Federal Fisheries Management: Additional Actions Could Advance Efforts to Incorporate Climate Information into Management Decisions
Published: 2016-09-28T00:00:00

Fast Facts:
As the climate changes and ocean temperatures rise, the abundance, distribution, and life cycles of fish in federally-managed ocean fisheries may change too. Federal agencies managing ocean fisheries have limited information to determine exactly how climate change might harm specific fish populations, and may not always understand the potential effects. The National Marine Fisheries Service is in the early stages of implementing its strategy to increase the use of climate information in fisheries management.
We made two recommendations to help NMFS better manage climate-related risks to fisheries.

Highlights:
section_title: Why GAO Did This Study
paragraphs: NMFS and the Councils manage commercial and recreational marine fisheries that are critical to the nation's economy. The effects of climate change may pose risks to these fisheries that could have economic consequences for the fishing industry and coastal communities, according to the 2014 Third National Climate Assessment.
GAO was asked to review federal efforts to address the effects of climate change on federal fisheries. This report examines (1) information NMFS and the Councils have about the existing and anticipated effects of climate change on federally managed fish stocks and challenges to better understand these effects and (2) efforts NMFS has taken to help it and the Councils incorporate climate information into fisheries management. GAO analyzed responses to its questionnaire from all NMFS regions and the Councils, analyzed seven nongeneralizable fish species selected to reflect variation in the potential effects of climate change, reviewed relevant documentation, and interviewed NMFS and Council officials.
section_title: What GAO Found
paragraphs: The Department of Commerce's National Marine Fisheries Service (NMFS) and eight Regional Fishery Management Councils (Council) have general information on the types of effects climate change is likely to have on federally managed fish stocks but limited information on the magnitude and timing of effects for specific stocks. They also face several challenges to better understand these effects, based on GAO's analysis of NMFS and Council questionnaire responses, NMFS and Council documentation, and interviews with NMFS and Council officials. For example, NMFS officials said that northern rock sole may adapt to warming ocean temperatures more easily than other fish species, but it is unknown how such temperatures may affect the timing of the fish's life cycle events, such as spawning. NMFS and Council officials identified several challenges to better understand potential climate change effects on fish stocks, including determining whether a change in a stock's abundance or distribution is the result of climate change or other factors, such as overfishing in the case of Atlantic cod.
NMFS developed a climate science strategy in 2015 to help increase the use of climate information in fisheries management. The strategy lays out a national framework to be implemented by NMFS' regions but does not provide specific guidance on how climate information should be incorporated into the fisheries management process. An NMFS official said that developing such guidance has not been an agency priority, but as knowledge on climate change progresses there is a more pressing need to incorporate climate information into fisheries management decision making. Developing such guidance would align with federal standards for internal control and may help NMFS ensure consistency in how its regions and the Councils factor climate-related risks into fisheries management. In addition, NMFS has not developed agency-wide performance measures to track progress toward the strategy's overall objectives, a leading practice. NMFS officials said they are waiting to finalize regional action plans for implementing the strategy before determining whether such measures may be necessary. GAO reviewed the proposed measures in NMFS' draft regional action plans and found that they aligned with some key attributes of successful performance measures. But, most of the measures did not contain other key attributes, such as measurable targets. By incorporating key attributes when developing performance measures and assessing whether agency-wide measures may also be needed, NMFS may be in a better position to determine the extent to which the objectives of its strategy overall are being achieved.
section_title: What GAO Recommends
paragraphs: GAO recommends that NMFS (1) develop guidance on incorporating climate information into the fisheries management process and (2) incorporate key attributes of successful performance measures in the regional action plans and assess whether agency-wide measures for the climate science strategy may be needed. The agency agreed with GAO's recommendations.

section_title: Letter
paragraphs: Commercial and recreational marine fisheries are critical to the nation’s  economy, contributing approximately $100 billion to the U.S. gross  domestic product and supporting more than 1.8 million jobs in 2014.  These fisheries may be vulnerable to the increasing effects of climate  change in the oceans—including physical changes such as warmer  surface temperatures and chemical changes such as higher acidity  levels—which could affect the abundance and distribution of fisheries,  according to the U.S. Global Change Research Program’s 2014 Third  National Climate Assessment. This assessment also reports that  changes in the abundance and distribution of certain fisheries could have  economic consequences for the communities and industries that depend  on harvesting the affected fish, for example, by reducing the availability of  some commercially and recreationally important fish species.
The federal government serves as a financial backstop to the fishing  industry by providing disaster assistance in the event of a fishery disaster.  For example, a fishery disaster can be declared after the Secretary of  Commerce determines that a commercial fishery failure under certain  conditions has occurred. The federal government provided more than  $640 million in federal fishery disaster assistance from 2005 through  2015, according to Department of Commerce data. The effects of climate  change could negatively affect fisheries and contribute to future fishery  disasters, according to the Department of Commerce’s National Oceanic  and Atmospheric Administration (NOAA). The effects of climate change,  in general, may also increase the fiscal exposure to the federal  government—limiting the federal government’s fiscal exposure by better  managing climate change risks has been on our high-risk list since 2013,  in part, because of concerns about the increasing costs of federal disaster  response and recovery assistance.
NOAA is the lead federal agency responsible for managing commercial  and recreational marine fisheries. Specifically, the Magnuson-Stevens  Fishery Conservation and Management Act of 1976, as amended  (Magnuson-Stevens Act), sets forth national standards for federal  fisheries conservation and management. Under the act, NOAA’s  National Marine Fisheries Service (NMFS) and eight Regional Fishery  Management Councils (Council) are responsible for fisheries  management and conservation in federal waters. NMFS generally serves  as the lead agency—in collaboration with partners from the states,  academia, and elsewhere—for developing scientific information on  federally managed fish stocks, including through stock assessments— reports that contain information on fish biology, abundance, and  distribution. NMFS and the Councils then use this information to develop  and implement fishery management plans, which contain practices  fisheries managers are to follow in managing each fishery and in setting  annual catch limits. Annual catch limits establish the limit on the amount  of fish that can be harvested annually for specific fish stocks.
You asked us to review federal efforts to address the effects of climate  change on federal fisheries management. This report examines              (1) information NMFS and the Councils have about the existing and  anticipated effects of climate change on federally managed fish stocks  and challenges they face to better understand these effects and             (2) efforts NMFS has taken to help it and the Councils incorporate climate  information into the fisheries management process.
