Recreational Fisheries Management: The National Marine Fisheries Service Should Develop a Comprehensive Strategy to Guide Its Data Collection Efforts
Published: 2015-12-08T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Almost 11 million anglers made nearly 71 million marine recreational fishing trips in the continental United States in 2013. Pressure on many fish stocks from fishing has increased demand for quality and timely data that can be used to assess the status of various fish stocks as part of managing marine recreational fisheries. The many modes of marine recreational fishing—in which anglers fish from private boats or boats with guides, the shoreline, private property, and public docks—make collecting the data needed to effectively manage recreational fisheries both complex and challenging.
GAO was asked to review NMFS' marine recreational fisheries data collection program. This report examines (1) challenges that have been identified with the agency's data collection efforts for managing marine recreational fisheries and (2) steps the agency has taken to improve data collection and challenges that remain. GAO reviewed laws, policies, and guidance related to federal and state recreational fisheries data collection methods; reviewed NMFS and other documents on recreational fisheries data collection; and interviewed a nongeneralizable sample of federal and state recreational fisheries officials and other stakeholders, selected to provide geographic representation, among other things, to obtain their views on NMFS' data collection efforts.
section_title: What GAO Found
paragraphs: The National Marine Fisheries Service (NMFS) within the Department of Commerce faces several challenges related to fisheries data collection, according to reports GAO reviewed and NMFS officials and stakeholders GAO interviewed. These challenges include collecting quality recreational fishing data that are timely for managing marine recreational fisheries and communicating with stakeholders. Regarding the collection of quality data, for example, NMFS faces a challenge identifying the universe of anglers from which to collect information about their marine recreational fishing activity. NMFS relies in part on state registries to identify anglers, but some states exempt certain anglers from registering, and therefore NMFS does not have a complete list of recreational anglers. NMFS officials and other stakeholders have also identified challenges in communicating with stakeholders in collecting recreational fisheries data. For example, several stakeholders told GAO that NMFS has not always communicated with the public about its activities, creating concerns about a lack of transparency regarding NMFS' fisheries management decisions. Reflecting this challenge, in 2014, Louisiana withdrew from the federal fisheries data collection program and implemented its own program because of concerns about federal recreational fisheries data, according to a Louisiana fisheries official.
NMFS has taken several steps aimed at improving data collection to manage marine recreational fisheries and addressing challenges related to communicating with stakeholders. For example, to help improve the quality of the state data it relies on to identify the universe of anglers, NMFS made recommendations to states on improving their recreational angler databases and provided funds to the states to support data quality improvement projects, according to NMFS documents. NMFS has also taken steps to improve communication, including working with Louisiana to perform a side-by-side comparison of federal data with Louisiana's data to determine whether Louisiana's data can be used as an alternative to federal data. However, some challenges persist, including challenges in validating data the NMFS collects and communicating about upcoming NMFS initiatives. More broadly, the agency does not have a comprehensive strategy to guide its efforts to improve recreational fisheries data collection. Such a strategy is consistent with the framework of leading practices in federal strategic planning, as described in the Government Performance and Results Act Modernization Act of 2010, Office of Management and Budget guidance, and practices GAO has identified. Based on GAO's discussions with NMFS officials and review of NMFS documents, the agency has not developed a comprehensive strategy because it has been focused on other priorities such as improving its data collection methods. NMFS officials told GAO that NMFS recognizes the need to enhance its strategic planning but did not provide information about how, or whether, they plan to develop a comprehensive strategy. Without a comprehensive strategy that articulates NMFS' goals to improve data collection and methods for measuring progress toward the goals, NMFS may have difficulty ensuring that the various steps it is taking to improve data collection are prioritized so that the most important steps are undertaken first, and it may find it difficult to determine the extent to which these steps will help it address the challenges it faces.
section_title: What GAO Recommends
paragraphs: GAO recommends that NMFS develop a comprehensive strategy to guide its data collection efforts. The agency agreed with GAO's recommendation.

section_title: Letter
paragraphs: Saltwater recreational fishing in the United States makes significant  contributions to local and regional economies and is an important social  activity for individuals, families, and communities. Almost 11 million  anglers made nearly 71 million marine recreational fishing trips in the  continental United States in 2013, according to National Marine Fisheries  Service (NMFS) statistics. NMFS, within the Department of Commerce’s  National Oceanic and Atmospheric Administration (NOAA), acts as a  steward of living marine resources through science-based conservation  and management. Much of this work occurs under the Magnuson- Stevens Fishery Conservation and Management Act, which sets forth  standards for the conservation and management of fisheries resources.  NMFS collaborates with stakeholders, such as states and interstate  marine fisheries commissions, primarily through its Marine Recreational  Information Program (MRIP) to collect and analyze marine recreational  fisheries data. Several states, such as Louisiana and Texas, also manage  their own marine recreational fisheries data collection programs. In  addition, NMFS and its partners collect other types of data, such as  information on commercial fishing activity and data on the total size of fish  stock populations. The various data that are collected and analyzed are  used to estimate fishing activity, understand fish biology, and determine  fish stock abundance. This information is used to support the  development of annual catch limits and other accountability measures to  prevent overfishing and support rebuilding plans for overfished stocks in  federal waters.
Pressure on many fish stocks from fishing has increased the demand for  high-quality and timely data that can be used to assess the status of  various fish stocks as part of managing marine recreational fisheries.
However, in contrast to commercial fisheries, which have standard  mechanisms for data collection, the many modes of marine recreational  fishing—in which anglers fish from private boats or boats with guides,  from the shoreline, from private property, and from public docks—make  collecting the data needed to effectively manage recreational fisheries  complex and challenging. Designing marine recreational fishing surveys  that provide high-quality and timely data at an acceptable cost was  identified as one of several challenges facing NMFS by a 2006 National  Research Council report on NMFS’ marine recreational fisheries data  collection methods.
You asked us to examine NMFS’ marine recreational fisheries data  collection program. This report examines (1) the challenges that have  been identified with NMFS’ data collection efforts for managing marine  recreational fisheries and (2) the steps NMFS has taken to improve data  collection and challenges that remain.
