Recreational Fisheries Management: The National Marine Fisheries Service Should Develop a Comprehensive Strategy to Guide Its Data Collection Efforts
Released: 2015-12-14T00:00:00

Letter

Background

NMFS’ mission is to act as a steward of the nation’s ocean resources and their habitats. This includes responsibility for managing recreational fisheries in federal waters. These waters generally include the United States Exclusive Economic Zone, which typically begins approximately 3 geographical miles from land and extends 200 nautical miles from land. Coastal states generally maintain responsibility for managing fisheries in waters that extend approximately 3 geographical miles from their coastlines. The extent of recreational fishing varies by region, with the greatest amount of marine recreational fishing taking place in the Gulf of Mexico, followed by the South Atlantic and Mid-Atlantic, according to NMFS statistics. Figure 1 shows NMFS statistics about the extent of marine recreational fishing activity overall and the locations of the highest levels of marine recreational fishing activity. overfished fisheries, protect essential fish habitat, and reduce bycatch, among other things. The 1996 act included requirements for NMFS and the councils to develop fisheries management plans for fish stocks and to establish required time frames for rebuilding fish stocks that are overfished. A reauthorization of the act was passed in 2006 and established further legal requirements to guide fisheries data collection and management, including mandates on the use of science-based annual catch limits. Under NMFS guidelines, plans should include accountability measures to prevent catch from exceeding the annual catch limit. These measures can include fishing season closures, closures of specific areas, changes in bag limits, or other appropriate management controls.

Private recreational anglers use private boats and sites on shore, such as public docks or private boat clubs, to access marine recreational fisheries.

The marine recreational fishing sector is divided between private anglers and the for-hire sector. Private anglers primarily access marine recreational fisheries by using private boats or by fishing from sites on shore. The for-hire sector includes both charter boats and “head boats.” Charter boats are chartered or contracted by anglers for a fishing trip for a flat fee regardless of the number of anglers on the boat. “Head boats” are usually large capacity multipassenger vessels that charge each angler a per person fee for a fishing trip.

Private recreational anglers also rely on the for-hire sector, which consists of charter boats and “head boats.” Charter boats commonly carry six or fewer passengers who purchase the services of a boat and crew. “Head boats” carry more than six passengers, with each individual angler paying a fee to go fishing.

NMFS has overall responsibility for collecting data to manage federal fisheries. It has several offices involved in fisheries data collection and management, including the Office of Science and Technology, six regional Fisheries Science Centers, and five regional offices. NMFS has numerous partners for collecting data to manage recreational fisheries, including coastal states and three interstate marine fisheries commissions. In addition, NMFS and these partners collaborate with regional fisheries information networks, such as the Gulf Fisheries Information Network and the Atlantic Coastal Cooperative Statistics Program, to collect and manage fisheries data. NMFS also collaborates with eight Regional Fishery Management Councils that are responsible for fisheries conservation and management in specific geographic regions of the country. In addition, NMFS collaborates with numerous other stakeholders, such as private anglers, charter boat operators, seafood dealers, nongovernmental organizations, and recreational fisheries associations, to gather input about fisheries data collection programs and management. Figure 2 shows key stakeholders involved in recreational fisheries data collection.

Collection and Use of Recreational Fisheries Data

NMFS and its stakeholders collect several types of data for use in recreational fisheries management. For example, information is collected on recreational fishing effort and catch rates. Effort measures the number of angler trips, while catch rates measure the average number and size of fish, by species, that are brought to shore, caught and used as bait, or discarded (i.e., caught but then released alive or dead). These data are used to estimate the total recreational fishing catch to determine the impact of recreational fishing activity on fish stock mortality and the changes that are occurring to the fish stock over time. Figure 3 shows how these data are used to estimate total catch.

According to NMFS documentation, data on catch and discards are generally collected through shoreside interviews of anglers at public access fishing sites, primarily through NMFS’ MRIP Access Point Angler Intercept Survey, which covers the Atlantic and Gulf coasts from Louisiana to Maine, or through state survey programs. These data may also be collected through the use of onboard observers, typically on charter boats or head boats. Data on fishing effort are collected through MRIP or state programs, using methods such as phone or mail surveys, shoreside interviews, onboard observers, logbooks, boat and boat trailer counts, and electronic monitoring or electronic reporting tools. Given the involvement of the interstate fisheries commissions and states in data collection efforts, methods for collecting data on recreational fishing vary among states and regions.

In addition, according to NMFS documentation, biological samples of fish specimens are collected for scientific analysis to provide information on the health and biology of fish stocks. For example, data are collected on the lengths, weights, and ages of fish samples. These samples are often collected during NMFS’ shoreside interviews of recreational anglers or by tagging fish to track after they are caught and released. Academic programs and cooperative research with the fishing industry are other sources of biological sampling data.