To examine information NMFS and the Councils have about the effects of  climate change on federally managed fish stocks and challenges they  face to better understand these effects, we reviewed scientific studies and  other documentation prepared by NMFS, the Councils, and others such  as academics. We also developed a questionnaire of open-ended  questions, which we disseminated to the five NMFS regional offices and  the eight Councils to obtain their views on the information they have  about the effects of climate change on the fish stocks they manage and  any challenges they face to better understand these effects, among other  things. All five NMFS regions and the eight Councils responded. We  analyzed their responses to identify key themes, which we attribute in this  report to NMFS and Council officials. In addition, we analyzed a  nongeneralizable sample of seven fish species as case studies. We  selected the seven species to reflect a range of potential effects of  climate change and variation in the value and volume of commercial  harvests, based on NMFS’ commercial fisheries data from 2008 to 2013.  We assessed the reliability of these fisheries data and found them to be  sufficiently reliable for the purpose of selecting case study species.
To examine efforts NMFS has taken to help it and the Councils  incorporate climate information into the fisheries management process,  we analyzed the questionnaire responses provided by the NMFS regions  and Councils and reviewed agency and Council documentation, such as  the NOAA Fisheries Climate Science Strategy (Strategy). We compared  this information to leading practices in risk management and federal  standards for internal control and assessed the Strategy against leading  practices in strategic planning and performance measurement. For both  objectives, we also interviewed officials from NMFS’ headquarters and  two regions (Greater Atlantic and Alaska), as well as representatives from  four Councils (New England, Mid-Atlantic, South Atlantic, and North  Pacific) and the Atlantic States Marine Fisheries Commission. To obtain  broader perspectives, we also interviewed representatives from 11  stakeholder organizations selected to reflect geographic diversity and  different types of involvement in fisheries management issues, including  fishing industry groups, conservation groups, and a nonprofit serving  Alaska Natives. Appendix I contains a more detailed description of our  objectives, scope, and methodology.
We conducted this performance audit from November 2014 to September  2016 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: NMFS—operating through its headquarters, five regional offices, and six  regional Fisheries Science Centers—and the eight Councils are  responsible for managing approximately 470 fish stocks in federal waters  across five geographic regions of the country (see fig. 1 for the NMFS  region and Council boundaries). Federal waters generally extend from 3  to 200 nautical miles off the coast of the United States. In fiscal year  2016, NMFS’ budget for its fisheries science and management activities,  such as conducting stock assessments and developing fisheries  management guidance, was approximately $536.7 million, according to  NOAA budget documents.
NMFS has overall responsibility for collecting data on fish stocks and  ocean conditions and for generating the scientific information necessary  for the conservation, management, and use of marine resources. The  agency’s six regional Fisheries Science Centers are the primary entities  responsible for performing this work, and they collaborate with a variety of  partners, such as coastal states, academics, other nations, and members  of the fishing industry in doing so. For many fish stocks, the regional  Fisheries Science Centers analyze the collected data to conduct stock  assessments to estimate, among other things, the size of the population  of a fish stock (i.e., the stock’s abundance) and other population  dynamics. In addition, stock assessments contain information on  reference points that can be used to inform management decisions.  NMFS provides the results of its stock assessments and other analyses,  as appropriate, to the Councils for use in implementing their respective  fisheries management responsibilities.
The Councils are responsible for a number of steps in the fisheries  management process. In particular, the Councils develop and amend  fishery management plans for fish stocks, based on guidelines developed  by NMFS. Fishery management plans identify, among other things, the  conservation and management measures that will be used to manage a  fishery, such as fishing equipment restrictions, permitting policies, and  restrictions on the timing or location of permissible fishing. The  Magnuson-Stevens Act requires the conservation and management  measures in fishery management plans to be based on the best scientific  information available. The Councils submit proposed plans and plan  amendments to NMFS, which is responsible for determining if they are  consistent with the Magnuson-Stevens Act and other applicable laws, and  for issuing and enforcing final regulations to implement approved plans.
In implementing fishery management plans, the Councils are responsible  for determining the maximum size of each fish stock’s allowable  harvest. This is generally done by developing annual catch limits for  each fish stock, that is, the amount of fish that can be harvested in the  year. Figure 2 presents an overview of the federal fisheries management  process.
subsections: section_title: Climate Change Effects on Ocean Environments
paragraphs: According to the 2014 Third National Climate Assessment, a number of  physical and chemical changes to the oceans have been observed or are  expected to occur as a result of climate change, largely attributable to  increasing concentrations of greenhouse gases in the atmosphere, such  as carbon dioxide. For instance, surface temperatures for the ocean  surrounding the United States and its territories warmed by more than 0.9  degrees Fahrenheit over the past century, according to the 2014  assessment. Changes in ocean temperature have varied, with the oceans  off the coasts of Alaska and parts of the northeastern United States, for  example, warming more rapidly than other areas. The 2014 assessment  notes that warming has several consequences and can lead to a number  of other physical changes in the ocean, such as the thermal expansion of  sea water, which may contribute to rising sea levels. Increases in ocean  surface temperatures may also alter ocean circulation by reducing the  vertical mixing of water that brings nutrients to the surface and oxygen to  deeper waters, which could affect the availability of nutrients and oxygen  for marine life in different locations, according to the 2014 assessment.
