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entitled 'Government Reorganization: Potential Benefits and Drawbacks 
of Merging the National Marine Fisheries Service into the Fish and 
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United States Government Accountability Office: 
GAO: 

Report to Agency Officials: 

February 2013: 

Government Reorganization: 

Potential Benefits and Drawbacks of Merging the National Marine 
Fisheries Service into the Fish and Wildlife Service: 

GAO-13-248: 

GAO Highlights: 

Highlights of GAO-13-248, a report to agency officials. 

Why GAO Did This Study: 

NMFS and FWS have primary federal responsibility for managing fish and 
wildlife. The missions of NMFS and FWS have some broad similarities, 
which have prompted long-standing questions about whether merging the 
agencies would improve the efficiency or effectiveness of their 
programs. This report examines (1) the extent to which NMFS and FWS 
share key programmatic responsibilities, (2) potential benefits and 
drawbacks identified by agency officials and stakeholders of merging 
NMFS into FWS, and (3) potential benefits and drawbacks identified by 
agency officials and stakeholders of alternative organizational 
options. To address these issues, GAO reviewed agency documents and 
conducted 97 semistructured interviews with current and former agency 
officials and a wide array of the agencies’ stakeholders, including 
organizations representing fishing and conservation interests. GAO 
performed a content analysis of interview responses. 

What GAO Found: 

While the National Marine Fisheries Service (NMFS) and the Fish and 
Wildlife Service (FWS) share certain key programmatic 
responsibilities, they also have programmatic responsibilities unique 
to each agency. The agencies largely carry out their shared 
responsibilities independently. For example, both agencies implement 
the Endangered Species Act, but NMFS generally does so for species 
found in marine habitats and FWS for species found in fresh water or 
on land. NMFS and FWS also have responsibilities that are unique to 
each agency. One of NMFS’s unique responsibilities is the federal 
management of marine fisheries and one of FWS’s unique 
responsibilities is the management of the National Wildlife Refuge 
System. 

Officials and stakeholders identified several potential benefits and 
drawbacks in a possible merger of NMFS into FWS. In many cases, 
officials and stakeholders differed in their views, as illustrated by 
the following: 

* One potential benefit is improving the efficiency of implementing 
the Endangered Species Act. Currently, when a proposed federal project—
such as building a road—affects species managed by both NMFS and FWS, 
both agencies review the project. Some officials noted that in some 
cases they spend a significant amount of time coordinating their 
reviews and, in these cases, it would be more efficient if a single 
agency were implementing the act. Other officials, however, said that 
having a single agency implement the act may not achieve significant 
efficiencies, since determining how to best minimize effects of a 
project on multiple species is time-consuming regardless of whether 
one or two agencies are involved. 

* A potential drawback is how a merger might change decision making 
for fisheries management. For example, merging the agencies would 
shift responsibility for approving fishery management plans to the 
Secretary of the Interior from the Secretary of Commerce, and some 
officials and stakeholders believed that the Department of the 
Interior would emphasize conserving fish populations more and consider 
the economic effects of management decisions on fishing communities 
less than NMFS does. Others, however, believed a merger would have 
little overall effect on fishery management. They said that because 
the framework for managing federal fisheries, including the criteria 
for evaluating fishery management plans, is established by statute, 
transferring approval authority to the Secretary of the Interior would 
not change fishery management decisions. 

Officials and stakeholders also identified potential benefits and 
drawbacks of several alternative organizational options that have 
previously been proposed—such as moving all of the National Oceanic 
and Atmospheric Administration (NOAA) into Interior, or creating an 
overall department of natural resources, or establishing NOAA as a 
stand-alone agency. For example, moving all of NOAA into Interior 
could better integrate natural resource management by bringing many 
aspects of federal land and ocean management under the same 
department, but it could diminish attention to ocean issues since NOAA 
would be competing with other Interior agencies for funding. Overall, 
officials and stakeholders generally said the drawbacks of 
reorganizing the agencies outweigh the benefits. 

What GAO Recommends: 

GAO is not making any recommendations. This report presents 
information that Congress and the administration could consider in 
determining whether to reorganize federal fish and wildlife agencies. 
GAO provided a draft of this report for review and comment to the 
Departments of Commerce and the Interior. Commerce provided technical 
comments that were incorporated, as appropriate. Interior did not 
provide comments. 

View [hyperlink, http://www.gao.gov/products/GAO-13-248]. For more 
information, contact Anne-Marie Fennell at (202) 512-3841 or 
fennella@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

NMFS and FWS Share Some Programmatic Responsibilities and Differ in 
Others: 

Officials and Stakeholders Identified Several Potential Benefits and 
Drawbacks in a Possible Merger of NMFS into FWS: 

Officials and Stakeholders Also Identified Several Key Potential 
Benefits and Drawbacks of Alternative Organizational Options: 

Agency Comments: 

Appendix I: Former Agency Officials and Stakeholders GAO Interviewed: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Key Practices Found in Successful Mergers and Organizational 
Transformations: 

Table 2: Key Features of Interagency Collaborations and Issues to 
Consider When Collaborating: 

Figures: 

Figure 1: Component Agencies within Commerce and Interior: 

Figure 2: United States Flyways, with Locations of National Wildlife 
Refuges: 

Abbreviations: 

FWS: Fish and Wildlife Service: 

NMFS: National Marine Fisheries Service: 

NOAA: National Oceanic and Atmospheric Administration: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 14, 2013: 

The Honorable Ken Salazar: 
Secretary of the Interior: 

The Honorable Rebecca Blank: 
Acting Secretary and Deputy Secretary of Commerce: 

The missions of the National Marine Fisheries Service (NMFS) and the 
Fish and Wildlife Service (FWS) have some broad similarities. NMFS--a 
component of the National Oceanic and Atmospheric Administration 
(NOAA) within the Department of Commerce--manages living marine 
resources, including federal marine fisheries and certain protected 
species. To help accomplish this mission, NMFS implements federal 
laws, conserves and restores coastal and marine habitats, and conducts 
research to support resource management. Similarly, FWS, within the 
Department of the Interior, conserves, protects, and enhances fish, 
wildlife, plants, and their habitats by implementing federal laws, 
protecting and restoring habitats, and conducting research. These 
similarities have prompted long-standing questions about whether 
merging the agencies would improve the efficiency or effectiveness of 
their programs. Since 1970, dozens of proposals to reorganize the 
agencies have been suggested by Congress, the President, and 
presidential advisory councils. 

Against this backdrop, this report examines (1) the extent to which 
NMFS and FWS share key programmatic responsibilities, (2) potential 
benefits and drawbacks identified by agency officials and stakeholders 
of merging NMFS into FWS, and (3) potential benefits and drawbacks 
identified by agency officials and stakeholders of alternative 
organizational options. We prepared this report under the Comptroller 
General's authority to conduct evaluations on his own initiative. We 
initiated this work in the 112TH Congress at the request of the 
Ranking Member of the Subcommittee on Federal Financial Management, 
Government Information, Federal Services, and International Security; 
Committee on Homeland Security and Governmental Affairs, who did not 
return to the 113TH Congress. 