To conduct our work, we reviewed and analyzed relevant laws, agency  policies, guidance, and other documentation related to fisheries data  collection, including specific federal and state marine recreational  fisheries data collection projects. To determine the challenges that have  been identified with NMFS’ data collection efforts, we first reviewed  reports and evaluations of NMFS’ data collection programs since 2006,  including reports from the National Research Council and NMFS, among  others. We also interviewed officials from NMFS headquarters and  NMFS’ Northeast, Northwest, and Southeast regional Fisheries Science  Centers; representatives of the Gulf of Mexico, Pacific, and South Atlantic  Fishery Management Councils; officials from the Atlantic, Gulf, and  Pacific States Marine Fisheries Commissions; and officials from state  fisheries agencies in Alabama, Florida, Louisiana, Mississippi, North  Carolina, Rhode Island, Texas, and Washington. We selected federal and  state agencies and regional organizations to interview based on such  factors as geographic representation, locations of large volumes of  recreational fishing, and representation from key data collection and  management stakeholders. In addition, we interviewed selected marine  recreational fisheries stakeholders, such as recreational anglers, to  gather information on recreational fisheries data collection methods,  associated challenges, and steps taken to address those challenges.  These stakeholders represented various geographic locations and  different recreational fishing sectors. We determined that the selection of  these entities and individuals was appropriate for our design and  objectives, and that the selection would generate valid and reliable  evidence to support our work. The results of our interviews cannot be  generalized to all stakeholders or data collection activities, but they  provide examples of different recreational fisheries data collection efforts  and challenges. Because the NMFS statistical surveys cover a wide  range of methods, apply to a wide diversity of locations, and often entail  in-depth technical knowledge about fisheries data collection, we did not  conduct a technical evaluation of these challenges or assess their  technical validity.
To determine the steps NMFS has taken to improve data collection and  challenges that remain, we conducted interviews as described above and  reviewed NMFS reports and other documents. Specifically, we reviewed  NMFS’ strategic plans, recreational fisheries planning documents, and  recreational fisheries data collection program documents. We compared  this information with the framework of leading practices in federal  strategic planning contained in the Government Performance and Results  Act of 1993, the Government Performance and Results Act Modernization  Act of 2010, and Office of Management and Budget guidance. We also  compared this information to key practices related to communication we  identified in previous reports. Consistent with our approach to the  previous objective, we did not conduct a technical evaluation of NMFS’  steps to improve data collection or assess the appropriateness of those  steps in light of the challenges NMFS faces. Appendix I contains a more  detailed description of our objectives, scope, and methodology.
We conducted this performance audit from July 2014 to December 2015  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.
subsections: section_title: Background
paragraphs: NMFS’ mission is to act as a steward of the nation’s ocean resources and  their habitats. This includes responsibility for managing recreational  fisheries in federal waters. These waters generally include the United  States Exclusive Economic Zone, which typically begins approximately 3  geographical miles from land and extends 200 nautical miles from land.  Coastal states generally maintain responsibility for managing fisheries in  waters that extend approximately 3 geographical miles from their  coastlines. The extent of recreational fishing varies by region, with the  greatest amount of marine recreational fishing taking place in the Gulf of  Mexico, followed by the South Atlantic and Mid-Atlantic, according to  NMFS statistics. Figure 1 shows NMFS statistics about the extent of  marine recreational fishing activity overall and the locations of the highest  levels of marine recreational fishing activity. overfished fisheries, protect essential fish habitat, and reduce bycatch,  among other things. The 1996 act included requirements for NMFS and  the councils to develop fisheries management plans for fish stocks and to  establish required time frames for rebuilding fish stocks that are  overfished. A reauthorization of the act was passed in 2006 and  established further legal requirements to guide fisheries data collection  and management, including mandates on the use of science-based  annual catch limits. Under NMFS guidelines, plans should include  accountability measures to prevent catch from exceeding the annual  catch limit. These measures can include fishing season closures,  closures of specific areas, changes in bag limits, or other appropriate  management controls.
Private recreational anglers use private boats  and sites on shore, such as public docks or  private boat clubs, to access marine  recreational fisheries.
The marine recreational fishing sector is divided between private anglers  and the for-hire sector. Private anglers primarily access marine  recreational fisheries by using private boats or by fishing from sites on  shore. The for-hire sector includes both charter boats and “head boats.”  Charter boats are chartered or contracted by anglers for a fishing trip for a  flat fee regardless of the number of anglers on the boat. “Head boats”  are usually large capacity multipassenger vessels that charge each  angler a per person fee for a fishing trip.
Private recreational anglers also rely on the  for-hire sector, which consists of charter boats  and “head boats.” Charter boats commonly  carry six or fewer passengers who purchase  the services of a boat and crew. “Head boats”  carry more than six passengers, with each  individual angler paying a fee to go fishing.
NMFS has overall responsibility for collecting data to manage federal  fisheries. It has several offices involved in fisheries data collection and  management, including the Office of Science and Technology, six  regional Fisheries Science Centers, and five regional offices. NMFS has  numerous partners for collecting data to manage recreational fisheries,  including coastal states and three interstate marine fisheries  commissions. In addition, NMFS and these partners collaborate with  regional fisheries information networks, such as the Gulf Fisheries  Information Network and the Atlantic Coastal Cooperative Statistics  Program, to collect and manage fisheries data. NMFS also collaborates  with eight Regional Fishery Management Councils that are responsible  for fisheries conservation and management in specific geographic regions  of the country. In addition, NMFS collaborates with numerous other  stakeholders, such as private anglers, charter boat operators, seafood  dealers, nongovernmental organizations, and recreational fisheries  associations, to gather input about fisheries data collection programs and  management. Figure 2 shows key stakeholders involved in recreational  fisheries data collection.
subsections: section_title: Collection and Use of Recreational Fisheries Data
paragraphs: NMFS and its stakeholders collect several types of data for use in  recreational fisheries management. For example, information is collected  on recreational fishing effort and catch rates. Effort measures the number  of angler trips, while catch rates measure the average number and size of  fish, by species, that are brought to shore, caught and used as bait, or  discarded (i.e., caught but then released alive or dead). These data are  used to estimate the total recreational fishing catch to determine the  impact of recreational fishing activity on fish stock mortality and the  changes that are occurring to the fish stock over time. Figure 3 shows  how these data are used to estimate total catch.
According to NMFS documentation, data on catch and discards are  generally collected through shoreside interviews of anglers at public  access fishing sites, primarily through NMFS’ MRIP Access Point Angler  Intercept Survey, which covers the Atlantic and Gulf coasts from  Louisiana to Maine, or through state survey programs. These data may  also be collected through the use of onboard observers, typically on  charter boats or head boats. Data on fishing effort are collected through  MRIP or state programs, using methods such as phone or mail surveys,  shoreside interviews, onboard observers, logbooks, boat and boat trailer  counts, and electronic monitoring or electronic reporting tools. Given the  involvement of the interstate fisheries commissions and states in data  collection efforts, methods for collecting data on recreational fishing vary  among states and regions.