Increasing levels of carbon dioxide in the atmosphere have also  contributed to chemical changes in the oceans. According to the National  Research Council, scientists estimate that the world’s oceans have  absorbed approximately 30 percent of the carbon dioxide emitted by  human activities over the past 200 years. As atmospheric  concentrations of carbon dioxide increase, the amount of carbon dioxide  in the oceans also increases. The increased uptake of atmospheric  carbon dioxide is resulting in chemical changes in the oceans, including a  decrease in the average pH of surface ocean waters (making seawater  more acidic) and a reduction in the availability of minerals needed by  many marine organisms to build shells and skeletons, according to the  National Research Council. These chemical changes, known as ocean  acidification, may pose risks for some marine species and ecosystems.  For the purposes of this report, our discussion of the effects of climate  change refers to both physical and chemical changes in the oceans.
section_title: Risk Management as a Strategy for Managing Climate-Related Risks to Fisheries
paragraphs: Broadly defined, risk management is a strategic process for helping  decision makers assess risk, allocate finite resources, and take action  under conditions of uncertainty, such as when faced with incomplete  information or unpredictable outcomes that may have negative impacts.  Risk management is an inherent part of fisheries management, as  fisheries managers often make decisions based on incomplete data and  in the face of uncertainty. Accounting for the potential effects of climate  change injects an additional source of uncertainty and risk into the  fisheries management process. The federal government has recognized  the need to account for climate change risks in its planning and programs  and has called on agencies to take certain actions. For example, the  President issued Executive Order 13653 in 2013, directing federal  agencies to develop or update comprehensive climate change adaptation  plans that among other things identify climate-related impacts on and  risks to an agency’s ability to accomplish its missions, operations, and  programs and describe the actions the agency will take to manage  climate risks. Subsequently, the Department of Commerce’s 2014  Climate Change Adaptation Strategy set a goal to incorporate climate  information in the department’s resource management programs and  policies and to take action to reduce vulnerabilities and increase  resilience of marine and coastal natural resources.
We have previously reported on risk management in the context of  climate change and identified risks that climate change may pose in a  variety of areas relevant to the federal government, such as infrastructure  and federal supply chains. We found that leading risk management  guidance recommends a sequence of activities that begins, in part, with  identifying risks. Specifically, the International Organization for  Standardization’s standards on risk management recommend that  organizations such as federal agencies develop, implement, and  continuously improve a framework for integrating risk management into  their overall planning, management, reporting processes, and policies.  These standards also state, among other things, that risk management  should be a part of decision making and that it should be based on the  best available information.
section_title: NMFS and the Councils Have Limited Information on the Magnitude and Timing of Climate Change Effects on Fish Stocks
paragraphs: We found that NMFS and the Councils have general information about  the types of effects climate change is likely to have on federally managed  fish stocks, but information about the magnitude and timing of effects for  specific fish stocks is limited, based on the responses NMFS and the  Councils provided to our questionnaire, our analysis of NMFS and  Council documentation, and our interviews with NMFS and Council  officials. In addition, NMFS and the Councils identified several challenges  they face to better understand the effects of climate change, such as  determining the extent to which a change in a fish stock’s abundance or  distribution is caused by climate change, natural variation in the oceans,  or other human or environmental factors.
subsections: section_title: NMFS and the Councils Have Limited Information on the Magnitude and Timing of Climate Change Effects on Fish Stocks
paragraphs: Through our analysis, we found that NMFS and the Councils have  general information about the types of effects climate change is likely to  have on fish stocks, but information about the magnitude and timing of  effects for specific fish stocks is limited. In general, the types of effects  climate change is likely to have include changes in fish stock abundance  and distribution and the timing or location of biological events such as  spawning (the process by which fish reproduce), according to NMFS and  Council officials. These effects will not be uniform across fish stocks but  rather will likely vary, with the abundance of some stocks being negatively  affected and the abundance of other stocks increasing or not being  affected, according to NMFS documentation. Similarly, potential shifts in  distribution will vary, as some fish stocks may respond to changing ocean  temperatures by moving north or to deeper waters in search of the water  temperatures they are accustomed to, but shifts in other directions may  occur as well. Some NMFS and Council officials said that changes in the  timing and location of biological events are also expected to vary between  fish stocks. For example, some fish stocks may spawn at different times  or in different locations under warmer ocean conditions.
In some instances, the abundance or distribution of fish stocks may shift  in response to changes in ocean habitats occurring because of a  changing climate. For example, reductions in seasonal sea ice cover and  warmer ocean surface temperatures may open up new habitats in polar  regions that could lead to shifts in distribution for some fish species,  according to the 2014 Third National Climate Assessment. Furthermore,  warming ocean temperatures and higher acidity levels also affect the  health of coral reefs, which provide essential habitat for many fish  stocks. The 2014 assessment reported, for example, that scientific  research indicated that 75 percent of the world’s coral reefs were under  threat from the effects of climate change and local stressors, such as  overfishing, nutrient pollution, and disease. When water is too warm,  corals will expel the algae living in their tissues, causing the coral to turn  completely white—this phenomenon, known as coral bleaching, can  cause coral to die or become more susceptible to disease, which can  subsequently decrease their capacity to provide shelter and other  resources for reef-dependent fish and other ocean life, according to the  2014 assessment.
We found that NMFS and the Councils have limited scientific information  about the magnitude and timing of potential climate change effects for  most fish stocks they manage. For example, officials from one Council  reported that they have very little scientific information specific to how  climate change is currently affecting the fish stocks in their region, or how  those stocks may be affected in the future, with the exception of some  anecdotal information. NMFS and Council officials explained that  scientific information is often lacking to quantify the magnitude and timing  of effects for most individual fish stocks and that their ability to project  future effects at the stock level is generally limited. For instance, NMFS  and Council officials in the Alaska region reported that they have  information sufficient to project potential climate change effects on  abundance for 3 of the 35 primary fish stocks they manage in their  region. And, as reflected in the examples below, for those stocks where  they are able to project potential effects, they are uncertain about the full  range of effects those stocks might experience.
Northern Rock Sole  The northern rock sole is a flatfish with both  eyes on one side of its head. Northern rock sole  live on the ocean floor and prefer a sandy or  gravel ocean bottom. In the United States,  northern rock sole are found from the Puget  Sound through the Bering Sea and the Aleutian  Islands. Northern rock sole are cooperatively  managed by the National Marine Fisheries  Service’s (NMFS) Alaska region and the North  Pacific Fishery Management Council. In 2014,  the commercial harvest for the rock sole fishery  (which includes northern rock sole and southern  rock sole) was valued at approximately $18.2  million, according to NMFS data.
Northern rock sole. NMFS officials in the Alaska region said that  their research on northern rock sole has shown that the juvenile fish  may have increased odds of surviving to become adults under warmer  ocean conditions, which could have a positive effect on their  abundance. NMFS officials said that the research indicates that  northern rock sole can adjust their diets to survive in a variety of  habitats and therefore may be able to adapt to ecosystem changes  such as warming ocean temperatures more easily than other fish  species. In general, NMFS and Council officials from the Alaska  region said that they do not anticipate the effects of climate change on  the abundance of northern rock sole to be significant, but  acknowledged that it is unknown how warming ocean conditions may  affect the timing or location of the fish’s life cycle events, such as  spawning.