To determine the extent to which NMFS and FWS share key programmatic 
activities, we reviewed pertinent laws and agency documents, including 
strategic plans and budget documents. To obtain additional information 
about similarities and differences in the agencies' programs, we 
interviewed agency leadership and officials responsible for key agency 
programs. To identify potential benefits and drawbacks of merging NMFS 
into FWS and alternative organizational options, we conducted 97 
semistructured interviews with current and former agency officials and 
a wide array of the agencies' stakeholders. Current agency officials 
we interviewed include those with Commerce, Interior, NOAA, NMFS, and 
FWS. To gain a broader perspective on these issues, we interviewed 
Secretaries of Commerce and the Interior and heads of NOAA, NMFS, and 
FWS from each of the two previous administrations. We also interviewed 
a nonprobability sample of the agencies' stakeholders, selected to 
represent a wide range of interests and different types of engagement 
with the agencies. Stakeholders we interviewed included officials from 
four of the eight regional fishery management councils and from state 
fish and wildlife agencies, as well as from nongovernmental 
organizations representing the fishing industry and conservation 
interests. Appendix I lists the former agency leaders and stakeholders 
we interviewed. The interviewees provided varied perspectives on the 
potential benefits and drawbacks of reorganizing the agencies. We 
performed a content analysis of their responses to our interview 
questions and identified several broad categories of potential 
benefits and drawbacks. Because we used a nonprobability sample, the 
information we obtained from these interviews cannot be generalized to 
all current and former agency officials and stakeholders. As such, we 
do not report the number of respondents who identified specific 
potential benefits and drawbacks; rather we report all issues as 
identified by "some" officials and stakeholders. To determine the 
alternative organizational options to discuss in our interviews with 
officials and stakeholders, we reviewed previous reorganization 
proposals involving NMFS and FWS and identified the options most 
commonly proposed. 

To obtain regional perspectives on these issues, we conducted site 
visits to two areas of the country--New England and the Pacific 
Northwest--meeting with agency officials and stakeholders in Boston, 
Gloucester, and Hadley, Massachusetts; Portland, Oregon; and Olympia 
and Seattle, Washington. We selected these locations to provide 
geographical variation and to obtain additional information about some 
of the key challenges facing the agencies. For example, we selected 
New England in part because of recent concerns in that region over 
NMFS's role in managing marine fisheries and because Atlantic salmon 
is one of the few species for which NMFS and FWS share Endangered 
Species Act responsibilities. We selected the Pacific Northwest in 
part because the presence in many of the region's watersheds of 
Pacific salmon listed under the Endangered Species Act means that many 
projects, such as building a road or a dam, may affect species managed 
by both NMFS and FWS and therefore need to be reviewed by both 
agencies. 

We conducted this performance audit from February 2012 to February 
2013 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. 

Background: 

In fiscal year 2012, NMFS's budget was approximately $880 million, 
which was about 17 percent of NOAA's overall budget. NMFS is the third-
largest component of NOAA by budget, after the National Environmental 
Satellite, Data, and Information Service and the National Weather 
Service. In fiscal year 2012, FWS's budget was about $1.5 billion, 
which was about 13 percent of Interior's overall budget. FWS is the 
third-largest component of Interior, after the National Park Service 
and the Bureau of Indian Affairs. Figure 1 lists the component 
agencies within Commerce and Interior. 

Figure 1: Component Agencies within Commerce and Interior: 

[Refer to PDF for image: chart] 

Department of Commerce: 

* Bureau of Economic Analysis; 
* Bureau of Industry and Society; 
* Census Bureau; 
* Economic Development Administration; 
* Economic and Statistics Administration; 
* International Trade Administration; 
* Minority Business Development Agency; 
* National Oceanic and Atmospheric Administration: 
- National Environmental Satellite, Data, and Information Service; 
- National Marine Fisheries Service; 
- National Ocean Service; 
- National Weather Service; 
- Office of Oceanic and Atmospheric Research; 
* National Telecommunications and Information Administration; 
* National Institute of Standards and Technology; 
* National Technical Information Service; 
* U.S. Patent and Trade Office. 

Department of the Interior: 

* Bureau of Indiana Affairs; 
* Bureau of Land Management; 
* Bureau of Ocean Energy Management; 
* Bureau of Reclamation; 
* Bureau of Safety and Environmental Enforcement; 
* Fish and Wildlife Service; 
* National Park Service; 
* Office of Surface Mining, Reclamation, and Enforcement; 
* U.S. Geological Survey. 

Source: GAO. 

[End of figure] 

NMFS is headquartered in Silver Spring, Maryland, and has over 20 
laboratories, regional offices, and other facilities nationwide. NMFS 
employs a staff of approximately 2,800, including biologists, social 
scientists, economists, and law enforcement officers. FWS is 
headquartered in Washington, D.C., and Arlington, Virginia, and has 
more than 700 management units across the country, including more than 
550 national wildlife refuges and 80 field stations.[Footnote 1] FWS 
employs approximately 9,500 staff across the country, with expertise 
in such disciplines as biology, the social sciences, economics, and 
law enforcement. 

Federal fish and wildlife programs have been reorganized several 
times. The Fish and Wildlife Service traces its roots back to two 
entities: the U.S. Fish Commission and the Office of Economic 
Ornithology and Mammalogy. The U.S. Fish Commission was established in 
1871 as an independent agency to address a decline in edible fish. In 
1903, it became the Bureau of Fisheries and was transferred to the 
Department of Commerce and Labor; it was later retained as part of the 
Department of Commerce. The Office of Economic Ornithology and 
Mammalogy was established as part of the Department of Agriculture in 
1886 and renamed the Bureau of Biological Survey in 1905. Its purposes 
were, among other things, to investigate the food habits, 
distribution, and migrations of North American birds and mammals in 
relation to agriculture, horticulture, and forestry. The Bureau of 
Fisheries and the Bureau of Biological Survey were transferred to the 
Department of the Interior in 1939[Footnote 2] and combined into FWS 
in 1940;[Footnote 3] both of these moves were achieved by executive 
order. In 1956, Congress established FWS in statute and divided the 
agency into two bureaus: the Bureau of Sport Fisheries and Wildlife 
and the Bureau of Commercial Fisheries. NMFS was established in 1970, 
when the Bureau of Commercial Fisheries was transferred to the 
Department of Commerce and made a part of NOAA, a newly established 
agency.[Footnote 4] NOAA was created largely in response to the 
recommendations of the Stratton Commission, which called for 
establishment of a new agency to administer the nation's civilian 
marine and atmospheric programs. 

Since 1970, Congress, the President, and presidential advisory 
councils have put forth dozens of reorganization proposals involving 
NMFS, FWS, or both. The proposals were generally intended to improve 
the effectiveness or efficiency of natural resource management; none 
of them were implemented. These proposals include: 

* Merging NMFS into FWS. At least two bills have been introduced to 
move all or part of NMFS into FWS. For example, in 1993, a bill was 
introduced that would have moved the functions performed by NMFS and 
other NOAA offices to FWS.[Footnote 5] Another bill was introduced 2 
years later that would have, among other actions, transferred NMFS's 
science functions to FWS, enforcement functions to the Secretary of 
Transportation, and seafood inspection functions to the Secretary of 
Agriculture.[Footnote 6] 

* Moving NOAA into Interior. In 2004, a bill was introduced that would 
have moved NOAA from Commerce to Interior.[Footnote 7] More recently, 
as a part of a larger initiative to reorganize federal business-and 
trade-related agencies, the Obama administration in 2012 proposed 
moving NOAA from Commerce to Interior. 