In addition, according to NMFS documentation, biological samples of fish  specimens are collected for scientific analysis to provide information on  the health and biology of fish stocks. For example, data are collected on  the lengths, weights, and ages of fish samples. These samples are often  collected during NMFS’ shoreside interviews of recreational anglers or by  tagging fish to track after they are caught and released. Academic  programs and cooperative research with the fishing industry are other  sources of biological sampling data.
In addition to collecting data on marine recreational fisheries, NMFS and  its stakeholders, such as states, collect other types of data including data  on commercial fisheries. Unlike recreational fisheries data, however,  commercial fisheries data are collected through a census of the weight  and value of all fish species sold to seafood dealers using a network of  cooperative agreements with states. According to NMFS documentation,  in some regions, state fishery agencies are the primary collectors of  commercial fisheries data that they receive from seafood dealers who  submit periodic reports on the amount and value of the various fish  species they purchase. In addition, independently from recreational or  commercial fishing data collection efforts, NMFS and its stakeholders also  collect information on the abundance of fish stocks and environmental  conditions in fish habitats, such as seafloors, open ocean water, and  natural and artificial reefs. These data are used to determine the size, age  composition, and distribution of fish stocks, and allow NMFS to track the  total abundance of fish stocks over time. NMFS officials told us NMFS  relies on its own research vessels or contracted commercial fishing  vessels to collect abundance data.
NMFS uses these various types of data to conduct fish stock  assessments that estimate, among other things, the population of fish  stocks, fish stock productivity, and biological reference points for  sustainable fisheries. NMFS and the Regional Fishery Management  Councils in turn use the fish stock assessments to examine the effects of  fishing activities on the fish stocks and make determinations such as  whether stocks are overfished and whether overfishing is occurring.  According to NMFS documentation, the data are also used to support  management decisions, such as setting limits on how many fish can be  caught annually or determining the need to close a recreational fishery for  a particular fish stock during an open fishing season, called an in-season  closure, when annual catch limits are anticipated to be exceeded.
section_title: National Research Council Findings and NMFS’ Implementation of MRIP
paragraphs: In 2006, the National Research Council issued a report that reviewed  NMFS’ marine recreational fisheries data collection programs and made  numerous general and specific recommendations to address  weaknesses. Among other things, the council recommended the redesign  of all marine recreational fishing surveys funded by NMFS. In addition,  the council recommended that NMFS improve its survey coverage by  either developing a national registration of all saltwater anglers or by  using new or existing state saltwater license programs that would provide  appropriate contact information for all anglers fishing in all marine waters,  both state and federal. The 2007 reauthorization of the Magnuson- Stevens Act included requirements for NMFS to take into consideration  and, to the extent feasible, implement the recommendations in the  National Research Council report.
Subsequently, in October 2008, NMFS began implementing MRIP,  managed in NMFS’ Office of Science and Technology, to collect  recreational fisheries effort and catch data and develop estimates for use  in fisheries management. MRIP was intended to coordinate collaborative  efforts among NMFS and its various stakeholders to develop and  implement an improved recreational fisheries statistics program. MRIP  consists of a system of regional surveys that provide effort and catch  statistics for use in the assessment and management of federal  recreational fisheries. According to NMFS officials, because counting  every recreational angler or observing every fishing trip is not possible,  NMFS relies upon statistical sampling to estimate the number of fishing  trips recreational anglers take and what they catch. The data gathered  from the regional surveys are compiled to provide regional and national  estimates. Under MRIP, certain states, including California, Oregon, and  Washington, have implemented recreational fisheries data collection  programs funded, in part, by NMFS; these data are also used to inform  fisheries management. Also, some states have developed and  implemented other recreational fisheries data collection programs funded,  in part, through mechanisms such as fee-based fishery programs in those  states. Figure 4 provides a timeline of key legislative and other events  related to marine recreational fisheries data collection and management.
section_title: Several Challenges with NMFS’ Fisheries Data Collection Efforts Have Been Identified
paragraphs: Since the 2006 National Research Council report, NMFS and some state  officials have identified several challenges related to collecting data to  manage marine recreational fisheries, such as obtaining quality  recreational fishing data to inform scientific analyses and produce  credible effort and catch estimates. NMFS and some state officials also  identified challenges with collecting recreational fisheries data in a timely  manner to support certain recreational fisheries management decisions.  In addition, NMFS and some state officials, as well as some other  stakeholders such as private recreational anglers, identified challenges  regarding how NMFS communicates with stakeholders about its marine  recreational fisheries data collection efforts.
Examples of NMFS’ challenges in obtaining quality recreational fishing  data through MRIP to inform scientific analyses and produce credible  effort and catch estimates include:  Identifying the universe of recreational anglers. NMFS faces a  challenge in obtaining complete information on the universe of  recreational anglers. According to NMFS officials, MRIP created a  national saltwater angler registry to obtain more complete information  about recreational anglers. However, this registry does not include  anglers if they are registered in states bordering the Atlantic Ocean  and Gulf of Mexico because NMFS granted those states exemptions  from the national registry. According to NMFS officials, NMFS relies  on state angler registries to identify the universe of recreational  anglers in those exempted states. However, some state angler  registries offer exemptions from fishing permit requirements, such as  for individuals under or over certain ages, and NMFS officials noted  that not all anglers comply with state licensing and registration  requirements. Therefore, these anglers do not appear on state angler  registries. As a result, NMFS does not have a complete list of  recreational anglers.
Obtaining sufficient coverage in effort surveys. According to some  state officials, NMFS faces challenges in ensuring that it covers the  full range of anglers among the participants it selects to participate in  fishing effort surveys so that they are representative of the overall  angler population. For example, NMFS has relied on its Coastal  Household Telephone Survey, which randomly selects participants  from all potential household telephone numbers in coastal counties, to  obtain information about shoreside and private boat fishing effort in  the Gulf of Mexico and the Atlantic coast. As a result, the survey does  not capture recreational anglers from noncoastal states that travel to  fish in the Gulf of Mexico or Atlantic coast, or coastal resident anglers  in households that do not have a landline phone. NMFS officials  acknowledged this limitation with the Coastal Household Telephone  Survey.
Targeting a representative sample in shoreside surveys.