Walleye Pollock  Walleye pollock are a member of the cod  family and have a speckled coloring that helps  them blend with the seafloor to avoid  predation. They are a schooling fish distributed  broadly in the North Pacific Ocean and in the  Bering Sea, with the largest concentrations in  the United States being found in the eastern  Bering Sea. Walleye pollock are cooperatively  managed by the National Marine Fisheries  Service’s (NMFS) Alaska region and the North  Pacific Fishery Management Council. The  pollock fishery is the largest commercial  fishery by volume in the United States, and in  2014, its commercial harvest was valued at  approximately $399.9 million, according to  NMFS data.
Walleye pollock. NMFS officials in the Alaska region said that they  can project some future effects of warming ocean temperatures on the  abundance of walleye pollock. For instance, the officials told us that  research indicates warming ocean temperatures could lead to a  mismatch between the size of the pollock population and the  availability of food sources for pollock to consume. Unusually warm  winters in the Alaska region in the early 2000s caused seasonal ice to  retreat earlier and farther than normal, which led to reductions in the  amount of zooplankton available for young pollock to eat, according to  NMFS officials. When young fish do not have sufficient food in their  first year of life, the likelihood they will survive is reduced, and  according to NMFS officials, the reduction in zooplankton led to a  reduction in the pollock population. The officials did not attribute the  warmer ocean temperatures during this time to climate change, but  they said this event helped them forecast potential future climate  effects by providing an opportunity to observe how pollock respond to  changes in the environment similar to those anticipated from climate  change. However, NMFS officials we interviewed said that making  further predictions about the magnitude of potential climate change  effects on the abundance and distribution of pollock is difficult  because of the limited amount of climate-related information specific  to the species. Agency officials told us that additional research is  under way to better understand the effects of warmer ocean  temperatures on pollock.
To better understand which fish species may be most vulnerable to  climate change, NMFS initiated an effort to systematically assess the  vulnerability of marine species to a changing climate. Specifically, in  2015, NMFS developed a methodology for conducting climate  vulnerability assessments for marine species using a combination of  quantitative data, qualitative information, and expert opinion. The agency  has used this methodology to complete an assessment for marine fish  and invertebrate species that commonly occur in the Greater Atlantic  region, which it published in February 2016. As of August 2016, NMFS  had climate vulnerability assessments under way for species in its other  four regions, according to agency officials. The assessment in the  Greater Atlantic region found that approximately half of the 82 species  assessed in the region were estimated to have a high or very high  vulnerability to climate change, with the other half having low or moderate  vulnerability. The assessment defined climate vulnerability as the extent  to which the abundance or productivity of a species could be affected by  climate change and natural long-term variability in ocean conditions.  Similarly, more than half of the species were estimated to have a high or  very high potential to shift their distribution in response to projected  changes in the climate. The assessment also provided a summary of the  existing scientific knowledge about the expected effects on different  species in the region but did not quantify the magnitude of the expected  effects for individual species. NMFS officials told us that the assessment  was not designed to provide that type of quantitative information. Instead,  the officials said the information provided by the assessments could be  used to help determine which species should be the subject of additional  research to help quantify potential climate effects in the future. The  vulnerability assessment completed in the Greater Atlantic region  provides illustrations of the range of ways that species may be affected by  climate change, as reflected in the following examples.
Atlantic Cod  Atlantic cod have a large head, blunt snout,  and a distinct barbel (a whisker-like organ, like  on a catfish) under the lower jaw. Cod live  near the ocean floor along rocky slopes and  ledges and prefer to live in cold water. In the  United States, cod range from the Gulf of  Maine to Cape Hatteras, North Carolina, and  are most commonly found off the coast of  Cape Cod, Massachusetts, and in the western  Gulf of Maine. Cod are cooperatively  managed by the National Marine Fisheries  Service’s (NMFS) Greater Atlantic region and  the New England Fishery Management  Council. In 2014, the Atlantic cod commercial  harvest was valued at approximately $9.4  million, according to NMFS data. Atlantic cod  have been an important commercial fish stock  based on the historical volume and value of  the fish caught in the Northeast.
Atlantic cod. According to the NMFS climate vulnerability  assessment, the abundance of Atlantic cod is likely to be negatively  affected by warming ocean temperatures in the Northeast.  Specifically, the assessment indicated that warmer ocean  temperatures may be linked with a lower number of juvenile cod that  survive and grow to a size sufficient to enter the fishery each year.  The assessment also found that continued ocean warming could  produce less-favorable habitat conditions for cod in the southern end  of its range. Atlantic cod have experienced a decline in abundance in  recent decades, and warming ocean temperatures may have  contributed to this decline, according to NMFS and Council officials in  the Greater Atlantic region. The officials further indicated, however,  that the extent to which changing temperatures played a role in the  cod decline is unclear because it is difficult to isolate this factor from  other contributing factors, such as overfishing.
Black Sea Bass  Black sea bass are usually black with a  slightly paler belly and a dorsal fin that is  marked with a series of white spots and  bands. Black sea bass commonly inhabit rock  bottoms near pilings, wrecks, and jetties.  Along the East Coast, black sea bass are  divided into two fish stocks for management  purposes. The stock found north of Cape  Hatteras, North Carolina, is cooperatively  managed by the National Marine Fisheries  Service’s (NMFS) Greater Atlantic region, the  Mid-Atlantic Fishery Management Council,  and the Atlantic States Marine Fisheries  Commission. The southern stock is  cooperatively managed by NMFS, the South  Atlantic Fishery Management Council, and the  Atlantic States Marine Fisheries Commission.  In 2014, the black sea bass commercial  harvest was valued at approximately $8.6  million, according to NMFS data.
Black sea bass. The distribution of the northern stock of black sea  bass, historically found in the Mid-Atlantic, has shifted northward in  recent decades, according to NMFS officials in the Greater Atlantic  region. This trend is likely to continue as ocean temperatures warm  and become more favorable for the fish, according to the NMFS  climate vulnerability assessment. The assessment also indicated that  the abundance of black sea bass in more northern areas will likely  increase as temperatures warm and more spawning occurs.  According to NMFS and Council officials and other fisheries  stakeholders, changes in the abundance and distribution of black sea  bass could present a challenge for fisheries managers because  commercial fishing rights have been allocated to states based on  historical catch data that may not reflect where the fish are found in  the future.