In addition to collecting data on marine recreational fisheries, NMFS and its stakeholders, such as states, collect other types of data including data on commercial fisheries. Unlike recreational fisheries data, however, commercial fisheries data are collected through a census of the weight and value of all fish species sold to seafood dealers using a network of cooperative agreements with states. According to NMFS documentation, in some regions, state fishery agencies are the primary collectors of commercial fisheries data that they receive from seafood dealers who submit periodic reports on the amount and value of the various fish species they purchase. In addition, independently from recreational or commercial fishing data collection efforts, NMFS and its stakeholders also collect information on the abundance of fish stocks and environmental conditions in fish habitats, such as seafloors, open ocean water, and natural and artificial reefs. These data are used to determine the size, age composition, and distribution of fish stocks, and allow NMFS to track the total abundance of fish stocks over time. NMFS officials told us NMFS relies on its own research vessels or contracted commercial fishing vessels to collect abundance data.

NMFS uses these various types of data to conduct fish stock assessments that estimate, among other things, the population of fish stocks, fish stock productivity, and biological reference points for sustainable fisheries. NMFS and the Regional Fishery Management Councils in turn use the fish stock assessments to examine the effects of fishing activities on the fish stocks and make determinations such as whether stocks are overfished and whether overfishing is occurring. According to NMFS documentation, the data are also used to support management decisions, such as setting limits on how many fish can be caught annually or determining the need to close a recreational fishery for a particular fish stock during an open fishing season, called an in-season closure, when annual catch limits are anticipated to be exceeded.

National Research Council Findings and NMFS’ Implementation of MRIP

In 2006, the National Research Council issued a report that reviewed NMFS’ marine recreational fisheries data collection programs and made numerous general and specific recommendations to address weaknesses. Among other things, the council recommended the redesign of all marine recreational fishing surveys funded by NMFS. In addition, the council recommended that NMFS improve its survey coverage by either developing a national registration of all saltwater anglers or by using new or existing state saltwater license programs that would provide appropriate contact information for all anglers fishing in all marine waters, both state and federal. The 2007 reauthorization of the Magnuson- Stevens Act included requirements for NMFS to take into consideration and, to the extent feasible, implement the recommendations in the National Research Council report.

Subsequently, in October 2008, NMFS began implementing MRIP, managed in NMFS’ Office of Science and Technology, to collect recreational fisheries effort and catch data and develop estimates for use in fisheries management. MRIP was intended to coordinate collaborative efforts among NMFS and its various stakeholders to develop and implement an improved recreational fisheries statistics program. MRIP consists of a system of regional surveys that provide effort and catch statistics for use in the assessment and management of federal recreational fisheries. According to NMFS officials, because counting every recreational angler or observing every fishing trip is not possible, NMFS relies upon statistical sampling to estimate the number of fishing trips recreational anglers take and what they catch. The data gathered from the regional surveys are compiled to provide regional and national estimates. Under MRIP, certain states, including California, Oregon, and Washington, have implemented recreational fisheries data collection programs funded, in part, by NMFS; these data are also used to inform fisheries management. Also, some states have developed and implemented other recreational fisheries data collection programs funded, in part, through mechanisms such as fee-based fishery programs in those states. Figure 4 provides a timeline of key legislative and other events related to marine recreational fisheries data collection and management.

Several Challenges with NMFS’ Fisheries Data Collection Efforts Have Been Identified

Since the 2006 National Research Council report, NMFS and some state officials have identified several challenges related to collecting data to manage marine recreational fisheries, such as obtaining quality recreational fishing data to inform scientific analyses and produce credible effort and catch estimates. NMFS and some state officials also identified challenges with collecting recreational fisheries data in a timely manner to support certain recreational fisheries management decisions. In addition, NMFS and some state officials, as well as some other stakeholders such as private recreational anglers, identified challenges regarding how NMFS communicates with stakeholders about its marine recreational fisheries data collection efforts.

Examples of NMFS’ challenges in obtaining quality recreational fishing data through MRIP to inform scientific analyses and produce credible effort and catch estimates include: Identifying the universe of recreational anglers. NMFS faces a challenge in obtaining complete information on the universe of recreational anglers. According to NMFS officials, MRIP created a national saltwater angler registry to obtain more complete information about recreational anglers. However, this registry does not include anglers if they are registered in states bordering the Atlantic Ocean and Gulf of Mexico because NMFS granted those states exemptions from the national registry. According to NMFS officials, NMFS relies on state angler registries to identify the universe of recreational anglers in those exempted states. However, some state angler registries offer exemptions from fishing permit requirements, such as for individuals under or over certain ages, and NMFS officials noted that not all anglers comply with state licensing and registration requirements. Therefore, these anglers do not appear on state angler registries. As a result, NMFS does not have a complete list of recreational anglers.

Obtaining sufficient coverage in effort surveys. According to some state officials, NMFS faces challenges in ensuring that it covers the full range of anglers among the participants it selects to participate in fishing effort surveys so that they are representative of the overall angler population. For example, NMFS has relied on its Coastal Household Telephone Survey, which randomly selects participants from all potential household telephone numbers in coastal counties, to obtain information about shoreside and private boat fishing effort in the Gulf of Mexico and the Atlantic coast. As a result, the survey does not capture recreational anglers from noncoastal states that travel to fish in the Gulf of Mexico or Atlantic coast, or coastal resident anglers in households that do not have a landline phone. NMFS officials acknowledged this limitation with the Coastal Household Telephone Survey.

Targeting a representative sample in shoreside surveys.