* Establishing a department of natural resources. Numerous proposals 
have been put forth to establish a department housing federal natural 
resource agencies within a single department. For example, in 1979, 
the Carter administration proposed creating a new Department of 
Natural Resources, which would have combined a number of agencies, 
including NOAA, the Forest Service, and a number of programs from the 
Department of the Interior.[Footnote 8] 

* Establishing NOAA as a stand-alone agency. Other proposals have 
sought to separate NOAA from Commerce and establish it as a stand-
alone agency. For example, in 1983, a bill was introduced to establish 
NOAA as an independent agency.[Footnote 9] In addition, in 2003, the 
Pew Oceans Commission proposed establishing an independent ocean 
agency that would have consolidated many ocean and coastal programs--
including those currently located in NOAA, the Environmental 
Protection Agency, the Department of Agriculture, and the Army Corps 
of Engineers.[Footnote 10] 

* Other proposals to reorganize certain NMFS and FWS responsibilities. 
Other proposals have aimed to reorganize, transfer, or consolidate the 
agencies' responsibilities in such areas as endangered species 
management. For example, a 1998 bill proposed eliminating the 
Secretary of Commerce's role in implementing and enforcing the 
Endangered Species Act by transferring Commerce's responsibilities 
under the act to Interior.[Footnote 11] In addition, another proposal, 
put forth by the American Fisheries Society in 1986, suggested 
creating a federal fishery agency, which would have consolidated 
NMFS's and FWS's fishery management functions.[Footnote 12] 

In addition, proposals have also been made to strengthen NOAA's 
existing organizational structure. For example, in 2004, the U.S. 
Commission on Ocean Policy recommended creating an organic act for 
NOAA to codify its mission in law.[Footnote 13] Following the 
commission's recommendations, a bill was introduced proposing to 
establish an organic act for NOAA, but it did not become law.[Footnote 
14] 

Theories of organizational change in the federal government have 
generally had two broad, competing themes, as described in a 2009 GAO 
report.[Footnote 15] On the one hand, some public administration 
experts, holding that better coordination occurs among agencies within 
a single department, have recommended reorganizing government to 
consolidate agencies with similar functions under one large 
department. For example, to improve the coordination of domestic 
security matters in response to the September 11, 2001, terrorist 
attacks, the Department of Homeland Security was created in 2002, 
consolidating more than 20 agencies or portions of agencies into one 
new department. On the other hand, recognizing that some crosscutting 
issues may affect the interests of multiple agencies, other experts 
have instead recommended working within existing organizational 
structures to clarify an agency's mission and align program goals and 
objectives with that mission. We have previously reported that 
reorganizations and consolidations can be complex and potentially 
expensive and that decision makers must balance the benefits and costs 
of any potential consolidation.[Footnote 16] 

NMFS and FWS Share Some Programmatic Responsibilities and Differ in 
Others: 

NMFS and FWS share certain key programmatic responsibilities, 
including protecting endangered and threatened species and marine 
mammals, along with conserving and restoring fish and wildlife 
habitat; the agencies are generally responsible for species in 
different habitat types. The agencies also share certain programmatic 
responsibilities related to law enforcement, scientific research, 
aquaculture, and international activities. NMFS and FWS also have 
programmatic responsibilities that are unique to each agency. One of 
NMFS's key responsibilities is the federal management of marine 
fisheries, whereas one of FWS's key responsibilities is the management 
of the National Wildlife Refuge System. Other differences in the 
agencies' responsibilities include FWS's role in conserving migratory 
birds and NMFS's management of a voluntary seafood inspection program. 

Protection of Endangered and Threatened Species and Marine Mammals: 

NMFS and FWS both work to protect, conserve, and recover or enhance 
species under the Endangered Species Act and Marine Mammal Protection 
Act, but the agencies are generally responsible for species in 
different habitat types. The agencies, in a 1974 memorandum of 
understanding, determined that in general NMFS would take 
responsibility under the Endangered Species Act for marine species, 
and FWS would take responsibility for species found in fresh water and 
on land.[Footnote 17] Responsibility for implementing the Marine 
Mammal Protection Act is split as well: NMFS has responsibility for 
most marine mammals (including whales, dolphins, and seals), and FWS 
is responsible for a few species--such as manatee, polar bear, and 
walrus--that are generally found close to land.[Footnote 18] 
Implementing these laws is an important part of each agency's 
responsibilities, accounting for roughly one-third of NMFS's fiscal 
year 2011 budget and roughly one-fifth of FWS's fiscal year 2011 
budget. 

The agencies carry out their responsibilities for implementing these 
acts largely independently from each other, but in some circumstances, 
the agencies have joint responsibility for a species and work 
together. Specifically, the agencies have agreed to jointly implement 
the Endangered Species Act for eight species that spend part of their 
lives in marine waters and part of their lives in fresh water or on 
land: Atlantic salmon, Gulf sturgeon, and six species of sea turtle. 
[Footnote 19] For each of these eight species, the agencies have 
developed agreements and processes to define each agency's role in 
implementing the act. In some circumstances, the agencies are both 
involved in making decisions, and in others the agencies make 
decisions independently. For example, a statement of cooperation for 
managing Atlantic salmon outlines that the agencies will both 
participate in making any decisions related to updating the status of 
the species. In contrast, the statement of cooperation also lists 
areas where each agency has its own responsibilities: for example, 
NMFS is responsible for designating critical habitat, and FWS is 
responsible for maintaining fish hatcheries.[Footnote 20] 

In addition, NMFS and FWS have taken steps to coordinate certain 
aspects of their implementation of the Endangered Species Act and 
Marine Mammal Protection Act. For example: 

* The agencies are working together to identify differences in the 
agencies' regulations, policies, and guidance related to the 
Endangered Species Act and are proposing changes to make the agencies' 
approaches more similar. For example, in August 2012, the agencies 
jointly published a proposed rule, stating that the agencies are to 
release the results of their economic impact analyses--required before 
designating critical habitat for listed species--concurrently with 
releasing the draft critical habitat designation for public 
comment.[Footnote 21] Under its current approach, FWS conducts the 
economic impact analysis after it publishes a proposed critical 
habitat designation for public comment and releases the results of the 
economic analysis several months later. NMFS follows a process similar 
to the one in the proposed rule. The revision is intended to align 
FWS's approach with NMFS's and to bring greater transparency to the 
overall process of designating critical habitat. 

* Similarly, the agencies are developing a joint policy interpreting 
"significant portion of its range"--a phrase used in the Endangered 
Species Act's definitions of endangered and threatened species. 
[Footnote 22] NMFS has never formally interpreted the phrase, and an 
earlier FWS interpretation was rejected by the courts and subsequently 
withdrawn. The two agencies recently issued a draft policy 
interpreting the phrase that, according to the agencies, is consistent 
with NMFS's existing informal interpretation.[Footnote 23] 

* NMFS and FWS joined with an association of state fish and wildlife 
agencies in 2010 in forming a federal-state Endangered Species Act 
joint task force, which is examining ways to facilitate effective 
cooperation among NMFS, FWS, and the states. Among other actions, this 
task force has formed a working group that is exploring options for 
improving the consistency of cooperative agreements entered into with 
states by NMFS and FWS. 

