mapping 

community. According to NOAA officials, examples of uses of HSSD are:

• The hydrographic specifications section of the National Society of 

Professional Surveyors/Hydrographic Society of America certified 

hydrographer exam is based in part on the HSSD.

• The University Oceanographic Laboratory System Multibeam 

Advisory Committee references the HSSD in its specifications for 

multibeam sonar calibrations.

• The only two U.S. universities with graduate programs in 

hydrography—the University of New Hampshire and the University of 

Southern Mississippi—rely on the HSSD as part of their programs.

In addition, NOAA officials said the Office of Coast Survey has worked 

with different entities to help ensure that data collected by these entities 

meet HSSD specifications so that the data can be used on NOAA’s 

nautical charts. For example, officials said the office has worked with:

• the New Jersey Department of Transportation since 2014 on survey 

data the department is collecting for all New Jersey coastal waters;

• Coastal Carolina University since 2015 on survey data the university 

is collecting for the Bureau of Ocean Energy Management, an agency 

within the Department of the Interior; and

• the University of South Florida since 2016 on survey data the 

university is collecting for a significant portion of western Florida’s 

coastal waters.

NOAA’s quality assurance program includes three main review 

procedures intended to ensure that hydrographic data submitted to NOAA 

meet quality standards: the Rapid Survey Assessment, Survey 

Acceptance Review, and Final Survey Review.

Rapid Survey Assessment. NOAA’s hydrographic survey data 

processing branches located in Seattle, Washington, and Norfolk, 

Virginia, are responsible for initiating a hydrographic survey data “rapid 

survey assessment” within 5 working days of survey data being delivered 

to NOAA by private sector contractors and NOAA staff. According to 

NOAA documentation, the assessment, which should be completed within 

2 working days, is intended to improve data quality by quickly identifying 

significant deficiencies in hydrographic survey data products. The 

assessment helps ensure the survey data meet HSSD technical 

requirements and project-specific instructions that are issued at the start 
Appendix I: National Oceanic and Atmospheric 

Administration Hydrographic Data Quality 

Standards and Review Process

Page 28 GAO-17-510 NOAA’s Hydrographic Survey Data

of each survey project. If the assessment finds significant deficiencies, 

NOAA’s assessment team may make corrections itself or may return the 

survey to the hydrographer for rework and resubmission. The 

hydrographic data processing branches take several factors into 

consideration when deciding whether to return a survey for rework, such 

as whether the hydrographers are capable of fixing the error, whether 

there is value in returning a survey for the purpose of educating the 

hydrographers to prevent future similar errors, and whether it is faster and 

more efficient for the processing branch to make corrections. According to 

NOAA documentation, even if no deficiencies are found, passing the data 

through this initial assessment does not preclude the processing branch 

from returning the survey to the field hydrographers for rework and 

resubmission later in the quality assurance process if significant 

deficiencies are subsequently found.

Survey Acceptance Review. The survey acceptance review is a detailed 

evaluation and acceptance of hydrographic survey data conducted by the 

data processing branches in Seattle, Washington, and Norfolk, Virginia. 

According to NOAA documentation, the survey acceptance review 

process includes: (1) accepting the survey data from the field 

hydrographers, (2) evaluating the data and products delivered by 

hydrographers for deficiencies and deviations from the guidance 

documents, (3) conducting an internal review of the survey acceptance 

review process to validate that process, and (4) outlining the findings from 

the survey acceptance review process and transferring responsibility for 

the integrity and maintenance of the survey data from the field 

hydrographer to the processing branch.

The survey acceptance review involves several compliance checks and is 

intended to confirm that the survey data are accurate and to highlight the 

strengths and weaknesses of the data. A key element of the survey 

acceptance review is performing quality assurance checks on the survey 

data to ensure the survey was performed to the standards required in 

guidance documents, including the HSSD, NOAA’s hydrographic field 

procedures manual, and any hydrographic survey project-specific 

instructions. Upon completion of the survey acceptance review, an 

internal review is conducted to verify that the survey acceptance review 

was completed in accordance with relevant standard operating 

procedures, and that any issues outlined in the review documentation are 

consistently delineated. After the internal review is completed and 

approved, the completed documentation is forwarded to the Processing 

Branch Chief for review. The final output of the review process includes 

an acceptance letter to the Hydrographic Surveys Division Chief through 
Appendix I: National Oceanic and Atmospheric 

Administration Hydrographic Data Quality 

Standards and Review Process

Page 29 GAO-17-510 NOAA’s Hydrographic Survey Data

the Processing Branch Chief outlining any findings from the review and 

releasing the field hydrographers from further responsibility for the data. 

Figure 5 illustrates the survey acceptance review process.

Figure 5: Overview of National Oceanic and Atmospheric Administration Hydrographic Survey Acceptance Review Process

Final Survey Review. The NOAA contracting officer’s representative is 

responsible for the final quality assurance review for each hydrographic 

survey project. According to NOAA officials, this is a critical stage, as the 

contracting officer’s representative has been involved at every stage of 

the survey, from planning and technical evaluation to survey monitoring, 

including at least one inspection visit with the contractor during the survey 

time frame. The contracting officer’s representative is the primary point of 

contact when the contractor seeks guidance to resolve technical issues. 

During the final review, the contracting officer’s representative reviews the 

survey to ensure it is complete—this is the last stage of quality assurance 

review before the data are archived and made available to the public.
Appendix II: Comments from the Department 

of Commerce

Page 30 GAO-17-510 NOAA’s Hydrographic Survey Data

Appendix II: Comments from the Department 

of Commerce
Appendix II: Comments from the Department 

of Commerce

Page 31 GAO-17-510 NOAA’s Hydrographic Survey Data
Appendix II: Comments from the Department 

of Commerce

Page 32 GAO-17-510 NOAA’s Hydrographic Survey Data
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 33 GAO-17-510 NOAA’s Hydrographic Survey Data

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

In addition to the individual named above, Steve Gaty (Assistant 

Director), Leo Acosta (Analyst-in-Charge), Martin (Greg) Campbell, 

Patricia Farrell Donahue, Timothy Guinane, Benjamin Licht, J. Lawrence 

Malenich, Ty Mitchell, Guisseli Reyes-Turnell, Danny Royer, Jeanette 

Soares, and Arvin Wu made key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff

Acknowledgments

(100564)
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