According to NMFS officials, NMFS faces challenges in collecting data on a portion of the recreational fishing sector since it generally does not collect data on private property or at private-access fishing sites. According to NMFS officials and other governmental stakeholders, this is an issue in states that have many private-access sites, such as California and Florida, because there may be a significant portion of the recreational fishing sector that is not being surveyed. As a result of this limitation, according to NMFS officials and some state officials, NMFS relies on untested assumptions about, for example, catch and discard rates for anglers that use private- access fishing sites to develop recreational catch estimates. However, NMFS officials noted that survey data on fishing effort are collected from anglers regardless of whether they fish from public or private- access fishing sites. In addition, according to one state official, NMFS’ standard protocols for determining when and where to assign shoreside observers to conduct interviews may not take into account local fishing patterns and, therefore, observers may not be located in the right places at the right times to collect the most representative data. For example, according to this official, NMFS’ protocols for assigning shoreside observers do not account for the length of time anglers would typically take to reach federal waters and return from their trip. As a result, observers may not be at the shoreside when anglers return.

Obtaining a sufficient number of survey responses and biological samples. According to NMFS and some state officials, NMFS faces the challenge of collecting a sufficient number of survey responses and samples in its effort and catch surveys. For example, some NMFS and state officials told us Coastal Household Telephone Survey response rates have been declining, and a 2014 report prepared for NMFS noted that response rates to the survey had “declined considerably” in the previous decade, which could increase the potential for bias in the data collected on recreational angler fishing effort. Also, one state official told us he does not believe NMFS assigns enough shoreside observers to collect the recreational angler catch and discard data needed to develop precise recreational catch estimates. In addition, another state official told us that the lack of shoreside observers has contributed to an insufficient amount of biological samples collected to adequately address scientific needs. Consistent with these views, in 2013 NMFS’ Southeast Fisheries Science Center identified a need for more fish tissue samples in its region to aid in assessing fish stock reproduction.

Obtaining valid survey responses. According to some state and NMFS officials, obtaining valid survey responses can be challenging because they depend on anglers’ recollections of prior fishing events. NMFS officials told us that the accuracy of self-reported data (i.e., data that rely on participants providing responses based on personal observations) depends on the angler’s ability to recall events or to distinguish between different fish species. However, anglers may not be able to accurately recall details about fish they caught and then discarded, especially as time elapses or because of limited knowledge about fish species, and without independent validation or verification, that data may be inaccurate. According to NMFS officials, these challenges affect the Coastal Household Telephone Survey because the survey asks anglers how many saltwater fishing trips were taken in the previous 2 months, but it does not use observers or other mechanisms to independently validate and verify this self-reported data.

Obtaining key recreational fisheries data. According to NMFS and some state officials, NMFS faces a challenge in collecting complete data on discards—that is, fish that are caught but then released— because of the difficulty of validating and verifying self-reported data as previously discussed. In light of this difficulty, Louisiana does not collect recreational angler discard data as part of its own recreational fisheries data collection program because of concerns about the quality of angler self-reported data, according to a state official. Even given the uncertainty in identifying the exact amount of discards, the number of discards can be substantial—for example, according to NMFS statistics, the majority of fish caught by marine recreational fishermen in 2013 were discarded. NMFS officials told us that discarded fish that have to return to great depths often experience high mortality rates due to barotrauma. As a result of limited information about the number of discarded fish and their mortality rates, according to NMFS officials, NMFS relies on assumptions about the mortality rates of discarded fish to produce or adjust recreational catch estimates.

NMFS also faces challenges in collecting timely marine recreational fishing data to support certain fisheries management decisions, according to NMFS and some state officials we interviewed. According to NMFS officials, the Magnuson-Stevens Reauthorization Act of 2006 implemented new requirements that have greatly expanded the pressures on fisheries managers to rely on timely data to make decisions. However, according to NMFS and some state officials, NMFS’ data collection systems have not evolved quickly enough to support management decision making. For example, it takes 2 months to conduct the Coastal Household Telephone Survey, which collects data on recreational fishing effort in the Gulf of Mexico and the Atlantic coast, and about 45 days to analyze the data and produce recreational fishing estimates. According to NMFS and some state officials, as a result of these timing issues, NMFS managers do not have enough information to make informed decisions about whether to initiate in-season closures for certain fish stocks with annual catch limits in order to prevent anglers from exceeding those limits. State officials frequently highlighted this as a concern in managing the Gulf of Mexico red snapper, which is susceptible to in-season closures because of concerns about overfishing. According to NMFS documentation, this fishery has been subject to shortened federal fishing seasons over the last few years—including seasons of 9 days in 2014 and 10 days in 2015, compared with 75 days in 2009 and 42 days in 2013.

NMFS, some state officials, and some other stakeholders, such as private recreational anglers, have also identified challenges in how NMFS communicates with stakeholders about its fisheries data collection efforts. For example, a fisheries official from Texas said that, although Texas provides NMFS with marine recreational fisheries data, NMFS does not clearly communicate how or if it uses those data. Some private recreational anglers also told us that NMFS has not always sufficiently communicated with the public about its activities, creating concerns about a lack of transparency regarding NMFS’ fisheries management decisions. For example, some private anglers told us they are confused because NMFS has not explained why it continues to shorten the Gulf of Mexico red snapper fishing season even though the red snapper population has increased. NMFS officials acknowledged that NMFS has not always clearly communicated with regional stakeholders to explain its decision- making processes, stating that this has contributed to the public’s misperceptions.