Habitat Conservation and Restoration for Fish and Wildlife: 

NMFS and FWS also both undertake a variety of actions to restore and 
conserve habitat for the species they are responsible for. The 
agencies' efforts often focus on different habitat types, NMFS in 
marine environments and FWS in terrestrial and freshwater 
environments. Nonetheless, according to NMFS and FWS officials, in 
some cases, such as on coastlines and in estuaries, both agencies may 
have responsibilities for the same habitat and may work together to 
improve habitat for species of interest to both agencies. Because much 
fish and wildlife habitat is partly or entirely on land that is 
privately owned, the agencies provide funding and technical assistance 
to state and local governments and to private, nonprofit, and other 
entities to conserve and restore habitat. For example, through its 
Community-Based Restoration Program, NMFS provides approximately $8 
million annually to local partners to restore coastal and estuarine 
ecosystems; according to agency documents, the program has funded 
habitat restoration projects in 26 states and enhanced more than 
69,000 acres of habitat. In a series of projects under this program, 
for example, NMFS worked with and provided funds to the Washington 
Department of Fish and Wildlife and a local government group to 
protect and restore over 1,000 acres of habitat in Puget Sound for 
juvenile Pacific salmon. Similarly, FWS's Partners for Fish and 
Wildlife Program has funded restoration of wetland and upland habitat 
on nearly 4 million acres of private land; FWS has also helped fund 
state fish and wildlife agencies to protect and restore habitat for 
recreation, such as fishing and hunting. According to FWS, over the 
past 75 years, it has provided about $14.3 billion to the states for 
these purposes. 

In environments where the agencies' interests intersect--as they do on 
coastlines and in estuaries--the agencies have sometimes worked 
together to help other entities conserve and protect habitat, 
according to agency officials. NMFS and FWS officials told us that 
habitat restoration projects are often sponsored by state or local 
agencies and by nongovernmental organizations and that if a project is 
intended to benefit habitat of interest to both NMFS and FWS, the 
sponsoring entity will approach both agencies for funding and 
technical assistance. If both agencies are involved, NMFS and FWS 
officials at the local level may work together and with the sponsoring 
agency to determine each agency's role in a project. This arrangement, 
officials told us, allows a single project to improve habitat for 
species of interest to both agencies. 

NMFS and FWS are also both involved in assessing damages to natural 
resources for which they are responsible.[Footnote 24] For example, 
habitat can be damaged by oil spills and releases of other toxic 
materials, such as mercury and other contaminants. Under the 
Comprehensive Environmental Response, Compensation, and Liability Act; 
the Clean Water Act; and the Oil Pollution Act, NMFS and FWS conduct a 
variety of activities, including assessing the damage resulting from 
such releases.[Footnote 25] For example, after the Deepwater Horizon 
drilling rig explosion in April 2010 and the subsequent oil spill in 
the Gulf of Mexico, both NMFS and FWS--as well as other federal and 
state agencies--have been assessing damages to natural resources for 
which they have responsibility. The agencies' initial assessments led 
to an agreement, in which one of the responsible parties agreed to 
provide $1 billion to fund projects to benefit the natural resources 
damaged by the spill. The agencies are still assessing damages from 
the spill, which could lead to additional compensation by responsible 
parties. 

In addition, NMFS and FWS are each involved in addressing the effects 
of certain types of development on fish and wildlife habitat. For 
example, hydroelectric dams can affect fish habitat by altering a 
river's seasonal flow patterns, ability to transport sediment, and 
temperature. Under the Federal Power Act, the agencies issue license 
conditions to protect federal lands and prescriptions to assist fish 
passage on these projects.[Footnote 26] These provisions include 
requirements for maintaining minimum stream flows or spilling water 
over dams during certain times of the year to avoid harm to young fish 
by the dams' turbines. In addition, many federal development projects-
-such as building a road or a dam--can affect habitat for fish and 
wildlife species protected under the Endangered Species Act. In such 
cases, federal agencies carrying out such projects must consult with 
NMFS, FWS, or both; NMFS and/or FWS may in turn identify measures that 
the federal agencies can take to mitigate these effects. Similarly, 
federal projects can also affect habitat important to sustaining 
fisheries. Under the Magnuson-Stevens Act, federal agencies must 
consult with NMFS on actions that may adversely affect "essential fish 
habitat"--habitat necessary to fish for spawning, breeding, feeding or 
growing to maturity--and NMFS must recommend measures that can be 
taken by federal agencies to conserve the habitat.[Footnote 27] For 
example, if the Army Corps of Engineers proposed dredging a river 
channel to improve navigation, NMFS would review the project to 
determine if it would have a negative impact on designated essential 
fish habitat and, if so, would recommend steps--such as a buffer area 
around certain areas or restricting dredging activities. 

Law Enforcement: 

NMFS and FWS both have law enforcement programs to help protect the 
resources under each agency's jurisdiction. For example, NMFS enforces 
fishery regulations because one of that agency's key programmatic 
responsibilities is federal management of marine fisheries, whereas 
FWS enforces migratory bird hunting regulations because conservation 
of migratory birds and their habitats is one of its key 
responsibilities. FWS also enforces federal laws on the millions of 
acres of federal lands the agency is responsible for managing. In some 
cases, the two agencies enforce the same laws, such as the Endangered 
Species Act. In such cases, the agencies enforce these laws as they 
apply to the species each is responsible for, which has led to NMFS's 
enforcing the act predominantly in marine environments and FWS in 
terrestrial and freshwater environments. FWS also inspects commercial 
cargo shipments and passengers entering the United States, stationing 
officers at selected ports and along the border with Canada and Mexico 
to ensure compliance with laws and treaties regarding wildlife trade; 
FWS and NMFS officials told us that FWS notifies NMFS when these 
inspections identify issues related to species of concern to NMFS. 
NMFS officials told us that the agency does not have a dedicated 
border presence but that its officers routinely work with U.S. Customs 
and Border Protection to inspect cargo and passengers entering the 
United States to enforce compliance with domestic laws and 
international treaties regarding seafood and wildlife trade for 
species within the scope of agency jurisdiction. 

Scientific Research: 

NMFS and FWS both conduct scientific research to develop information 
needed to help the agencies manage many of their programs. For 
example, among other areas of research, NMFS collects data on the 
cumulative weight of species caught in marine fisheries in different 
regions of the country and develops scientific models to estimate the 
health of fish populations, information NMFS uses to make decisions 
about how to manage the fisheries. Similarly, among FWS's research 
activities are efforts to collect and analyze data on the health of 
migratory bird populations, information it uses to manage hunting. 

NMFS's science program is much larger than FWS's. NMFS officials 
estimated the agency spent approximately $298 million on scientific 
activities in fiscal year 2011, almost one-third of its total budget; 
in contrast, FWS officials estimated the agency spent approximately 
$62 million on scientific activities in fiscal year 2011, about 4 
percent of the agency's budget.[Footnote 28] The agencies also have 
structured their scientific research programs differently. NMFS has 
established an Office of Science and Technology to oversee its science 
program and six regional science centers, which conduct research to 
support NMFS's management of fisheries and other marine resources. FWS 
has integrated its scientific research into various programmatic 
activities, such as the endangered species and migratory bird 
programs, rather than having a separate science research program. 