According to NMFS officials, NMFS faces challenges in collecting  data on a portion of the recreational fishing sector since it generally  does not collect data on private property or at private-access fishing  sites. According to NMFS officials and other governmental  stakeholders, this is an issue in states that have many private-access  sites, such as California and Florida, because there may be a  significant portion of the recreational fishing sector that is not being  surveyed. As a result of this limitation, according to NMFS officials  and some state officials, NMFS relies on untested assumptions about,  for example, catch and discard rates for anglers that use private- access fishing sites to develop recreational catch estimates. However,  NMFS officials noted that survey data on fishing effort are collected  from anglers regardless of whether they fish from public or private- access fishing sites. In addition, according to one state official, NMFS’  standard protocols for determining when and where to assign  shoreside observers to conduct interviews may not take into account  local fishing patterns and, therefore, observers may not be located in  the right places at the right times to collect the most representative  data. For example, according to this official, NMFS’ protocols for  assigning shoreside observers do not account for the length of time  anglers would typically take to reach federal waters and return from  their trip. As a result, observers may not be at the shoreside when  anglers return.
Obtaining a sufficient number of survey responses and  biological samples. According to NMFS and some state officials,  NMFS faces the challenge of collecting a sufficient number of survey  responses and samples in its effort and catch surveys. For example,  some NMFS and state officials told us Coastal Household Telephone  Survey response rates have been declining, and a 2014 report  prepared for NMFS noted that response rates to the survey had  “declined considerably” in the previous decade, which could increase  the potential for bias in the data collected on recreational angler  fishing effort. Also, one state official told us he does not believe  NMFS assigns enough shoreside observers to collect the recreational  angler catch and discard data needed to develop precise recreational  catch estimates. In addition, another state official told us that the lack  of shoreside observers has contributed to an insufficient amount of  biological samples collected to adequately address scientific needs.  Consistent with these views, in 2013 NMFS’ Southeast Fisheries  Science Center identified a need for more fish tissue samples in its  region to aid in assessing fish stock reproduction.
Obtaining valid survey responses. According to some state and  NMFS officials, obtaining valid survey responses can be challenging  because they depend on anglers’ recollections of prior fishing events.  NMFS officials told us that the accuracy of self-reported data (i.e.,  data that rely on participants providing responses based on personal  observations) depends on the angler’s ability to recall events or to  distinguish between different fish species. However, anglers may not  be able to accurately recall details about fish they caught and then  discarded, especially as time elapses or because of limited knowledge  about fish species, and without independent validation or verification,  that data may be inaccurate. According to NMFS officials, these  challenges affect the Coastal Household Telephone Survey because  the survey asks anglers how many saltwater fishing trips were taken  in the previous 2 months, but it does not use observers or other  mechanisms to independently validate and verify this self-reported  data.
Obtaining key recreational fisheries data. According to NMFS and  some state officials, NMFS faces a challenge in collecting complete  data on discards—that is, fish that are caught but then released— because of the difficulty of validating and verifying self-reported data  as previously discussed. In light of this difficulty, Louisiana does not  collect recreational angler discard data as part of its own recreational  fisheries data collection program because of concerns about the  quality of angler self-reported data, according to a state official. Even  given the uncertainty in identifying the exact amount of discards, the  number of discards can be substantial—for example, according to  NMFS statistics, the majority of fish caught by marine recreational  fishermen in 2013 were discarded. NMFS officials told us that  discarded fish that have to return to great depths often experience  high mortality rates due to barotrauma. As a result of limited  information about the number of discarded fish and their mortality  rates, according to NMFS officials, NMFS relies on assumptions about  the mortality rates of discarded fish to produce or adjust recreational  catch estimates.
NMFS also faces challenges in collecting timely marine recreational  fishing data to support certain fisheries management decisions, according  to NMFS and some state officials we interviewed. According to NMFS  officials, the Magnuson-Stevens Reauthorization Act of 2006  implemented new requirements that have greatly expanded the pressures  on fisheries managers to rely on timely data to make decisions.  However, according to NMFS and some state officials, NMFS’ data  collection systems have not evolved quickly enough to support  management decision making. For example, it takes 2 months to conduct  the Coastal Household Telephone Survey, which collects data on  recreational fishing effort in the Gulf of Mexico and the Atlantic coast, and  about 45 days to analyze the data and produce recreational fishing  estimates. According to NMFS and some state officials, as a result of  these timing issues, NMFS managers do not have enough information to  make informed decisions about whether to initiate in-season closures for  certain fish stocks with annual catch limits in order to prevent anglers  from exceeding those limits. State officials frequently highlighted this as a  concern in managing the Gulf of Mexico red snapper, which is susceptible  to in-season closures because of concerns about overfishing. According  to NMFS documentation, this fishery has been subject to shortened  federal fishing seasons over the last few years—including seasons of 9  days in 2014 and 10 days in 2015, compared with 75 days in 2009 and 42  days in 2013.
NMFS, some state officials, and some other stakeholders, such as private  recreational anglers, have also identified challenges in how NMFS  communicates with stakeholders about its fisheries data collection efforts.  For example, a fisheries official from Texas said that, although Texas  provides NMFS with marine recreational fisheries data, NMFS does not  clearly communicate how or if it uses those data. Some private  recreational anglers also told us that NMFS has not always sufficiently  communicated with the public about its activities, creating concerns about  a lack of transparency regarding NMFS’ fisheries management decisions.  For example, some private anglers told us they are confused because  NMFS has not explained why it continues to shorten the Gulf of Mexico  red snapper fishing season even though the red snapper population has  increased. NMFS officials acknowledged that NMFS has not always  clearly communicated with regional stakeholders to explain its decision- making processes, stating that this has contributed to the public’s  misperceptions.