As a result of the challenges that have been identified with collecting fisheries data, NMFS officials told us they face a lack of public confidence and trust in their ability to provide the data needed for managing recreational fisheries. For example, according to a Texas fisheries official, Texas withdrew from NMFS’ recreational data collection program and implemented its own data collection program in the late 1970s because it did not believe that NMFS’ data collection methods suited Texas’ needs for managing recreational fisheries. Similarly, in 2014, Louisiana withdrew from MRIP and implemented its own recreational fisheries data collection program, called LA Creel, because of concerns about MRIP data being able to support Louisiana’s needs for managing recreational fisheries, according to a Louisiana fisheries official. Similarly, according to state officials, Mississippi and Alabama have also independently initiated efforts to collect data on the abundance of certain fish, including red snapper, in artificial reefs off the coasts of these states because of concerns that NMFS’ current data collection methods underestimate the abundance of these fish stocks. Citing dissatisfaction with NMFS’ management of the Gulf of Mexico red snapper fishery, the states bordering the Gulf of Mexico released a proposal in March 2015 to transfer the responsibility for managing Gulf of Mexico red snapper from NMFS to these states.

NMFS Has Taken Steps Aimed at Improving Data Collection, but Some Challenges Persist and NMFS Does Not Have a Comprehensive Strategy to Guide Improvement Efforts

NMFS has taken several steps aimed at improving data collection to manage marine recreational fisheries and addressing challenges related to communicating with stakeholders. However, some data collection challenges persist, and NMFS does not have a comprehensive strategy to guide its efforts to improve recreational fisheries data collection.

NMFS Has Taken Steps Aimed at Improving Recreational Fisheries Data Collection, but Some Challenges Persist

NMFS has taken steps to address some of the challenges it faces in collecting data for managing marine recreational fisheries, including steps aimed at collecting quality data to support scientific analyses and producing credible effort and catch estimates, improving the timeliness of data collection, and improving communication with stakeholders. However, even with the various steps NMFS has taken, agency officials said that some challenges persist. In April 2015, NMFS requested that the National Research Council review MRIP to determine the extent to which NMFS has addressed the recommendations in the 2006 National Research Council report. A NMFS official told us the National Research Council has initiated the review process, and NMFS expects the review to be completed in 2017.

Addressing Challenges in Collecting Quality Data

NMFS has taken several steps to address the challenges it faces in collecting quality data. To address the challenge of identifying the universe of recreational anglers, NMFS documents indicate that by October 2011 NMFS had entered into memoranda of agreement with states and United States territories that were exempt from the national registry requirements, whereby these states and territories agreed to submit their data on marine recreational fishing participants to NMFS for inclusion into the national registry. In 2011 and 2012, NMFS provided approximately 20 grants to states through the interstate marine fisheries commissions to support initial data quality improvement projects. Subsequently, in 2012 and 2013, NMFS received state angler registry data from each of the exempted Atlantic and Gulf Coast states and entered the data into the national registry database. During this same period, NMFS made recommendations to the states on improving their recreational angler databases. NMFS also continued to provide funds to the states through the commissions to support the initial data quality improvement projects, according to NMFS documents.

To address both regional and national needs for effort and catch data, NMFS has supported the redesign of state and federally managed surveys in all regions. For example, in 2009, NMFS initiated a series of pilot studies to address declining participation rates in telephone recreational fishing effort surveys and potential gaps in the data that could skew survey results due to limitations in reaching coastal residences. NMFS conducted these pilot studies to determine whether mail survey methods for collecting recreational fishing effort data would improve estimates. In a July 2014 report, NMFS stated that the findings from the study indicated that mail survey response rates were nearly three times higher than the telephone survey response rates. Given these results, in May 2015, NMFS issued a plan for transitioning from the current Coastal Household Telephone Survey to a newly designed mail-based survey, referred to as the Fishing Effort Survey. According to NMFS documentation, NMFS expects the Fishing Effort Survey to be fully implemented by January 2018, as shown in figure 5.

In 2013, NMFS also issued new protocols for the Access Point Angler Intercept Survey. Under these new protocols, NMFS assigns shoreside observers to specific locations at precise times to address potential data gaps related to where and when the data are collected. According to NMFS officials, the new peer-reviewed survey design is intended to provide complete coverage of fishing trips ending at public access sites with representative sampling of trips ending at different times of day.

Also in 2013, NMFS initiated a science program review to help provide a systematic peer review of its fisheries data collection programs at its six regional Fisheries Science Centers and Office of Science and Technology. As part of this effort, peer review panels evaluated NMFS’ data collection and management programs in 2013, subsequently issuing a report identifying a number of crosscutting national challenges and making several recommendations to address them. For example, the report recommended that NMFS develop a plan for providing the data necessary for conducting fish stock assessments.