Aquaculture: 

NMFS and FWS both have various responsibilities related to aquaculture 
operations, such as fish and shellfish farms, although other agencies 
also play an important role. For example, aquaculture in the United 
States generally occurs in nearshore marine waters or onshore (such as 
in ponds or tanks), under the jurisdiction of individual states. 
Nevertheless, aquaculture operations may also need to obtain federal 
permits: operations that place structures in navigable waters may need 
to obtain permits from the Army Corps of Engineers, and operations 
that discharge pollutants into waters of the United States may need to 
obtain permits from the Environmental Protection Agency.[Footnote 29] 
NMFS and FWS both consult with the state and federal agencies involved 
in permitting aquaculture facilities to reduce the effect these 
facilities have on the fish populations the agencies are responsible 
for managing. NMFS has a more direct role in relation to offshore 
marine aquaculture--managing such activities in federal waters, in 
consultation with stakeholders, under the Magnuson-Stevens Act. NOAA 
also reports that it is working with stakeholders to develop 
regulations for aquaculture in federal waters.[Footnote 30] Both 
agencies also conduct or fund research to develop and improve 
techniques and equipment that can help advance the aquaculture 
industry. FWS has a substantial hatchery program as well, operating 72 
national fish hatcheries to help, among other purposes, ensure the 
recovery of threatened or endangered species; restore native fish 
stocks; and mitigate the effects of federal water development 
projects, such as hydroelectric dams and irrigation projects. NMFS 
helps fund some of these hatcheries.[Footnote 31] 

International Activities: 

NMFS and FWS both undertake a variety of international activities 
related to the species they manage. Both agencies work with the 
Department of State and other federal agencies to administer 
international treaties related to fish and wildlife. For example, FWS 
participates in international discussions determining which species 
warrant protection under the Convention on International Trade in 
Endangered Species,[Footnote 32] an international agreement intended 
to ensure that international trade in certain plants and animals does 
not threaten their survival. Similarly, NMFS participates in 
international discussions--for example, through the International 
Convention for the Conservation of Atlantic Tunas--related to the 
conservation and management of highly migratory fish stocks. Both 
agencies also assist other countries, for example by providing 
technical expertise or funding for projects to protect or enhance 
wildlife and habitat. 

Marine Fisheries: 

One of the key differences between the agencies is that NMFS is the 
principal federal agency managing commercial and recreational marine 
fisheries in federal waters, whereas FWS's role in these fisheries is 
primarily advisory. Managing these fisheries is a major component of 
NMFS's programmatic responsibilities, constituting approximately one-
fifth of its annual budget. The Magnuson-Stevens Act establishes the 
framework for managing fisheries in federal waters. Under the act, 
NMFS and eight regional fishery management councils play critical 
roles in fishery management. NMFS is a voting member on each fishery 
management council. NMFS also furnishes data and scientific analyses 
critical to the fishery management councils' decision making. For 
example, NMFS's regional science centers assess the health of various 
fish stocks, information the councils use in setting catch limits. 
NMFS also has seats on a number of committees established by the 
councils to examine specific topics, such as scientific information or 
management of particular fishery sectors. Each fishery management 
council is responsible for developing a fishery management plan for 
each fishery in its region that requires conservation and management. 
[Footnote 33] The Secretary of Commerce reviews the plans to determine 
if they comply with Magnuson-Stevens Act requirements and other 
applicable law, and, if so, approves them. In contrast, FWS plays 
primarily an advisory role in federal fishery management. A nonvoting 
member on the regional fishery management councils, FWS advises the 
councils on issues such as reducing the impact of fisheries on 
migratory birds and certain marine mammals. For some of the councils, 
FWS also sits on advisory committees, such as the habitat committee, 
which makes recommendations to the council on how to resolve habitat 
issues. 

NMFS and FWS are also involved in supporting certain state coastal 
fishery programs. Specifically, the Atlantic States Marine Fisheries 
Commission consists mostly of representatives of the 15 Atlantic coast 
states, but NMFS and FWS are also voting members. The commission 
develops and approves fishery management plans--similar to those 
developed by the regional councils for federal fisheries--for stocks 
that move, or are broadly distributed, within the waters of two or 
more states or waters under both federal and state jurisdiction. 

National Wildlife Refuge System: 

Another key difference between NMFS and FWS is that FWS manages the 
National Wildlife Refuge System, whereas NMFS generally does not have 
land management responsibilities. FWS has jurisdiction over 
approximately 150 million acres of fish and wildlife habitat through 
its management of more than 550 national wildlife refuges in the 
National Wildlife Refuge System, whose management is one of the 
agency's core responsibilities and constitutes approximately one-third 
of its annual budget. Although NMFS also has responsibilities related 
to habitat, it generally does not directly manage lands or waters 
specifically for that purpose. The primary purpose of the National 
Wildlife Refuge System is to provide for the conservation; management; 
and, where appropriate, restoration of fish, wildlife, and plants and 
their habitats. The refuge system includes lands and waters 
representing a full range of habitat types, including wetlands, 
grasslands, forests, and coastal and marine areas. These areas provide 
habitat for hundreds of species of birds, mammals, and fish, including 
more than 250 species listed as threatened or endangered under the 
Endangered Species Act. For example, more than 200 wildlife refuges 
have been established specifically to protect breeding or wintering 
habitat for migratory birds, with many refuges strategically located 
along migratory bird corridors (known as "flyways") to offer resting 
and feeding areas to long-distance migrants (see fig. 2). In addition, 
approximately 180 wildlife refuges protect sensitive oceanic, coastal, 
and estuarine areas that are critical nurseries for many fisheries. 

Figure 2: United States Flyways, with Locations of National Wildlife 
Refuges: 

[Refer to PDF for image: illustrated map of continental U.S.] 

Depicted on map: 

Pacific flyway; 
Central flyway; 
Mississippi flyway; 
Atlantic flyway; 
Locations of national wildlife refuges. 

Source: GAO and FWS; Map REsources (map). 

[End of figure] 

Migratory Birds: 

In addition to stewardship over the national wildlife refuges, the 
explicit conservation of migratory birds and their habitats is another 
key FWS responsibility. The agency monitors and assesses the health of 
migratory bird populations and evaluates the effects of human and 
environmental factors on bird population dynamics and distribution. 
Many migratory birds are hunted, and under the Migratory Bird Treaty 
Act, FWS is responsible for establishing the length of hunting seasons 
and limits on the number of birds hunters may take.[Footnote 34] FWS 
also implements other laws pertaining to migratory birds, including 
the Fish and Wildlife Conservation Act, the Bald and Golden Eagle 
Protection Act of 1940, and the Neotropical Migratory Bird 
Conservation Improvement Act of 2000.[Footnote 35] In addition, FWS 
provides information to help businesses avert or minimize the impacts 
on migratory birds of communication towers, wind turbines, and fishing. 