American Lobster  The American lobster is a crustacean with a  large shrimp-like body with eight legs and two  claws. Lobster live on the ocean floor and are  most abundant in coastal waters from Maine  through New Jersey, and offshore from Maine  through North Carolina. The lobster fishery  has northern and southern stocks that are  cooperatively managed by the National Marine  Fisheries Service’s (NMFS) Greater Atlantic  region and the member states of the Atlantic  States Marine Fisheries Commission. In 2014,  lobster’s commercial harvest was valued at  approximately $567.3 million, which made it  one of the most economically valuable  fisheries in the country that year, according to  NMFS data.
American lobster. The overall effect of climate change on lobster  abundance is estimated to be neutral, as population decreases in the  southern portion of its range have been offset by increases in the  north, according to the NMFS climate vulnerability assessment. NMFS  officials in the Greater Atlantic region said that these population  changes are believed to be driven in large part by warming ocean  temperatures. Specifically, officials said that as ocean conditions in  southern New England have become less favorable to lobsters  because of increasing ocean temperatures, the abundance of the  southern stock has declined. In contrast, the abundance of the  northern stock has increased as temperature changes in the Gulf of  Maine (where waters are generally colder) have produced more  favorable conditions for lobster. NMFS has not been able to quantify  the magnitude of expected future changes in lobster abundance in the  region, however, in part because it is difficult to accurately forecast  changes in ocean temperatures more than a few months out,  according to agency officials. Additionally, NMFS officials indicated  that changing ocean conditions can affect the timing of biological  events in the lobster’s life cycle, which may subsequently alter the  seasonal abundance of the stocks in a way that may cause  disruptions to the fishing industry. For instance, in 2012, warmer-than- usual ocean temperatures in the Gulf of Maine resulted in American  lobsters growing to market size earlier than usual, according to NMFS  documentation. As a result, lobsters were harvested early, but some  lobster processing facilities were not yet ready to receive them, which  led to an abundance of supply for the fishermen and a drop in the  market price they received for their harvest.
section_title: NMFS and the Councils Identified Several Challenges to Better Understand the Effects of Climate Change on Fish Stocks
paragraphs: Through the questionnaire responses and our interviews, NMFS and  Council officials identified several challenges to better understand the  existing and anticipated effects of climate change on fish stocks as well  as efforts they are taking to address some of these challenges, including:
Understanding how climate change may affect fish stocks. NMFS  and most of the Councils indicated that a significant challenge they  face is better understanding the relationship between changes in  ocean conditions and the processes that drive how fish will react to  those changes. NMFS officials explained that it can be difficult, for  instance, to understand how water temperature changes may affect  the biology of specific fish stocks or may indirectly affect their habitat  and interactions with other species within that habitat. Officials from  one NMFS region said that they do not have a sufficient  understanding of the processes that drive fish stock productivity— including their birth, growth, and death rates—in their region, or how  those processes may be affected by climate change. Officials from  several other NMFS regions and Councils shared similar views and  noted that this challenge limits their ability to understand the overall  effects that climate change may have on different fish stocks.
Availability of baseline data. NMFS and several of the Councils  reported that insufficient baseline data at times limit their ability to  predict the effects of various changes in the climate on fish stocks.  Baseline data include oceanographic information, such as water  temperature in different regions and depths; information about a fish  stock, such as temperature preference and spawning history; and  ecological information, such as the type of plants or animals available  as a food source for a particular stock or its role in a food web. For  example, NMFS officials told us that sea surface temperature data are  widely available in most regions but that data on subsurface  temperatures are limited. The officials attributed the difference in the  availability of these two types of data to the ability to use satellites to  measure sea surface temperatures, whereas the collection of  subsurface temperature data is more difficult and requires  measurements to be taken directly from the ocean. NMFS officials  said that the lack of subsurface temperature data limits their ability to  research and determine potential effects of changing temperatures on  bottom-dwelling fish stocks, such as the American lobster. The  officials told us that NOAA has increased its efforts to utilize  technologies such as ocean gliders—autonomous underwater  vehicles used to collect ocean data—to track subsurface ocean  conditions and collect additional baseline data. For example, in 2014  NOAA partnered with other scientists to launch two ocean gliders in  the Gulf of Alaska to collect data for 5 months on water temperature,  salinity, and dissolved oxygen, among other things.
Summer Flounder  Summer flounder are flatfish, with both eyes  located on the left side of the body when  viewed from above, with the dorsal fin facing  up. Adult summer flounder spend most of their  lives on or near the seafloor, burrowing into  the sand. In the United States, summer  flounder are found from the Gulf of Maine  through North Carolina. The stock is  cooperatively managed by the National Marine  Fisheries Service’s (NMFS) Greater Atlantic  region, the Mid-Atlantic Fishery Management  Council, and the Atlantic States Marine  Fisheries Commission. Summer flounder are  one of the most sought after commercial and  recreational fish along the Atlantic coast, and  in 2014, the commercial harvest was valued at  approximately $32.3 million, according to  NMFS data.
Distinguishing between climate change and other factors. It can  be challenging to determine whether a change in a fish stock’s  abundance or distribution is caused by climate change; natural  variation in the oceans; or other human or environmental factors, such  as overfishing or pollution, according to NMFS and some Council  officials. Isolating the effects of climate change from other factors is  difficult, and the complexities of trying to understand the ways in  which these factors interact also present challenges, according to the  officials. For example, NMFS officials in the Greater Atlantic region  said that populations of summer flounder have increased in recent  years after experiencing significant declines from overfishing in the  1970s and 1980s, and that summer flounder are being found in  greater numbers in northern areas, such as the Gulf of Maine. The  officials said that changes in fishing levels are likely driving the  increase in summer flounder abundance and their increased presence  in northern areas, but also suggested that warming ocean  temperatures may have played a role.