NMFS has also initiated efforts to evaluate the potential of electronic monitoring and reporting to address quality of data challenges. For example, according to NMFS officials, as of October 2015, NMFS was working with stakeholders in Florida to test the use of a smartphone- and Internet-based electronic reporting tool called iAngler to collect and report data on recreational effort and catch. NMFS is also working with Texas on an electronic reporting tool called iSnapper to test the collection of self- reported catch data, according to NMFS officials. In addition, NMFS issued a policy directive in May 2013 to provide guidance on the adoption of electronic technologies to complement or improve existing fishery data collection programs. In 2013, NMFS began working with its regional Fisheries Science Centers to develop regional plans to identify, evaluate, and prioritize the implementation of electronic monitoring and reporting technologies. According to NMFS documents, each of NMFS’ regional offices, in consultation with the Fisheries Science Centers, issued implementation plans in January and February 2015 that include a focus on using electronic technologies to improve the quality of recreational fishing data and data timeliness. Figure 6 shows examples of electronic monitoring and reporting technologies.

However, even with the various steps NMFS has taken, agency officials said that some challenges persist. For example, according to NMFS officials we interviewed, NMFS uses independent checks to either validate self-reported data or estimate a reporting error that can be used to produce unbiased estimates, but the agency faces challenges in independently validating and verifying self-reported angler data. In addition, NMFS officials told us the 2006 National Research Council report contains recommendations that the agency has not yet addressed, including developing methods for improving the accuracy of estimates for the number of discarded fish and addressing the potential bias resulting from the exclusion of private access sites from shoreside surveys. NMFS officials agreed that additional effort should be undertaken through MRIP to evaluate alternative methods for obtaining and verifying discard data. According to NMFS officials, they initiated a process in October 2015 for developing strategies to address these challenges.

Addressing Data Timeliness Challenges

NMFS has begun taking steps to improve the timeliness of its recreational fisheries data to support certain fisheries management decisions but, according to NMFS officials and stakeholders, this data timeliness challenge has not been fully addressed. For example, according to NMFS documentation, in fiscal year 2015, NMFS began studying the feasibility of moving from a 2-month survey period to a 1-month survey period—that is, conducting the survey each month to collect data on the previous month’s fishing activity—in its new mail-based Fishing Effort Survey as a way to help reduce recall errors and improve the precision and timeliness of recreational fishing effort estimates. However, some stakeholders told us that NMFS’ new mail-based Fishing Effort Survey will still not provide enough timely data to inform in-season closure decisions for federal Gulf of Mexico red snapper seasons. NMFS officials acknowledged limitations with its approach, noting that in-season closure decisions are based on the previous year’s recreational fishing catch estimates. According to NMFS officials, beginning in 2013, NMFS coordinated a series of MRIP workshops with fisheries officials from Alabama, Florida, Louisiana, Mississippi, and Texas to discuss options for improving the timeliness of data to support Gulf of Mexico red snapper in-season closure decisions. NMFS officials told us that they will continue to collaborate with their Gulf state partners to develop supplemental surveys focused on red snapper that can be integrated with the more general MRIP survey approach. According to NMFS officials, NMFS and the Gulf of Mexico Fisheries Information Network recently developed a timeline that describes the process and timing for making key decisions about future red snapper specialized survey methods, as shown in figure 7. NMFS officials told us as of October 2015 the states concurred with the timeline.

According to NMFS and a state official, addressing some of the data collection challenges related to quality and timeliness entails making trade-offs. For example, according to NMFS officials, NMFS also held a workshop in March 2011 with several recreational fishing stakeholders, such as states and councils, to address the need for more timely and precise updates in a short-season fishery. NMFS officials told us the workshop identified several ways in which improvements could be made, but they concluded that more resources beyond what MRIP could afford would be needed to implement those improvements. NMFS’ new Fishing Effort Survey collects data on recreational fishing effort that targets many fish stocks, including some that do not need timely data necessary to make fishery management decisions within a shortened federal fishing season. However, according to NMFS officials and a state official, to implement a separate survey that specifically targets Gulf of Mexico red snapper would likely entail adding additional resources to this effort that would need to be taken from other surveys, such as the Fishing Effort Survey. According to NMFS officials, trade-offs also are often necessary to balance the competing needs of state and federal fisheries management and, as a result, NMFS prioritizes among competing demands for data. NMFS has attempted to address the need to understand the trade-offs involved in data collection; according to NMFS documentation, tools intended to help evaluate possible resource allocation trade-offs were expected to be available for use in 2014. However, according to NMFS officials, the tools were not in place as of October 2015, and NMFS has not determined when the tools will be available. The officials said that the tools were being developed in collaboration with academia, but the project stalled because the project leader left the academic institution, and the institution has not yet found a replacement.

Addressing Challenges in Communication

NMFS has also taken steps to improve communication with recreational fisheries stakeholders about recreational data collection. NMFS has worked with its MRIP Executive Steering Committee to address priority communication initiatives through various MRIP teams. For example, the MRIP communications and education team plans to implement a communications strategy—entailing various communication activities such as webinars—to support the transition from the Coastal Household Telephone Survey to MRIP’s new mail-based Fishing Effort Survey. According to NMFS officials, the agency is developing an MRIP strategic communications plan to guide its transition to the Fishing Effort Survey that was expected to be finalized by the end of October 2015. To further enhance MRIP communications, in 2014, the MRIP communications and education team began restructuring its communications network by developing MRIP communication teams at the regional level.