Although conserving migratory birds is a key FWS responsibility, NMFS 
also has a responsibility to reduce the effect of its management 
actions, in particular those related to commercial fisheries, on 
migratory bird populations. Specifically, because the actions of many 
federal agencies can affect migratory bird populations, Executive 
Order 13186 directs all federal agencies that take actions that have, 
or are likely to have, a measurable negative effect on migratory birds 
to develop and implement a memorandum of understanding with FWS to 
promote the conservation of migratory bird populations.[Footnote 36] 
NMFS and FWS described their respective responsibilities for migratory 
birds in a June 2012 memorandum of understanding. For example, one of 
NMFS's responsibilities is to integrate principles for migratory bird 
conservation into its fisheries and other management plans and, to the 
extent practicable, to avoid or minimize the adverse effects of its 
actions on migratory birds. One of FWS's responsibilities is to inform 
NMFS and the regional fishery management councils of the potential 
effects that fishery practices may have on migratory birds and of 
steps to reduce those effects. The 2006 amendments to the Magnuson-
Stevens Act also direct NMFS to establish a program to reduce the 
number of seabirds accidentally caught in fishing equipment. 

Fee-for-Service Seafood Inspection: 

Another difference between NMFS and FWS is that NMFS manages a 
voluntary seafood inspection program, under which fishing vessels and 
processors can pay the agency to inspect seafood products and 
processing facilities. Through this program, NMFS inspects the 
sanitation of participating vessels and facilities, evaluates the 
quality and condition of seafood products, and certifies that 
participating vessels and facilities comply with all applicable food 
regulations.[Footnote 37] For example, processors can request that 
NMFS inspect processed seafood products--such as breaded fish sticks--
to certify that they contain a specified amount of seafood. This 
inspection program also facilitates international trade. For example, 
NMFS can certify that seafood products exported from the United States 
meet the importing country's requirements and can offer inspection 
services to foreign processors and importers to help them meet U.S. 
regulations and requirements, reducing the likelihood of trade 
shipments being delayed due to questions about their compliance with 
import requirements. According to a senior program official, 
approximately 300 facilities contracted with NMFS for seafood 
inspection services and paid approximately $26 million for them in 
fiscal year 2012. 

Officials and Stakeholders Identified Several Potential Benefits and 
Drawbacks in a Possible Merger of NMFS into FWS: 

The main potential benefits of merging NMFS into FWS that agency 
officials and stakeholders identified include improving the 
effectiveness and efficiency of implementing the Endangered Species 
Act and Marine Mammal Protection Act, better integrating natural 
resource management, improving habitat conservation and law 
enforcement programs, and realizing cost savings. Officials and 
stakeholders also cited potential drawbacks, including the potential 
for a merger to disrupt marine fisheries management, sever existing 
connections between NMFS and other NOAA offices, result in transition 
costs, and broadly disrupt agency programs in the short term. In many 
cases, however, officials and stakeholders differed in their views, 
both on whether they saw a potential merger outcome as a benefit or a 
drawback and on the likelihood and importance of that outcome. 
Previous GAO work has identified a number of key management practices--
including ensuring that top leadership drives a transformation and 
establishing clear goals to guide the transformation--that could help 
mitigate the program disruptions and transition costs that inevitably 
accompany reorganization. 

Potential to Improve Implementation of the Endangered Species Act and 
Marine Mammal Protection Act: 

A key potential benefit of merging the agencies, some officials and 
stakeholders said, is that doing so could improve the effectiveness 
and efficiency of the agencies' implementation of the Endangered 
Species Act. These officials and stakeholders identified several ways 
that merging the agencies could yield such possible benefits, 
including the following: 

* Better protection for jointly managed threatened and endangered 
species. According to agency officials, joint management of certain 
species by NMFS and FWS has in some cases not been as effective as it 
might be because neither agency has sole responsibility for the 
overall well-being of the species in question. For example, the 
agencies have split their responsibilities for managing sea turtles so 
that NMFS is responsible for the animals while they are in the marine 
environment, and FWS is responsible for them on land. As we reported 
in 2012,[Footnote 38] one effect of this division is that the agencies 
make some decisions affecting turtles, such as authorizing the 
harassment, harming, or killing of turtles (known as take), without 
consistently sharing information about their decisions.[Footnote 39] 
According to sea turtle experts interviewed for that report, each 
agency may therefore be authorizing sea turtle take without knowing 
how much its counterpart has authorized, and the combined allowance 
may be harming threatened or endangered sea turtles and delaying their 
recovery. According to a former FWS director, it is important for one 
agency to have responsibility for monitoring cumulative impacts on 
species to effectively conserve and protect them under the act. 

* Less need for interagency coordination. Agency officials also noted 
that in some cases they currently spend a significant amount of time 
coordinating actions between the two agencies, and in such cases, it 
could be more efficient if a single agency were implementing the act. 
For example, for the eight species NMFS and FWS manage jointly under 
the Endangered Species Act, program officials told us, it takes longer 
to make some decisions regarding species management because both 
agencies need to agree. Moreover, if the two agencies disagree on a 
course of action, no single decision maker can hear both sides and 
ultimately make a choice, which, officials said, can lead to months of 
high-level negotiations to resolve. Similarly, program officials told 
us it was important that they coordinate the agencies' reviews of 
projects affecting multiple species, such as building a road or dam, 
where one or more of the species are managed by NMFS and the other(s) 
by FWS.[Footnote 40] These reviews may direct the project sponsor to 
take specified measures to mitigate the impact of the project on 
listed species. Some stakeholders told us that when the agencies do 
not work together when developing these mitigation requirements, NMFS 
and FWS may provide project sponsors with conflicting requirements for 
their projects, requiring the sponsors to go back to the agencies so 
they can resolve the conflict. NMFS and FWS officials told us they 
often work with each other to ensure that their mitigation measures do 
not conflict, but they do not always do so. As a senior NMFS official 
explained, the agencies may not coordinate with each other when they 
put a higher priority on meeting deadlines for completing their own 
reviews over such coordination. 

* Streamlined process for the public. Some officials and stakeholders 
told us that having a single agency implementing the Endangered 
Species Act could also be more efficient and simpler for the public. 
Aquaculture and timber industry stakeholders we spoke with told us 
they are frustrated by the requirement to consult separately with each 
agency if a project affects species managed by both agencies. Some 
senior agency officials and stakeholders said a significant potential 
benefit of merging NMFS into FWS is that it could create "one-stop 
shopping," where permittees could go to one agency for all their 
species-related approvals, simplifying and streamlining the permitting 
process. 

Some officials and stakeholders also noted that merging the agencies 
would likely lead to greater consistency in how the Endangered Species 
Act and Marine Mammal Protection Act were implemented, which could 
help ensure that the agencies apply protections under the acts 
similarly. Officials and stakeholders identified several instances 
where NMFS and FWS had adopted different regulations, policies, and 
guidance, which may have led to species' receiving different levels of 
protection based on which agency had jurisdiction over that species, 
rather than the species' needs. For example: 

* FWS has adopted a default rule under the Endangered Species Act that 
automatically extends certain protections to species listed as 
threatened that are afforded to species listed as endangered, unless 
the agency decides otherwise. In contrast, NMFS decides whether to 
extend such protections on a case-by-case basis.[Footnote 41] As a 
result, threatened species managed by FWS automatically receive 
protections--such as requiring a permit to take the species for 
research and conservation purposes--not automatically received by 
threatened species managed by NMFS. For example, a senior NMFS 
official told us, NMFS often allows the taking of threatened species 
for these purposes without a permit. Some stakeholders said they 
believe FWS's approach leads to an "overregulation" of threatened 
species because these species may be receiving more protections than 
are biologically necessary. A senior FWS official told us the agency 
agrees with this assessment for some species and that instead of 
automatically providing threatened species with the same level of 
protection as endangered species, it plans to take the individual 
needs of each threatened species into account when determining the 
appropriate level of protection, an approach more in line with NMFS's. 