Modeling capabilities. NMFS and most of the Councils identified  limitations in climate and fisheries modeling capabilities as a  challenge to better understand the effects of climate change on  fisheries. For example, according to NMFS officials, one important  step to improving the ability to project the effects of climate change on  specific fish stocks will be to downscale global ocean climate models,  such as models of changes in ocean temperatures, to more regional  and local levels that can then be used to assess climate effects on the  fish stocks that inhabit those locations. Agency officials described  this type of information as foundational knowledge that is generally  not yet available across the NMFS regions, in part because it is  resource intensive to develop. The officials said that NMFS considers  the development of downscaled climate models that can be used to  support fisheries management to be a critical need, and that efforts  are under way to develop such models in some NMFS regions. For  example, NMFS is funding a project to help downscale global climate  models for some of the major rivers and estuaries in the Northeast,  such as the Chesapeake Bay, that are crucial habitats for many  commercial, recreational, and protected species.
Resources. NMFS and most of the Councils identified constrained  resources as a challenge to expanding climate-related data collection  and analysis efforts. For instance, according to NMFS officials at one  Fisheries Science Center, developing climate science for fisheries  management requires extensive new modeling to assess and project  current and future fishery conditions, including how fish stock  abundance and distribution may change under changing physical and  chemical ocean conditions. However, the officials said that staff  capacity to conduct this work is limited because of existing modeling  demands for stock assessments. Similarly, officials from one Council  told us that additional staff and resources would be required to  incorporate climate-related information into their work.
section_title: NMFS Developed a Strategy to Help Incorporate Climate Information into Fisheries Management, but It Is in the Early Stages of Implementation
paragraphs: NMFS has developed a strategy to help it and the Councils incorporate  climate information—such as information on changes in ocean  temperatures and acidity levels and the risks to fish stocks associated  with those changes—into the fisheries management process, but is in the  early stages of implementing the strategy. Through our analysis, we  found that NMFS and the Councils have generally not incorporated  climate information into the fisheries management process to date  because the information they have on the effects of climate change on  most fish stocks has not been sufficient. However, recognizing the  importance of further developing climate information and incorporating it  into the fisheries management process, NMFS published its NOAA  Fisheries Climate Science Strategy in August 2015. The Strategy is  intended to support efforts by the agency and its partners to increase the  production, delivery, and use of climate information in managing fish and  other living marine resources. According to the Strategy, failing to  adequately incorporate climate change considerations into fisheries  management and conservation efforts could cause those efforts to be  ineffective, produce negative results, or miss opportunities. Determining  how information on the effects of climate change can be incorporated into  the fisheries management process is a key question that NMFS must  address, according to the Strategy.
The Strategy lays out a national framework that is to be regionally tailored  and implemented. NMFS officials said that the agency’s regions  (including its regional offices and regional Fisheries Science Centers) will  have primary responsibility for implementing the Strategy, and those  offices are in the process of developing regional action plans to describe  how they will do so. NMFS has directed its regions to develop regional  action plans that identify specific actions each region will take over the  next 5 years to implement the Strategy and include the region’s  assessment of its priorities and available resources, among other things.  As of July 2016, four of NMFS’ five regions had released draft versions of  their regional action plans for public comment, and agency officials said  that they expect all of the regions to finalize their plans by October 2016.  The officials said that NMFS headquarters has provided input on the draft  plans and will work with the NMFS Science Board to review and approve  the final plans.
The Strategy recognizes the importance of incorporating climate  information into the fisheries management process but does not provide  specific guidance on how this is to be done. For example, the Strategy  notes the importance of factoring climate information into stock  assessments but does not include specific guidance on how such  information should be incorporated into developing the assessments.  Historically, fish stock assessments primarily considered the effects of  fishing when estimating the abundance of individual fish stocks and have  not accounted for ecosystem factors, including effects from changes in  the climate. This traditional approach has been effective for assessing  present and historical abundance levels but may not be effective in  forecasting future levels because it does not account for effects related to  changing environmental conditions, according to NMFS documentation.  NMFS and Council officials said that factoring climate information more  widely into stock assessments in the future will be important, given the  changing climate conditions and particularly because stock assessments  often provide the scientific basis for management decisions, including  setting annual catch limits. The Strategy also states that including  climate-related data to inform reference points (the limits or targets used  to guide management decisions), where appropriate, is critical to avoid  misaligned management targets for fish stocks, but the Strategy does not  provide specific guidance on how this is to be done. In addition, the  Strategy calls for NMFS to complete climate vulnerability assessments for  all regions as an initial priority action but does not specify how NMFS  regions and the Councils should use the results of the assessments to  inform management decisions or incorporate them into the fisheries  management process.
Without developing guidance on how climate information is to be  incorporated into specific aspects of the fisheries management process,  NMFS does not have reasonable assurance that all of its regions and the  Councils will consistently factor climate-related risks into fisheries  management. Under federal standards for internal control, agencies are  to clearly document internal controls, and the documentation is to appear  in management directives, administrative policies, or operating manuals.  In addition, according to the International Organization for  Standardization, for risk management to be effective, it is important for  information on risks to be included as a part of decision making.  Moreover, developing guidance would be consistent with actions NMFS  has taken for other parts of its mission, according to the agency’s Climate  Change Coordinator. The official noted that in January 2016, NMFS  developed guidance on using climate change information in the agency’s  Endangered Species Act decisions, which could serve as a model for the  fisheries management process. The guidance provides direction on how  climate information should be incorporated into Endangered Species Act  management decisions and what types of climate information should be  used, among other things. NMFS has not yet developed similar guidance  for fisheries management because doing so was not previously  considered to be an immediate priority given the agency’s limited  information on the anticipated effects of climate change on fish stocks  and the near-term focus of most fisheries management decisions,  according to NMFS’ Climate Change Coordinator. The official said,  however, that as knowledge about the effects of climate change on  fisheries has progressed over time, NMFS has found an increased and  more pressing need to begin preparing for these effects in the near term.  By developing guidance on how the NMFS regions and Councils are to  incorporate climate information into different parts of the fisheries  management process, NMFS may help ensure consistency in how its  regions and the Councils factor climate-related risks into fisheries  management decision making.
In addition, the Strategy lays out overall objectives to help identify the  agency’s climate information needs and help better ensure effective  management in a changing climate, but does not contain agency-wide  performance measures to track progress in achieving the Strategy’s  objectives. Specifically, the Strategy lays out seven interrelated, priority  objectives (see table 1).