Some of NMFS’ steps to improve communication have resulted in increased collaboration with recreational fisheries stakeholders, according to NMFS and state officials. For example, according to a state fisheries official, NMFS coordinated with the state to provide state officials greater input in determining observer assignment schedules and locations as part of the new protocols for the Access Point Angler Intercept Survey. NMFS officials told us that they are also working collaboratively with Louisiana to perform a side-by-side comparison of MRIP data with data collected under Louisiana’s LA Creel data collection program, to determine whether LA Creel can be used as an alternative to MRIP surveys. According to NMFS officials, in early 2016, NMFS and Louisiana plan to evaluate the results of the side-by-side comparison to determine next steps. Regarding stakeholder concerns about NMFS’ lack of data on fish stock abundance in reef habitats, NMFS officials told us that NMFS plans to use data collected by academic partners on red snapper abundance on artificial reefs in its Gulf of Mexico red snapper fish stock assessment. NMFS also has worked with the Atlantic States Marine Fisheries Commission and the Atlantic Coastal Cooperative Statistics Program to transition from a NMFS-led data collection system to a state-led data collection approach. In 2016, according to a NMFS official, the Atlantic Coast states will assume responsibility for conducting the Access Point Angler Intercept Survey shoreside interviews to collect marine recreational fishing data from anglers, and NMFS’ role will be to review, certify, and provide funds to support these data collection efforts.

NMFS is also placing renewed emphasis on collaborating with its regional partners to determine future data collection needs and priorities for improving recreational fisheries effort and catch surveys, according to NMFS documents. For example, NMFS’ 2013-2014 MRIP implementation plan recommended establishing a hybrid approach to MRIP data collection. Under this approach, NMFS is to maintain a central role in developing and certifying survey methods and establishing national standards and best practices for data collection, while regions—through the regional fishery information networks or their equivalent—are to be responsible for selecting survey methods and managing data collection. According to NMFS officials and NMFS documentation, NMFS staff participated in a workshop in July 2013 to discuss the initial planning stages for developing this new regional approach to recreational fisheries data collection. According to NMFS officials, NMFS is developing MRIP Regional Implementation Plans to address regional data collection needs and priorities. The NMFS officials said that the West Coast region is scheduled to have a Regional Implementation Plan in early 2016. The officials said the Atlantic and Gulf Coast regions support the new approach to data collection and plan to complete their respective MRIP Regional Implementation Plans in 2016. As part of the new hybrid MRIP data collection approach, NMFS is in the process of identifying regional recreational fisheries data collection funding priorities.

Challenges related to how NMFS communicates with stakeholders, however, persist. For example, some Gulf Coast state fisheries officials expressed concerns that NMFS has not provided sufficient information to improve communication regarding its recreational fisheries data collection activities. One state fisheries official said that NMFS has made some progress working with stakeholders to identify MRIP initiatives to improve recreational fisheries data collection, but it has not adequately communicated how it intends to coordinate and collaborate with its stakeholders to implement MRIP initiatives. Some stakeholders continue to express concerns that NMFS is not adequately communicating its process for developing Gulf of Mexico red snapper catch and effort estimates. For example, some stakeholders cited the presence of larger and more numerous red snapper in the Gulf of Mexico and do not understand the need for continued catch limits and fishing restrictions. NMFS officials told us that, although the Gulf red snapper population is rebounding, and the average weight of red snapper that are caught by anglers has increased, NMFS’ most recent stock assessment confirms that Gulf red snapper continue to be overfished. Therefore, as required by the Magnuson-Stevens Act, red snapper continue to be managed under a stock rebuilding plan. According to these officials, annual catch limits for red snapper are being reached more quickly due to several factors, including higher catch rates and more fishing effort being directed at the more abundant rebuilding stock. This has required even shorter fishing seasons despite increasing stock abundance, as well as corresponding increases to annual catch limits. NMFS officials stated that, in response to a history of exceedance of annual red snapper catch limits and litigation, NMFS is now setting the length of the red snapper fishing season based on a recommendation by the Gulf of Mexico Fishery Management Council to use a buffer of 20 percent of the annual catch limit. This buffer is intended to account for uncertainty resulting from the difficulty of obtaining timely and precise catch estimates, as well as uncertainty stemming from state regulations that provide for longer seasons in state waters. NMFS officials acknowledged that achieving stakeholder understanding of this complex process is an ongoing concern, but they told us they plan to continue communicating with stakeholders to help convey the rationale behind NMFS’ fisheries management decisions.

NMFS Does Not Have a Comprehensive Strategy to Guide Its Data Collection Improvement Efforts

NMFS has taken steps aimed at addressing several data collection challenges, but it does not have a comprehensive strategy to guide its efforts to improve recreational fisheries data collection. The Government Performance and Results Act Modernization Act of 2010 requires, among other things, that federal agencies develop long-term strategic plans that include agency-wide goals and strategies for achieving those goals. Our body of work has shown that these requirements also can serve as leading practices at lower levels within federal agencies, such as at NMFS, to assist with planning for individual programs or initiatives that are particularly challenging. Taken together, the strategic planning elements established under the act and associated Office of Management and Budget guidance, and practices we have identified, provide a framework of leading practices in federal strategic planning and characteristics of good performance measures. These practices include defining a program’s or initiative’s goals, defining strategies and identifying the resources needed to achieve the goals, and developing time frames and using performance measures to track progress in achieving them and inform management decision making. Furthermore, key practices related to communication call for communicating information early and often and developing a clear and consistent communications strategy to help develop an understanding about the purpose of planned changes, build trust among stakeholders and the public, cultivate strong relationships, and enhance ownership for transition or transformation.