* NMFS and FWS have taken different approaches to agreements they sign 
with states to cooperatively manage species. In accordance with the 
Endangered Species Act, the agencies can sign cooperative agreements 
with states that have programs to help conserve threatened and 
endangered species.[Footnote 42] FWS's agreements generally allow 
state employees to take endangered species without a permit for 
certain conservation activities they perform in their official duties, 
such as conducting research. NMFS's state agreements, however, do not 
allow state employees to take endangered species without obtaining 
approval. According to a senior NMFS official, NMFS's approach offers 
a higher level of protection to species because each instance of take 
is reviewed and subject to approval or rejection. 

* NMFS and FWS authorize take of marine mammals differently in certain 
circumstances under the Marine Mammal Protection Act. According to FWS 
officials, the agency tends to authorize incidental take--take that is 
unintentional but expected--of marine mammals over a 5-year period for 
some activities, most notably for oil and gas drilling in the Arctic, 
whereas NMFS officials said they authorize take for similar activities 
in the Arctic annually.[Footnote 43] FWS officials told us that they 
believe authorizing these oil and gas activities over a 5-year period 
provides a more comprehensive picture of the take that may occur of 
the mammals FWS manages in the area, including polar bears and 
walruses. These officials also noted that the 5-year approach is more 
efficient. NMFS officials told us they agreed with this assessment, 
but they said that authorizing take annually also has advantages: it 
allows NMFS to conduct a more detailed analysis of the activities 
expected to affect the marine mammals it manages--primarily whales, 
dolphins, and seals--in a specific location in a given year. They said 
that this level of detail is especially important in the Arctic, where 
offshore oil and gas exploration is not limited to a single area and 
varies significantly from year to year. 

Some officials and stakeholders, however, told us that they did not 
believe that merging the agencies would substantially improve the 
agencies' implementation of the two acts. These officials and 
stakeholders noted that eliminating interagency coordination when 
evaluating the impact of a proposed project on multiple species may 
not achieve significant efficiencies. For example, agency officials 
and stakeholders explained that many projects in the Pacific Northwest 
affect multiple listed species--including salmon, bull trout, and 
spotted owls--and determining how to best minimize effects of a 
project on each of these species and their different habitats is time-
consuming regardless of whether one or two agencies is involved. 
Moreover, some agency officials said they did not believe a merger 
would make the joint management of species more effective. They said 
that having two agencies implement the Endangered Species Act provides 
certain benefits that could be lost if the agencies merged, such as 
bringing in different perspectives and avoiding "group think" when 
considering major decisions. 

Potential to Better Integrate Natural Resource Management: 

Officials and stakeholders told us that another potential benefit of 
merging NMFS into FWS could be better integrated management of natural 
resources. According to these officials and stakeholders, placing 
responsibility in a single agency for considering all species living 
in the interconnected environments from the mountains to the sea may 
be preferable to splitting responsibility for species between two 
agencies according to which habitats the species occupy. Some 
officials and stakeholders explained that a benefit of an integrated 
fish and wildlife management agency would be that it could better 
address large-scale environmental challenges, such as climate change, 
that are likely to affect many ecosystems across the country. 
Officials and stakeholders provided some examples of how management of 
natural resources could be better integrated with a merger, including 
the following: 

* Facilitating an ecosystem approach to natural resource management. 
Some agency officials and stakeholders said that a merger could help 
managers take more of an ecosystem approach and consider the impact of 
activities on the health of many species and their habitats across a 
landscape, instead of considering only those species under their 
agency's jurisdiction. Some officials cited FWS's efforts to develop 
landscape conservation cooperatives--public-private partnerships that 
promote conservation planning at a landscape scale--as one initiative 
that could be expanded to more effectively include marine and 
shoreline habitats. One senior FWS official explained that FWS staff 
struggle with including these habitats in the cooperatives because 
responsibility for many of the species found there lies with NMFS. 
Although NMFS collaborates with FWS in some of these cooperatives, 
this official said he believes it would be more efficient to manage a 
comprehensive cooperative under one agency. 

* Promoting a more holistic approach to managing ocean resources. 
Interior and FWS officials explained that bringing NMFS to Interior 
could help the government manage ocean resources more holistically. 
For example, Interior, through its Bureau of Ocean Energy Management, 
manages the exploration and development of offshore mineral resources 
but, according to a senior Interior official, does not manage many of 
the species affected by offshore oil, gas, and wind energy 
development. This official told us that having the agencies 
responsible for managing both living and mineral marine resources all 
located within Interior could help the department better mitigate the 
effects of offshore development. Similarly, some FWS officials noted, 
FWS has jurisdiction over migratory seabirds but does not manage 
marine fisheries. Yet practices some of these fisheries employ--
including longline fishing--can harm these birds. FWS works with NMFS 
and the regional fishery management councils to reduce these impacts, 
but, the officials said, having one agency responsible for protecting 
migratory birds and managing fisheries could better ensure that the 
birds' needs are considered when making management decisions for 
fisheries. 

Some officials and stakeholders told us, however, that they do not 
believe that integrating the agencies would be beneficial. Some 
stakeholders said that having NMFS responsible for living marine 
resources and Interior responsible for offshore energy development 
gives NMFS an independent voice in assessing the impacts of energy 
development on living resources. Some stakeholders said NMFS's 
location in Commerce means that if a proposed project would harm 
living marine resources, NMFS can seek to mitigate the project's 
effects, or even oppose the project, more easily than if the agency 
were part of Interior. 

Potential to Improve Habitat Conservation Programs: 

Officials and stakeholders told us that merging NMFS into FWS could 
help the agencies improve how they prioritize and coordinate their 
habitat conservation and restoration efforts, which could help ensure 
that the agencies focus their limited resources on the projects that 
provide the most benefits. NMFS and FWS habitat program officials told 
us that although the agencies coordinate their work in several forums, 
the agencies generally work independently in identifying, selecting, 
and undertaking habitat projects.[Footnote 44] Program officials said 
that by not working together in habitat types of common interest, such 
as estuaries and coastlines, the agencies have missed opportunities to 
identify potential habitat conservation and restoration projects that 
would provide more overall benefits to fish and wildlife species. 

Potential to Improve Law Enforcement Programs: 

Some officials and stakeholders also said that merging NMFS into FWS 
could improve the effectiveness of the agencies' law enforcement 
programs. Specifically, officials and stakeholders said that merging 
the agencies' law enforcement programs, which would bring a larger 
number of law enforcement officers together under a single agency, 
could make it easier to mobilize officers to conduct long-term 
investigations. They noted that some complex investigations may occupy 
one or more officers for many weeks or months and that it can be 
difficult to assign officers to such investigations if the agency has 
a small number of officers in a particular geographic area. Some 
officials and stakeholders also noted that having a larger number of 
officers under a single management structure could improve officer 
safety by making it easier to mobilize additional officers to provide 
backup when making arrests or serving warrants. 