According to NMFS officials, the agency recognizes the potential benefit  of developing a comprehensive set of agency-wide performance  measures for the Strategy, but it has not specified when or how it may do  so because it is first focusing on completing the regional action plans.  NMFS has directed its regions to include performance measures in their  regional action plans outlining how they will implement the Strategy, and  agency officials told us that once the regional action plans are finalized in  October 2016, NMFS plans to revisit whether to develop agency-wide  performance measures for the Strategy. We have previously reported on  the importance of agencies using performance measures to track  progress in achieving their goals and to inform management decisions.  Moreover, the Government Performance and Results Act of 1993, as  amended, requires federal agencies to establish performance goals and  related performance measures to track progress in annual agency  performance plans, among other things. While these requirements apply  at the departmental level (e.g., Department of Commerce), we have  previously found that they also serve as leading practices in component  agencies, such as at NMFS, to assist with planning for individual  programs or initiatives that are particularly challenging. This is also in  line with federal standards for internal control, which identify the  establishment and review of performance measures as a control activity  that can help ensure that management’s directives are carried out and  that actions are taken to address risks, among other things.
According to NMFS guidance, the regional action plans are to identify  performance measures to document progress in implementing the  Strategy at the regional level. In reviewing the four draft regional action  plans that had been released as of July 2016, we found that three of the  draft plans contained proposed performance measures. Specifically, we  found that the measures each of the three regions proposed included  some key attributes of successful performance measures that we have  previously identified, such as being aligned with the Strategy’s objectives  and having limited overlap (see app. II for the full list of key attributes).  However, most of the measures did not contain other key attributes. For  example, nearly all of the proposed measures contained in the three draft  plans did not include measurable targets, another key attribute of  successful performance measures. In some cases, the proposed  measures identified quantitative data to be tracked—such as the number  of stock assessments or annual catch limits that include climate  information—but there were no numerical targets identified that could  serve as a means for assessing progress. We have previously found that  including measurable targets in performance measures helps in  assessing whether performance is meeting expectations. NMFS officials  said that they recognized the importance of developing meaningful  performance measures. By incorporating key attributes associated with  successful performance measures in the final performance measures  developed for the plans and assessing whether agency-wide performance  measures may also be needed, NMFS may be in a better position to  determine the extent to which the objectives of the Strategy overall are  being achieved.
section_title: Conclusions
paragraphs: Changing environmental conditions in the oceans, such as warming  temperatures, could affect the abundance and distribution of federally  managed fisheries in ways that may pose risks to the communities and  industries that depend on harvesting the affected fish. Such risks also  have potential implications for the federal government’s fiscal exposure  because commercial fishery failures may result in the federal government  providing fishery disaster assistance. NMFS has taken steps to help it  and the Councils better understand how climate change may affect the  fish stocks they manage, even as they face challenges related to the  availability of data and resources, among others. Recognizing the  importance of incorporating climate considerations into the fisheries  management process, NMFS has also developed its NOAA Fisheries  Climate Science Strategy to help increase the production, delivery, and  use of climate information. However, NMFS is in the early stages of  implementing the Strategy and has not developed guidance to specify  how climate information is to be incorporated into different parts of the  fisheries management process, such as in developing stock assessments  or reference points. Developing such guidance would align with federal  standards for internal control and may help NMFS ensure consistency in  how its regions and the Councils factor climate-related risks into fisheries  management decision making.
Additionally, NMFS has directed its regions to include performance  measures in their regional action plans outlining how they will implement  the Strategy, but the proposed measures in the draft plans we reviewed  did not include some key attributes of successful performance measures,  such as containing measurable targets. Moreover, NMFS has not  developed agency-wide performance measures to assess progress in  meeting the Strategy’s overall objectives, instead choosing to wait to  complete the regional action plans before determining whether such  measures may be necessary. By incorporating key attributes associated  with successful performance measures in the final performance measures  developed for the plans and assessing whether agency-wide performance  measures may also be needed, NMFS may be in a better position to  determine the extent to which the objectives of the Strategy overall are  being achieved.
section_title: Recommendations for Executive Action
paragraphs: To help NMFS and the Councils incorporate climate information into the  fisheries management process and better manage climate-related risks,  we recommend that the Secretary of Commerce direct NOAA’s Assistant  Administrator for Fisheries to take the following two actions:
Develop guidance to direct the NMFS regions and Councils on how  climate information should be incorporated into different parts of the  fisheries management process.
In finalizing the regional action plans for implementing the NOAA  Fisheries Climate Science Strategy, (1) incorporate the key attributes  associated with successful performance measures in the final  performance measures developed for the plans and (2) assess  whether agency-wide performance measures may be needed to  determine the extent to which the objectives of the Strategy overall  are being achieved, and develop such measures, as appropriate, that  incorporate the key attributes of successful performance measures.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report for review and comment to the  Department of Commerce. In written comments (reproduced in appendix  III), the Department of Commerce and NOAA agreed with our  recommendations. NOAA stated that the report provides a good summary  of climate-related effects on the nation’s fishery resources and the  challenges to understanding and responding to climate effects in fisheries  management. NOAA agreed with our recommendation to develop  guidance on how climate information should be incorporated into different  parts of the fisheries management process, and outlined several ongoing  and planned efforts to help address the recommendation. For example,  NOAA stated that NMFS recently released a policy and related agency  directives intended to help clarify if and when fishing allocations may  need to be reviewed or adjusted, such as when fish stocks shift  distribution in response to a changing climate.
In addition, NOAA agreed with our recommendation to incorporate key  attributes associated with successful performance measures in the final  performance measures included in the regional action plans for the  Strategy and to assess whether agency-wide performance measures for  the Strategy may be needed. NOAA stated that NMFS will review the  draft regional action plans and take action to ensure that the performance  measures in the final plans include key attributes of successful measures.  Following completion of the regional action plans, NOAA indicated that  NMFS will also assess the need for agency-wide measures to track and  evaluate achievement of the Strategy’s objectives and will develop such  measures as appropriate. NOAA also provided technical comments,  which we incorporated as appropriate.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Commerce, and other interested parties. In  addition, the report is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-3841 or fennella@gao.gov. Contact points for  our Offices of Congressional Relations and Public Affairs may be found  on the last page of this report. GAO staff members who made key  contributions to this report are listed in appendix IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: This report examines (1) information the National Marine Fisheries  Service (NMFS) and the Regional Fishery Management Councils  (Council) have about the existing and anticipated effects of climate  change on federally managed fish stocks and challenges they face to  better understand these effects and (2) efforts NMFS has taken to help it  and the Councils incorporate climate information into the fisheries  management process. For both objectives, to understand the legal  framework for fisheries management in the United States, we reviewed  the Magnuson-Stevens Fishery Conservation and Management Act of  1976, as amended, which governs marine fisheries management in  federal waters, including both commercial and recreational fishing. We  also reviewed our past work on fisheries management, climate change  adaptation, and risk management.