As a result of the challenges that have been identified with collecting  fisheries data, NMFS officials told us they face a lack of public confidence  and trust in their ability to provide the data needed for managing  recreational fisheries. For example, according to a Texas fisheries official,  Texas withdrew from NMFS’ recreational data collection program and  implemented its own data collection program in the late 1970s because it  did not believe that NMFS’ data collection methods suited Texas’ needs  for managing recreational fisheries. Similarly, in 2014, Louisiana withdrew  from MRIP and implemented its own recreational fisheries data collection  program, called LA Creel, because of concerns about MRIP data being  able to support Louisiana’s needs for managing recreational fisheries,  according to a Louisiana fisheries official. Similarly, according to state  officials, Mississippi and Alabama have also independently initiated  efforts to collect data on the abundance of certain fish, including red  snapper, in artificial reefs off the coasts of these states because of  concerns that NMFS’ current data collection methods underestimate the  abundance of these fish stocks. Citing dissatisfaction with NMFS’  management of the Gulf of Mexico red snapper fishery, the states  bordering the Gulf of Mexico released a proposal in March 2015 to  transfer the responsibility for managing Gulf of Mexico red snapper from  NMFS to these states.
section_title: NMFS Has Taken Steps Aimed at Improving Data Collection, but Some Challenges Persist and NMFS Does Not Have a Comprehensive Strategy to Guide Improvement Efforts
paragraphs: NMFS has taken several steps aimed at improving data collection to  manage marine recreational fisheries and addressing challenges related  to communicating with stakeholders. However, some data collection  challenges persist, and NMFS does not have a comprehensive strategy  to guide its efforts to improve recreational fisheries data collection.
subsections: section_title: NMFS Has Taken Steps Aimed at Improving Recreational Fisheries Data Collection, but Some Challenges Persist
paragraphs: NMFS has taken steps to address some of the challenges it faces in  collecting data for managing marine recreational fisheries, including steps  aimed at collecting quality data to support scientific analyses and  producing credible effort and catch estimates, improving the timeliness of  data collection, and improving communication with stakeholders.  However, even with the various steps NMFS has taken, agency officials  said that some challenges persist. In April 2015, NMFS requested that the  National Research Council review MRIP to determine the extent to which  NMFS has addressed the recommendations in the 2006 National  Research Council report. A NMFS official told us the National Research  Council has initiated the review process, and NMFS expects the review to  be completed in 2017.
subsections: section_title: Addressing Challenges in Collecting Quality Data
paragraphs: NMFS has taken several steps to address the challenges it faces in  collecting quality data. To address the challenge of identifying the  universe of recreational anglers, NMFS documents indicate that by  October 2011 NMFS had entered into memoranda of agreement with  states and United States territories that were exempt from the national  registry requirements, whereby these states and territories agreed to  submit their data on marine recreational fishing participants to NMFS for  inclusion into the national registry. In 2011 and 2012, NMFS provided  approximately 20 grants to states through the interstate marine fisheries  commissions to support initial data quality improvement projects.  Subsequently, in 2012 and 2013, NMFS received state angler registry  data from each of the exempted Atlantic and Gulf Coast states and  entered the data into the national registry database. During this same  period, NMFS made recommendations to the states on improving their  recreational angler databases. NMFS also continued to provide funds to  the states through the commissions to support the initial data quality  improvement projects, according to NMFS documents.
To address both regional and national needs for effort and catch data,  NMFS has supported the redesign of state and federally managed  surveys in all regions. For example, in 2009, NMFS initiated a series of  pilot studies to address declining participation rates in telephone  recreational fishing effort surveys and potential gaps in the data that could  skew survey results due to limitations in reaching coastal residences.  NMFS conducted these pilot studies to determine whether mail survey  methods for collecting recreational fishing effort data would improve  estimates. In a July 2014 report, NMFS stated that the findings from the  study indicated that mail survey response rates were nearly three times  higher than the telephone survey response rates. Given these results, in  May 2015, NMFS issued a plan for transitioning from the current Coastal  Household Telephone Survey to a newly designed mail-based survey,  referred to as the Fishing Effort Survey. According to NMFS  documentation, NMFS expects the Fishing Effort Survey to be fully  implemented by January 2018, as shown in figure 5.
In 2013, NMFS also issued new protocols for the Access Point Angler  Intercept Survey. Under these new protocols, NMFS assigns shoreside  observers to specific locations at precise times to address potential data  gaps related to where and when the data are collected. According to  NMFS officials, the new peer-reviewed survey design is intended to  provide complete coverage of fishing trips ending at public access sites  with representative sampling of trips ending at different times of day.
Also in 2013, NMFS initiated a science program review to help provide a  systematic peer review of its fisheries data collection programs at its six  regional Fisheries Science Centers and Office of Science and  Technology. As part of this effort, peer review panels evaluated NMFS’  data collection and management programs in 2013, subsequently issuing  a report identifying a number of crosscutting national challenges and  making several recommendations to address them. For example, the  report recommended that NMFS develop a plan for providing the data  necessary for conducting fish stock assessments.
NMFS has also initiated efforts to evaluate the potential of electronic  monitoring and reporting to address quality of data challenges. For  example, according to NMFS officials, as of October 2015, NMFS was  working with stakeholders in Florida to test the use of a smartphone- and  Internet-based electronic reporting tool called iAngler to collect and report  data on recreational effort and catch. NMFS is also working with Texas on  an electronic reporting tool called iSnapper to test the collection of self- reported catch data, according to NMFS officials. In addition, NMFS  issued a policy directive in May 2013 to provide guidance on the adoption  of electronic technologies to complement or improve existing fishery data  collection programs. In 2013, NMFS began working with its regional  Fisheries Science Centers to develop regional plans to identify, evaluate,  and prioritize the implementation of electronic monitoring and reporting  technologies. According to NMFS documents, each of NMFS’ regional  offices, in consultation with the Fisheries Science Centers, issued  implementation plans in January and February 2015 that include a focus  on using electronic technologies to improve the quality of recreational  fishing data and data timeliness. Figure 6 shows examples of electronic  monitoring and reporting technologies.
However, even with the various steps NMFS has taken, agency officials  said that some challenges persist. For example, according to NMFS  officials we interviewed, NMFS uses independent checks to either  validate self-reported data or estimate a reporting error that can be used  to produce unbiased estimates, but the agency faces challenges in  independently validating and verifying self-reported angler data. In  addition, NMFS officials told us the 2006 National Research Council  report contains recommendations that the agency has not yet addressed,  including developing methods for improving the accuracy of estimates for  the number of discarded fish and addressing the potential bias resulting  from the exclusion of private access sites from shoreside surveys. NMFS  officials agreed that additional effort should be undertaken through MRIP  to evaluate alternative methods for obtaining and verifying discard data.   According to NMFS officials, they initiated a process in October 2015 for  developing strategies to address these challenges.