According to a NMFS official, the initial 2008 MRIP implementation plan and the subsequent updates are the key documents used to guide NMFS’ recreational fisheries data collection efforts. However, based on our review, NMFS’ MRIP implementation plans do not constitute a comprehensive strategy for improving recreational fisheries data collection consistent with the framework previously discussed. For example, the implementation plans do not consistently and clearly define NMFS’ goals, identify the resources needed to achieve the goals, or develop time frames or performance measures to track progress in achieving them.

Based on our analysis, NMFS does not have a comprehensive strategy because it has been focused primarily on implementing the recommendations of the 2006 National Research Council report. A NMFS official confirmed that MRIP initially focused on implementing the recommendations in the 2006 National Research Council report and meeting the requirements to improve recreational fisheries data collection as described in the Magnuson-Stevens Reauthorization Act that was passed in 2006. According to NMFS officials, the agency’s first priority was to address the recreational fisheries survey design issues identified in the 2006 National Research Council report. Specifically, NMFS determined that it would first design, test, review, certify, and implement new survey designs, such as the new mail-based Fishing Effort Survey. As previously discussed, NMFS intends to transition to a regional data collection approach whereby the agency will collaborate with regional stakeholders, such as states, to identify regional data collection needs. NMFS officials told us that, in hindsight, NMFS could have benefited from a more robust strategic planning approach to MRIP implementation and stated that NMFS recognizes the need to enhance its strategic planning as it begins to transition to a regional data collection approach. NMFS officials told us that NMFS intends to develop strategic planning documents to guide future individual initiatives, using NMFS’ experiences with the transition to the new mail-based Fishing Effort Survey as a template, but they did not provide information about how, or whether, they planned to integrate these documents into a comprehensive strategy or how they would communicate such a strategy to NMFS’ stakeholders. Without a comprehensive strategy, NMFS may have difficulty ensuring that the variety of steps it is taking to improve data collection are prioritized so that the most important steps are undertaken first and may find it difficult to determine the extent to which these steps will help address challenges. Further, without communicating the strategy and NMFS’ progress in implementing it, NMFS may have difficulty building trust among its stakeholders, and these stakeholders may have difficulty tracking the agency’s efforts.

Conclusions

Recognizing the importance of collecting quality and timely data at an acceptable cost to guide recreational fisheries management and conduct fish stock assessments, NMFS has taken many steps to improve its data collection, such as funding several pilot programs to test alternative data collection methods. NMFS has also initiated a fundamental shift in its data collection approach, envisioning a standard-setting and oversight role for NMFS rather than actual data collection, which is to be carried out by partners. However, NMFS does not have a comprehensive strategy to guide the implementation of its various efforts. Without a comprehensive strategy and associated performance measures to assess progress, NMFS may have difficulty ensuring that the variety of steps it is taking to help address the challenges it faces are prioritized so that the most important steps are undertaken first. Likewise, NMFS may have difficulty determining the extent to which these steps will help address challenges or if a different approach may be needed. Moreover, without clearly communicating the strategy to its stakeholders, NMFS may find it difficult to build trust, potentially limiting its ability to effectively implement MRIP improvement initiatives that rely on data collection partners.

Recommendation for Executive Action

To improve NMFS’ ability to capitalize on its efforts to improve fisheries data collection for managing marine recreational fisheries, we recommend that the Secretary of Commerce direct NOAA’s Assistant Administrator for Fisheries to develop a comprehensive strategy to guide NMFS’ implementation of its marine recreational fisheries data collection program efforts, including a means to measure progress in implementing this strategy and to communicate information to stakeholders. As part of this strategy, NMFS should clearly identify and communicate programmatic goals, determine the program activities and resources needed to accomplish the goals, and establish time frames and performance measures to track progress in implementing the strategy and accomplishing goals.

Agency Comments and Our Evaluation

We provided a draft of this report to the Department of Commerce for comment. In its written comments (reproduced in app. II), NOAA, providing comments on behalf of Commerce, agreed with our recommendation that NMFS develop a comprehensive strategy to guide the implementation of its marine recreational fisheries data collection program efforts. NOAA stated that it agrees that transitioning from a primarily research and development focused program to one that is more focused on implementing improvements to recreational fisheries data collection presents an opportunity to engage in strategic planning. Specifically, NOAA stated it will work with its regional stakeholders over the next year to develop MRIP implementation plans that include milestones, timelines, performance metrics, and resource needs. In addition, NOAA stated that a new National Research Council review of its recreational fisheries data collection program will help to inform its strategic planning effort.