To examine information NMFS and the Councils have about the effects of  climate change on federally managed fish stocks and the challenges they  face to better understand these effects, we reviewed scientific studies and  documentation prepared by NMFS, the Councils, and others such as  academics. These documents included studies about the existing and  anticipated effects of climate change on the ocean and particular fish  stocks and key fisheries management documents, such as stock  assessments and fisheries management plans. We also developed a  questionnaire of open-ended questions about the information NMFS and  the Councils have on the effects of climate change on the fish stocks they  manage and any challenges they face to better understand these effects,  among other things. We disseminated the questionnaire to the regional  administrator of each NMFS region and the executive director of each  Council. All five regions and eight Councils responded to the  questionnaire. To characterize officials’ views presented in the  questionnaire responses, two analysts analyzed the narrative responses  to these questions and identified key themes. In describing these  responses in the report, we attribute the information to NMFS and Council  officials.
We conducted interviews, either in person or by telephone, with officials  from two NMFS regions (Greater Atlantic and Alaska) and representatives  of four Councils (New England, Mid-Atlantic, South Atlantic, and North  Pacific) and the Atlantic States Marine Fisheries Commission about their  understanding of the effects of climate change on fish stocks and any  challenges they face to better understand these effects. We selected  these entities to interview because they are involved in managing  fisheries in regions of the country that are expected to experience  significant effects from climate change, according to NMFS  documentation and our discussions with agency officials. We also  interviewed representatives from 11 stakeholder organizations  representing fishing, conservation, and Alaska Native interests to obtain a  broader range of views on the existing and anticipated effects of climate  change on fish stocks and the efforts of NMFS and the Councils to better  understand these effects. We selected these entities to reflect geographic  diversity and different types of involvement in fisheries management  issues.
We analyzed a nongeneralizable sample of seven fish species as case  studies from NMFS’ Greater Atlantic and Alaska regions. These species  were the American lobster, Atlantic cod, black sea bass, northern rock  sole, spiny dogfish, summer flounder, and walleye pollock. We selected  these species to reflect variation in the value and volume of commercial  harvests, based on NMFS’ commercial fisheries data from 2008 to 2013,  and a range of potential effects of climate change. We assessed the  reliability of NMFS’ commercial fisheries data and found the data to be  sufficiently reliable for the purpose of selecting our case study species.  The case study species are intended to provide illustrative examples and  cannot be generalized to the entire universe of fish species. For each of  our case study species, we reviewed applicable stock assessments and  fisheries management plans. We also obtained written information from  the applicable NMFS Fisheries Science Centers and Councils in the  regions on the extent to which each species is expected to change its  distribution, abundance, or the timing or location of biological events as a  result of the effects of climate change. In addition, we interviewed NMFS  scientists involved in studying our case study species at NMFS’ Alaska  Fisheries Science Center and the Northeast Fisheries Science Center.  We used the information collected through these case studies to provide  examples in the report.
To examine the efforts NMFS has taken to help it and the Councils  incorporate climate information into the fisheries management process,  we analyzed the questionnaire responses provided by the NMFS regions  and Councils and reviewed agency and Council documentation, including  planning documents, analyses, and reports with information on the  fisheries management process. As part of our interviews with officials  from NMFS’ headquarters, regional offices, and regional Fisheries  Science Centers, as well as representatives from the Councils and  nonfederal stakeholders, we discussed the steps taken to assess climate- related risks to fisheries and the extent to which climate information has  been incorporated into different parts of the fisheries management  process. We focused our analysis on the process for setting annual catch  limits and related management actions, because developing these limits  is required for all fisheries managed by the Councils and NMFS considers  it a major part of the fisheries management process.
In performing this work, we examined NMFS’ NOAA Fisheries Climate  Science Strategy (Strategy) to assess the agency’s plans for increasing  the production, delivery, and use of climate information for managing  fisheries and other marine resources. In doing so, we first reviewed the  draft Strategy (released in January 2014) and stakeholder comments on  the Strategy submitted during the public comment period. We used this  analysis to help identify potential issues stakeholders had about the  Strategy’s design and proposed implementation, and to develop follow-up  questions for NMFS and Council officials. We reviewed the final version  of the Strategy after it was released in August 2015 and assessed the  Strategy—as well as the four draft regional action plans for implementing  the Strategy that had been released as of July 2016—against leading  practices in agencies’ strategic planning and performance measurement  identified in our previous work based on the requirements of the  Government Performance and Results Act of 1993, as amended. We  also compared NMFS’ efforts to incorporate information on climate- related risks in the fisheries management process to leading risk  management guidance developed by the International Organization for  Standardization and GAO’s Standards for Internal Control in the Federal  Government.
section_title: Appendix II: Key Attributes of Successful Performance Measures
paragraphs: Measuring performance allows organizations to track the progress they  are making toward their goals and gives managers critical information on  which to base decisions for improving their programs. Table 2 presents a  summary of nine key attributes of successful performance measures  identified in our prior work, including the potentially adverse  consequences if they are missing. All attributes are not equal, and failure  to have a particular attribute does not necessarily indicate that there is a  weakness in that area or that the measure is not useful; rather, it may  indicate an opportunity for further refinement.
section_title: Appendix III: Comments from the Department of Commerce
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Alyssa M. Hundrup (Assistant  Director), Stephen D. Secrist (Assistant Director), Mark Braza, Alicia  Puente Cackley, John Delicath, Heather Dowey, Karen Howard,  Benjamin T. Licht, Dan C. Royer, Jeanette M. Soares, Levine Thomas,  Joseph Dean Thompson, Jason Trentacoste, Sarah Veale, and Joshua  Wiener made key contributions to this report.