section_title: Addressing Data Timeliness Challenges
paragraphs: NMFS has begun taking steps to improve the timeliness of its recreational  fisheries data to support certain fisheries management decisions but,  according to NMFS officials and stakeholders, this data timeliness  challenge has not been fully addressed. For example, according to NMFS  documentation, in fiscal year 2015, NMFS began studying the feasibility  of moving from a 2-month survey period to a 1-month survey period—that  is, conducting the survey each month to collect data on the previous  month’s fishing activity—in its new mail-based Fishing Effort Survey as a  way to help reduce recall errors and improve the precision and timeliness  of recreational fishing effort estimates. However, some stakeholders told  us that NMFS’ new mail-based Fishing Effort Survey will still not provide  enough timely data to inform in-season closure decisions for federal Gulf  of Mexico red snapper seasons. NMFS officials acknowledged limitations  with its approach, noting that in-season closure decisions are based on  the previous year’s recreational fishing catch estimates. According to  NMFS officials, beginning in 2013, NMFS coordinated a series of MRIP  workshops with fisheries officials from Alabama, Florida, Louisiana,  Mississippi, and Texas to discuss options for improving the timeliness of  data to support Gulf of Mexico red snapper in-season closure decisions.  NMFS officials told us that they will continue to collaborate with their Gulf  state partners to develop supplemental surveys focused on red snapper  that can be integrated with the more general MRIP survey approach.  According to NMFS officials, NMFS and the Gulf of Mexico Fisheries  Information Network recently developed a timeline that describes the  process and timing for making key decisions about future red snapper  specialized survey methods, as shown in figure 7. NMFS officials told us  as of October 2015 the states concurred with the timeline.
According to NMFS and a state official, addressing some of the data  collection challenges related to quality and timeliness entails making  trade-offs. For example, according to NMFS officials, NMFS also held a  workshop in March 2011 with several recreational fishing stakeholders,  such as states and councils, to address the need for more timely and  precise updates in a short-season fishery. NMFS officials told us the  workshop identified several ways in which improvements could be made,  but they concluded that more resources beyond what MRIP could afford  would be needed to implement those improvements. NMFS’ new Fishing  Effort Survey collects data on recreational fishing effort that targets many  fish stocks, including some that do not need timely data necessary to  make fishery management decisions within a shortened federal fishing  season. However, according to NMFS officials and a state official, to  implement a separate survey that specifically targets Gulf of Mexico red  snapper would likely entail adding additional resources to this effort that  would need to be taken from other surveys, such as the Fishing Effort  Survey. According to NMFS officials, trade-offs also are often necessary  to balance the competing needs of state and federal fisheries  management and, as a result, NMFS prioritizes among competing  demands for data. NMFS has attempted to address the need to  understand the trade-offs involved in data collection; according to NMFS  documentation, tools intended to help evaluate possible resource  allocation trade-offs were expected to be available for use in 2014.  However, according to NMFS officials, the tools were not in place as of  October 2015, and NMFS has not determined when the tools will be  available. The officials said that the tools were being developed in  collaboration with academia, but the project stalled because the project  leader left the academic institution, and the institution has not yet found a  replacement.
section_title: Addressing Challenges in Communication
paragraphs: NMFS has also taken steps to improve communication with recreational  fisheries stakeholders about recreational data collection. NMFS has  worked with its MRIP Executive Steering Committee to address priority  communication initiatives through various MRIP teams. For example, the  MRIP communications and education team plans to implement a  communications strategy—entailing various communication activities  such as webinars—to support the transition from the Coastal Household  Telephone Survey to MRIP’s new mail-based Fishing Effort Survey.  According to NMFS officials, the agency is developing an MRIP strategic  communications plan to guide its transition to the Fishing Effort Survey  that was expected to be finalized by the end of October 2015. To further  enhance MRIP communications, in 2014, the MRIP communications and  education team began restructuring its communications network by  developing MRIP communication teams at the regional level.
Some of NMFS’ steps to improve communication have resulted in  increased collaboration with recreational fisheries stakeholders, according  to NMFS and state officials. For example, according to a state fisheries  official, NMFS coordinated with the state to provide state officials greater  input in determining observer assignment schedules and locations as part  of the new protocols for the Access Point Angler Intercept Survey. NMFS  officials told us that they are also working collaboratively with Louisiana to  perform a side-by-side comparison of MRIP data with data collected  under Louisiana’s LA Creel data collection program, to determine whether  LA Creel can be used as an alternative to MRIP surveys. According to  NMFS officials, in early 2016, NMFS and Louisiana plan to evaluate the  results of the side-by-side comparison to determine next steps. Regarding  stakeholder concerns about NMFS’ lack of data on fish stock abundance  in reef habitats, NMFS officials told us that NMFS plans to use data  collected by academic partners on red snapper abundance on artificial  reefs in its Gulf of Mexico red snapper fish stock assessment. NMFS also  has worked with the Atlantic States Marine Fisheries Commission and the  Atlantic Coastal Cooperative Statistics Program to transition from a  NMFS-led data collection system to a state-led data collection approach.  In 2016, according to a NMFS official, the Atlantic Coast states will  assume responsibility for conducting the Access Point Angler Intercept  Survey shoreside interviews to collect marine recreational fishing data  from anglers, and NMFS’ role will be to review, certify, and provide funds  to support these data collection efforts.
NMFS is also placing renewed emphasis on collaborating with its regional  partners to determine future data collection needs and priorities for  improving recreational fisheries effort and catch surveys, according to  NMFS documents. For example, NMFS’ 2013-2014 MRIP implementation  plan recommended establishing a hybrid approach to MRIP data  collection. Under this approach, NMFS is to maintain a central role in  developing and certifying survey methods and establishing national  standards and best practices for data collection, while regions—through  the regional fishery information networks or their equivalent—are to be  responsible for selecting survey methods and managing data collection.  According to NMFS officials and NMFS documentation, NMFS staff  participated in a workshop in July 2013 to discuss the initial planning  stages for developing this new regional approach to recreational fisheries  data collection. According to NMFS officials, NMFS is developing MRIP  Regional Implementation Plans to address regional data collection needs  and priorities. The NMFS officials said that the West Coast region is  scheduled to have a Regional Implementation Plan in early 2016. The  officials said the Atlantic and Gulf Coast regions support the new  approach to data collection and plan to complete their respective MRIP  Regional Implementation Plans in 2016. As part of the new hybrid MRIP  data collection approach, NMFS is in the process of identifying regional  recreational fisheries data collection funding priorities.
