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

Letter

Background

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.

Climate Change Effects on Ocean Environments

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.

Risk Management as a Strategy for Managing Climate-Related Risks to Fisheries

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.

NMFS and the Councils Have Limited Information on the Magnitude and Timing of Climate Change Effects on Fish Stocks

We found that NMFS and the Councils have 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.

NMFS and the Councils Have Limited Information on the Magnitude and Timing of Climate Change Effects on Fish Stocks

Through our analysis, we found that NMFS and the Councils have general information about the types of effects climate change is likely to have on fish stocks, but information about the magnitude and timing of effects for specific fish stocks is limited. In general, the types of effects climate change is likely to have include changes in fish stock abundance and distribution and the timing or location of biological events such as spawning (the process by which fish reproduce), according to NMFS and Council officials. These effects will not be uniform across fish stocks but rather will likely vary, with the abundance of some stocks being negatively affected and the abundance of other stocks increasing or not being affected, according to NMFS documentation. Similarly, potential shifts in distribution will vary, as some fish stocks may respond to changing ocean temperatures by moving north or to deeper waters in search of the water temperatures they are accustomed to, but shifts in other directions may occur as well. Some NMFS and Council officials said that changes in the timing and location of biological events are also expected to vary between fish stocks. For example, some fish stocks may spawn at different times or in different locations under warmer ocean conditions.

In some instances, the abundance or distribution of fish stocks may shift in response to changes in ocean habitats occurring because of a changing climate. For example, reductions in seasonal sea ice cover and warmer ocean surface temperatures may open up new habitats in polar regions that could lead to shifts in distribution for some fish species, according to the 2014 Third National Climate Assessment. Furthermore, warming ocean temperatures and higher acidity levels also affect the health of coral reefs, which provide essential habitat for many fish stocks. 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.

NMFS and the Councils Identified Several Challenges to Better Understand the Effects of Climate Change on Fish Stocks

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.

NMFS Developed a Strategy to Help Incorporate Climate Information into Fisheries Management, but It Is in the Early Stages of Implementation

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.

Conclusions

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.

Recommendations for Executive Action

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.

Agency Comments and Our Evaluation

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.

Appendix I: Objectives, Scope, and Methodology

This report examines (1) information the National Marine Fisheries Service (NMFS) and the Regional Fishery Management Councils (Council) have about the existing and anticipated effects of climate change on federally managed fish stocks and challenges they face to better understand these effects and (2) efforts NMFS has taken to help it and the Councils incorporate climate information into the fisheries management process. For both objectives, to understand the legal framework for fisheries management in the United States, we reviewed the Magnuson-Stevens Fishery Conservation and Management Act of 1976, as amended, which governs marine fisheries management in federal waters, including both commercial and recreational fishing. 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.

Appendix II: Key Attributes of Successful Performance Measures

Measuring performance allows organizations to track the progress they are making toward their goals and gives managers critical information on which to base decisions for improving their programs. Table 2 presents a summary of nine key attributes of successful performance measures identified in our prior work, including the potentially adverse consequences if they are missing. 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.

Appendix III: Comments from the Department of Commerce

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

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.