NOAA also provided three general comments. First, NOAA stated that our report disproportionally included interviewees from the Gulf Coast, which may weigh the report’s conclusions differently than if other regions were more fully represented. As noted in our scope and methodology appendix (app. I), we selected federal and state agencies and regional organizations to interview based on such factors as geographic representation and locations of large volumes of recreational fishing. According to NMFS statistics, the largest volumes of recreational fishing are in the Gulf of Mexico. As a result, we believe that our selection of agencies and organizations, while not nationally representative, nevertheless provides an appropriate set of perspectives on recreational fisheries management. Second, NOAA stated that it interpreted our statement that we did not conduct a technical evaluation to mean that we are suggesting that a technical evaluation is needed to determine whether NMFS has appropriately prioritized its recreational fisheries data collection challenges. We did not conduct a technical evaluation because it was not within the scope of our review, and it was not our intent to suggest that a technical evaluation is needed. Third, NOAA stated that, while the report identifies several unaddressed recreational fisheries data collection challenges, it does not mention that the challenges require funding levels above the current MRIP budget. Addressing whether NMFS funding levels are sufficient to address the data collection challenges it faces was not within the scope of our review. We do, however, note in our report the importance of making trade-offs in addressing challenges and allocating resources. NOAA also provided technical comments, which we incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the appropriate congressional committees, the Secretary of Commerce, the NOAA Assistant Administrator for Fisheries, and other interested parties. In addition, the report will be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please contact me at (202) 512-3841 or fennella@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix III.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to examine (1) the challenges that have been identified with the National Marine Fisheries Service’s (NMFS) data collection efforts for managing marine recreational fisheries and (2) the steps NMFS has taken to improve data collection and challenges that remain.

To conduct our work, we reviewed and analyzed relevant laws, agency policies, guidance, and other documentation related to fisheries data collection, including documentation related to specific federal and state marine recreational fisheries data collection projects. We also reviewed previous GAO work related to fisheries management. To determine the challenges that have been identified with NMFS’ data collection efforts, we first reviewed reports and evaluations of NMFS’ data collection programs issued since 2006 from the National Research Council, the Department of Commerce Inspector General, NMFS, states, and independent consultants and assessed the extent to which they discussed data collection challenges. Of these reports, we relied primarily on the findings of the National Research Council and NMFS to identify data collection challenges. To obtain insights into the challenges identified in these documents, as well as to obtain information on any additional challenges, we interviewed officials from NMFS headquarters and three of NMFS’ six regional Fisheries Science Centers (Northeast, Northwest, and Southeast); representatives of three of the eight Regional Fishery Management Councils (Gulf of Mexico, Pacific, and South Atlantic) and all three interstate Marine Fisheries Commissions (Atlantic, Gulf, and Pacific States); and officials from state fisheries agencies in Alabama, Florida, Louisiana, Mississippi, North Carolina, Rhode Island, Texas, and Washington. We selected federal and state agencies and regional organizations to interview based on such factors as geographic representation, locations of large volumes of recreational fishing, and representation from key data collection and management stakeholders. The views of representatives from the agencies and organizations we contacted are not generalizable to other agencies and organizations, but they provided various perspectives on recreational fisheries management. In addition, to obtain additional information about data collected by the recreational fishing sector and challenges associated with data collection, as well as to obtain views on recreational fisheries data collection generally, we interviewed 22 nongovernmental marine recreational fisheries stakeholders. Of these stakeholders, 17 had expressed interest in, or concerns about, NMFS’ recreational fisheries data collection to congressional staff. These stakeholders added to the geographic variation and the recreational fishing sectors represented in our review, but their views do not represent the views of NMFS stakeholders generally. To supplement views on recreational fisheries data collection, we interviewed 5 additional stakeholders, including 4 stakeholders identified by NMFS and 1 stakeholder we identified through our previous work on fisheries management. The 22 stakeholders we interviewed included charter boat owners, private recreational anglers, members of academia, and advocacy groups, among others, and represented various geographic locations and different recreational fishing sectors. The NMFS statistical surveys used to collect data for managing recreational fisheries cover a wide range of methods, apply to a wide diversity of locations and often entail in-depth technical knowledge about fisheries data collection. For these reasons, we did not conduct a technical evaluation of these challenges or assess their technical validity.

To determine the steps NMFS has taken to improve data collection and challenges that remain, we conducted interviews as described above and reviewed NMFS’ reports and other documents. Specifically, we reviewed NMFS’ strategic plans, recreational fisheries planning documents, and recreational fisheries data collection program documents. We compared this information with the framework of leading practices in federal strategic planning contained in the Government Performance and Results Act of 1993, the Government Performance and Results Act Modernization Act of 2010, and Office of Management and Budget guidance. We also compared this information to key practices related to communication we identified in previous reports. Consistent with our approach to the previous objective, we did not conduct a technical evaluation of NMFS’ steps to improve data collection or assess the appropriateness of those steps in light of the challenges NMFS faces.

We conducted this performance audit from July 2014 to December 2015 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Comments from the Department of Commerce

Appendix III: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the individual named above, Steve Gaty (Assistant Director), Steve Secrist (Assistant Director), Leo Acosta (Analyst-in- Charge), Mark Braza, Joseph Capuano, Elizabeth Curda, John Delicath, Richard Johnson, Jerry Leverich, Jeanette Soares, and Sara Sullivan made contributions to this report.