Challenges related to how NMFS communicates with stakeholders,  however, persist. For example, some Gulf Coast state fisheries officials  expressed concerns that NMFS has not provided sufficient information to  improve communication regarding its recreational fisheries data collection  activities. One state fisheries official said that NMFS has made some  progress working with stakeholders to identify MRIP initiatives to improve  recreational fisheries data collection, but it has not adequately  communicated how it intends to coordinate and collaborate with its  stakeholders to implement MRIP initiatives. Some stakeholders continue  to express concerns that NMFS is not adequately communicating its  process for developing Gulf of Mexico red snapper catch and effort  estimates. For example, some stakeholders cited the presence of larger  and more numerous red snapper in the Gulf of Mexico and do not  understand the need for continued catch limits and fishing restrictions.  NMFS officials told us that, although the Gulf red snapper population is  rebounding, and the average weight of red snapper that are caught by  anglers has increased, NMFS’ most recent stock assessment confirms  that Gulf red snapper continue to be overfished. Therefore, as required by  the Magnuson-Stevens Act, red snapper continue to be managed under a  stock rebuilding plan. According to these officials, annual catch limits for  red snapper are being reached more quickly due to several factors,  including higher catch rates and more fishing effort being directed at the  more abundant rebuilding stock. This has required even shorter fishing  seasons despite increasing stock abundance, as well as corresponding  increases to annual catch limits. NMFS officials stated that, in response to  a history of exceedance of annual red snapper catch limits and litigation,  NMFS is now setting the length of the red snapper fishing season based  on a recommendation by the Gulf of Mexico Fishery Management Council  to use a buffer of 20 percent of the annual catch limit. This buffer is  intended to account for uncertainty resulting from the difficulty of obtaining  timely and precise catch estimates, as well as uncertainty stemming from  state regulations that provide for longer seasons in state waters. NMFS  officials acknowledged that achieving stakeholder understanding of this  complex process is an ongoing concern, but they told us they plan to  continue communicating with stakeholders to help convey the rationale  behind NMFS’ fisheries management decisions.
section_title: NMFS Does Not Have a Comprehensive Strategy to Guide Its Data Collection Improvement Efforts
paragraphs: NMFS has taken steps aimed at addressing several data collection  challenges, but it does not have a comprehensive strategy to guide its  efforts to improve recreational fisheries data collection. The Government  Performance and Results Act Modernization Act of 2010 requires, among  other things, that federal agencies develop long-term strategic plans that  include agency-wide goals and strategies for achieving those goals. Our  body of work has shown that these requirements also can serve as  leading practices at lower levels within federal agencies, such as at  NMFS, to assist with planning for individual programs or initiatives that  are particularly challenging. Taken together, the strategic planning  elements established under the act and associated Office of Management  and Budget guidance, and practices we have identified, provide a  framework of leading practices in federal strategic planning and  characteristics of good performance measures. These practices include  defining a program’s or initiative’s goals, defining strategies and  identifying the resources needed to achieve the goals, and developing  time frames and using performance measures to track progress in  achieving them and inform management decision making. Furthermore,  key practices related to communication call for communicating  information early and often and developing a clear and consistent  communications strategy to help develop an understanding about the  purpose of planned changes, build trust among stakeholders and the  public, cultivate strong relationships, and enhance ownership for  transition or transformation.
According to a NMFS official, the initial 2008 MRIP implementation plan  and the subsequent updates are the key documents used to guide NMFS’  recreational fisheries data collection efforts. However, based on our  review, NMFS’ MRIP implementation plans do not constitute a  comprehensive strategy for improving recreational fisheries data  collection consistent with the framework previously discussed. For  example, the implementation plans do not consistently and clearly define  NMFS’ goals, identify the resources needed to achieve the goals, or  develop time frames or performance measures to track progress in  achieving them.
Based on our analysis, NMFS does not have a comprehensive strategy  because it has been focused primarily on implementing the  recommendations of the 2006 National Research Council report. A NMFS  official confirmed that MRIP initially focused on implementing the  recommendations in the 2006 National Research Council report and  meeting the requirements to improve recreational fisheries data collection  as described in the Magnuson-Stevens Reauthorization Act that was  passed in 2006. According to NMFS officials, the agency’s first priority  was to address the recreational fisheries survey design issues identified  in the 2006 National Research Council report. Specifically, NMFS  determined that it would first design, test, review, certify, and implement  new survey designs, such as the new mail-based Fishing Effort Survey.  As previously discussed, NMFS intends to transition to a regional data  collection approach whereby the agency will collaborate with regional  stakeholders, such as states, to identify regional data collection needs.  NMFS officials told us that, in hindsight, NMFS could have benefited from  a more robust strategic planning approach to MRIP implementation and  stated that NMFS recognizes the need to enhance its strategic planning  as it begins to transition to a regional data collection approach. NMFS  officials told us that NMFS intends to develop strategic planning  documents to guide future individual initiatives, using NMFS’ experiences  with the transition to the new mail-based Fishing Effort Survey as a  template, but they did not provide information about how, or whether, they  planned to integrate these documents into a comprehensive strategy or  how they would communicate such a strategy to NMFS’ stakeholders.  Without a comprehensive strategy, NMFS may have difficulty ensuring  that the variety of steps it is taking to improve data collection are  prioritized so that the most important steps are undertaken first and may  find it difficult to determine the extent to which these steps will help  address challenges. Further, without communicating the strategy and  NMFS’ progress in implementing it, NMFS may have difficulty building  trust among its stakeholders, and these stakeholders may have difficulty  tracking the agency’s efforts.
section_title: Conclusions
paragraphs: Recognizing the importance of collecting quality and timely data at an  acceptable cost to guide recreational fisheries management and conduct  fish stock assessments, NMFS has taken many steps to improve its data  collection, such as funding several pilot programs to test alternative data  collection methods. NMFS has also initiated a fundamental shift in its data  collection approach, envisioning a standard-setting and oversight role for  NMFS rather than actual data collection, which is to be carried out by  partners. However, NMFS does not have a comprehensive strategy to  guide the implementation of its various efforts. Without a comprehensive  strategy and associated performance measures to assess progress,  NMFS may have difficulty ensuring that the variety of steps it is taking to  help address the challenges it faces are prioritized so that the most  important steps are undertaken first. Likewise, NMFS may have difficulty  determining the extent to which these steps will help address challenges  or if a different approach may be needed. Moreover, without clearly  communicating the strategy to its stakeholders, NMFS may find it difficult  to build trust, potentially limiting its ability to effectively implement MRIP  improvement initiatives that rely on data collection partners.
section_title: Recommendation for Executive Action
paragraphs: To improve NMFS’ ability to capitalize on its efforts to improve fisheries  data collection for managing marine recreational fisheries, we  recommend that the Secretary of Commerce direct NOAA’s Assistant  Administrator for Fisheries to develop a comprehensive strategy to guide  NMFS’ implementation of its marine recreational fisheries data collection  program efforts, including a means to measure progress in implementing  this strategy and to communicate information to stakeholders. As part of  this strategy, NMFS should clearly identify and communicate  programmatic goals, determine the program activities and resources  needed to accomplish the goals, and establish time frames and  performance measures to track progress in implementing the strategy  and accomplishing goals.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Commerce for  comment. In its written comments (reproduced in app. II), NOAA,  providing comments on behalf of Commerce, agreed with our  recommendation that NMFS develop a comprehensive strategy to guide  the implementation of its marine recreational fisheries data collection  program efforts. NOAA stated that it agrees that transitioning from a  primarily research and development focused program to one that is more  focused on implementing improvements to recreational fisheries data  collection presents an opportunity to engage in strategic planning.  Specifically, NOAA stated it will work with its regional stakeholders over  the next year to develop MRIP implementation plans that include  milestones, timelines, performance metrics, and resource needs. In  addition, NOAA stated that a new National Research Council review of its  recreational fisheries data collection program will help to inform its  strategic planning effort.
NOAA also provided three general comments. First, NOAA stated that our  report disproportionally included interviewees from the Gulf Coast, which  may weigh the report’s conclusions differently than if other regions were  more fully represented. As noted in our scope and methodology appendix  (app. I), we selected federal and state agencies and regional  organizations to interview based on such factors as geographic  representation and locations of large volumes of recreational fishing.  According to NMFS statistics, the largest volumes of recreational fishing  are in the Gulf of Mexico. As a result, we believe that our selection of  agencies and organizations, while not nationally representative,  nevertheless provides an appropriate set of perspectives on recreational  fisheries management. Second, NOAA stated that it interpreted our  statement that we did not conduct a technical evaluation to mean that we  are suggesting that a technical evaluation is needed to determine whether  NMFS has appropriately prioritized its recreational fisheries data  collection challenges. We did not conduct a technical evaluation because  it was not within the scope of our review, and it was not our intent to  suggest that a technical evaluation is needed. Third, NOAA stated that,  while the report identifies several unaddressed recreational fisheries data  collection challenges, it does not mention that the challenges require  funding levels above the current MRIP budget. Addressing whether  NMFS funding levels are sufficient to address the data collection  challenges it faces was not within the scope of our review. We do,  however, note in our report the importance of making trade-offs in  addressing challenges and allocating resources. NOAA also provided  technical comments, which we incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of Commerce, the NOAA  Assistant Administrator for Fisheries, and other interested parties. In  addition, the report will be 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. Key contributors to this report are listed in  appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to examine (1) the challenges that have been  identified with the National Marine Fisheries Service’s (NMFS) data  collection efforts for managing marine recreational fisheries and (2) the  steps NMFS has taken to improve data collection and challenges that  remain.
To conduct our work, we reviewed and analyzed relevant laws, agency  policies, guidance, and other documentation related to fisheries data  collection, including documentation related to specific federal and state  marine recreational fisheries data collection projects. We also reviewed  previous GAO work related to fisheries management. To determine the  challenges that have been identified with NMFS’ data collection efforts,  we first reviewed reports and evaluations of NMFS’ data collection  programs issued since 2006 from the National Research Council, the  Department of Commerce Inspector General, NMFS, states, and  independent consultants and assessed the extent to which they  discussed data collection challenges. Of these reports, we relied  primarily on the findings of the National Research Council and NMFS to  identify data collection challenges. To obtain insights into the challenges  identified in these documents, as well as to obtain information on any  additional challenges, we interviewed officials from NMFS headquarters  and three of NMFS’ six regional Fisheries Science Centers (Northeast,  Northwest, and Southeast); representatives of three of the eight Regional  Fishery Management Councils (Gulf of Mexico, Pacific, and South  Atlantic) and all three interstate Marine Fisheries Commissions (Atlantic,  Gulf, and Pacific States); and officials from state fisheries agencies in  Alabama, Florida, Louisiana, Mississippi, North Carolina, Rhode Island,  Texas, and Washington. We selected federal and state agencies and  regional organizations to interview based on such factors as geographic  representation, locations of large volumes of recreational fishing, and  representation from key data collection and management stakeholders.  The views of representatives from the agencies and organizations we  contacted are not generalizable to other agencies and organizations, but  they provided various perspectives on recreational fisheries management.  In addition, to obtain additional information about data collected by the  recreational fishing sector and challenges associated with data collection,  as well as to obtain views on recreational fisheries data collection  generally, we interviewed 22 nongovernmental marine recreational  fisheries stakeholders. Of these stakeholders, 17 had expressed interest  in, or concerns about, NMFS’ recreational fisheries data collection to  congressional staff. These stakeholders added to the geographic  variation and the recreational fishing sectors represented in our review,  but their views do not represent the views of NMFS stakeholders  generally. To supplement views on recreational fisheries data collection,  we interviewed 5 additional stakeholders, including 4 stakeholders  identified by NMFS and 1 stakeholder we identified through our previous  work on fisheries management. The 22 stakeholders we interviewed  included charter boat owners, private recreational anglers, members of  academia, and advocacy groups, among others, and represented various  geographic locations and different recreational fishing sectors. The NMFS  statistical surveys used to collect data for managing recreational fisheries  cover a wide range of methods, apply to a wide diversity of locations and  often entail in-depth technical knowledge about fisheries data collection.  For these reasons, we did not conduct a technical evaluation of these  challenges or assess their technical validity.
To determine the steps NMFS has taken to improve data collection and  challenges that remain, we conducted interviews as described above and  reviewed NMFS’ reports and other documents. Specifically, we reviewed  NMFS’ strategic plans, recreational fisheries planning documents, and  recreational fisheries data collection program documents. We compared  this information with the framework of leading practices in federal  strategic planning contained in the Government Performance and Results  Act of 1993, the Government Performance and Results Act Modernization  Act of 2010, and Office of Management and Budget guidance. We also  compared this information to key practices related to communication we  identified in previous reports. Consistent with our approach to the  previous objective, we did not conduct a technical evaluation of NMFS’  steps to improve data collection or assess the appropriateness of those  steps in light of the challenges NMFS faces.
We conducted this performance audit from July 2014 to December 2015  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.
section_title: Appendix II: Comments from the Department of Commerce
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Steve Gaty (Assistant  Director), Steve Secrist (Assistant Director), Leo Acosta (Analyst-in- Charge), Mark Braza, Joseph Capuano, Elizabeth Curda, John Delicath,  Richard Johnson, Jerry Leverich, Jeanette Soares, and Sara Sullivan  made contributions to this report.