Some other officials and stakeholders, however, questioned the extent 
to which a merger would benefit the agencies' law enforcement 
programs. These officials and stakeholders said that both agencies' 
law enforcement programs are understaffed, given their 
responsibilities, and that any additional enforcement resources a 
merger would enable the agencies to direct at certain tasks would be 
accompanied by directing fewer resources at other tasks. Some 
officials and stakeholders also noted that although the agencies' law 
enforcement programs have many similarities, they also have important 
differences, which limit the potential benefits of merging the 
programs. A major enforcement responsibility for NMFS, for example, is 
enforcing fisheries management regulations adopted under the Magnuson-
Stevens Act. Officials and stakeholders said that these regulations 
can be very complex and that it makes sense to have a number of 
officers dedicated primarily to enforcing them, rather than training 
all officers on the complexities. Similarly, FWS--in addition to 
enforcing a variety of federal laws governing the lands and resources 
in the National Wildlife Refuge System--also works to ensure visitor 
safety on national wildlife refuges. Given this variety, as well as 
the geographical isolation of many refuges, officials and stakeholders 
said that it makes sense to dedicate a number of officers primarily to 
protecting refuges. 

Potential to Realize Cost Savings: 

Cost savings were also cited as a potential benefit of a merger by 
some officials and stakeholders. Some of these officials and 
stakeholders said that likely sources for savings include 
consolidating the agencies' administrative and support functions--such 
as budgeting, finance, and human capital--and reducing mid-and high-
level management positions, such as program managers, that would 
potentially be made redundant. Nevertheless, given the lack of detail 
about exactly how the agencies would be merged, none of the officials 
we spoke with offered a concrete estimate of potential cost savings. 

Many officials and stakeholders we interviewed, however, told us they 
believed that few, if any, opportunities exist for significant cost 
savings. A major reason cited was that although NMFS and FWS have some 
similar programmatic responsibilities, the agencies' execution of 
these responsibilities overlaps little, because the agencies mostly 
work in different habitat types. Simply merging the agencies, 
therefore, would not consolidate their activities enough to actually 
reduce costs. Moreover, some officials and stakeholders told us they 
believe that the agencies are already understaffed and that no obvious 
opportunities are available to reduce staffing levels without also 
reducing their on-the-ground activities. Some stakeholders also 
cautioned that, in their experiences, both government and private-
sector proposals to consolidate organizations overestimate the 
potential long-term cost savings, which often do not materialize. For 
example, one former state wildlife agency director noted that the 
proposal for the merger of his state's fish and wildlife agencies 
projected cost savings that did not ultimately occur. 

Potential to Disrupt Fisheries Management: 

A key potential drawback of merging the agencies, some officials and 
stakeholders said, is the disruption it could cause to fisheries 
management, particularly for commercial fisheries. Officials and 
stakeholders cited a number of ways in which merging NMFS into FWS 
could potentially disrupt fisheries management, including the 
following: 

* Disrupting NMFS's work with regional fishery management councils. 
NMFS conducts numerous stock assessments and other research that 
provide key information about the size of fish stocks, among other 
topics, which the regional councils consider in determining the level 
of catch to be authorized in a fishery management plan. Some officials 
and stakeholders said that merging the agencies could interrupt NMFS's 
ability to provide the needed information. One regional fishery 
management council member said that even a 1-year disruption in 
approving fishery management plans would cause problems for the 
industry. 

* Reducing access to scientific resources needed to manage fisheries. 
NMFS's six regional science centers do much of the research and data 
collection the agency and fishery management councils use in managing 
fisheries. Officials and stakeholders noted that Interior in the 1990s 
consolidated many of its scientific capabilities into a separate 
agency, the U.S. Geological Survey. These officials expressed concern 
that if NMFS and FWS merged, Interior could decide to move NMFS's 
science centers into the Geological Survey too, which they believed 
could affect the continued availability of basic fisheries management 
data. Specifically, fisheries managers need scientific data that 
directly inform management decisions, such as stock assessments to 
establish catch levels. Officials and stakeholders were concerned that 
if NMFS's science centers were moved to the Geological Survey, the 
scientists would be in a separate organization and further removed 
from fisheries managers, which could make it more difficult for 
managers to obtain the data they need. 

* Changing decision-making responsibilities. Some officials and 
stakeholders, including some stakeholders associated with the 
commercial fishing industry, said that merging NMFS into FWS would 
shift responsibility for approving fishery management plans to the 
Secretary of the Interior rather than the Secretary of Commerce, which 
they said could change how the federal government balances 
conservation and economic factors in managing fisheries. Under the 
Magnuson-Stevens Act, fishery management plans are to "take into 
account the importance of fishery resources to fishing communities" to 
provide for the sustained participation of such communities and, to 
the extent practicable, minimize adverse economic impacts on those 
communities.[Footnote 45] The act, however, does not define what is 
meant by the phrase "take into account." Officials and stakeholders 
said they believed that Interior could emphasize conserving fish 
populations more and consider the economic effects of management 
decisions on fishing communities less than NMFS does. 

* Causing further industry disruptions. Officials from nongovernmental 
conservation organizations emphasized that the fishing industry has 
recently undergone several important changes and that merging the 
agencies now could cause further disruptions. For example, the 
Magnuson-Stevens Act was amended in 2006 to, among other things, 
require that fishery management plans establish a mechanism for 
setting annual catch limits, require regional fishery management 
councils to implement plans to end overfishing immediately, and 
authorize a type of "catch share" program that restricts access to a 
fishery.[Footnote 46] These steps are intended to both maintain 
healthy fish populations and strengthen the industry. Conservation 
stakeholders told us these steps are important to the long-term health 
of both marine ecosystems and the fishing industry but recognized that 
the changes--by reducing catch levels in some fisheries and raising 
concerns about the equity of catch allocations in others--have 
disrupted the industry in the short term. These stakeholders said that 
they expect the industry, as well as fish populations, to start 
benefiting soon from the changes and that a disruption caused by 
merging the agencies now could delay realizing those benefits. 

In contrast, some officials and stakeholders said they believed 
merging NMFS into FWS could benefit fishery management in certain 
ways, and others said they believed a merger would have little overall 
effect on fishery management. Regarding potential benefits to fishery 
management, some stakeholders said that, in balancing conservation and 
economic interests, NMFS has tended to favor economic interests, 
leading to higher catch levels, which have depleted stocks and, 
ultimately, left fewer fish available for harvest. These stakeholders 
suggested that putting greater emphasis on conserving fish 
populations, which they believed could occur if NMFS moved to 
Interior, would be a positive step. In addition, some stakeholders 
said that a merger could lead to a better balance between commercial 
and recreational fishing interests. These stakeholders said that NMFS, 
perhaps because of its position in Commerce, favors commercial over 
recreational fishing interests and that FWS has a reputation for 
working well with recreational interests. Officials and stakeholders 
who said they believed a merger would have little effect on fishery 
management pointed out that the staff currently working on fisheries 
management issues would also work on them if the agencies merged. They 
also said that because the framework for managing federal fisheries, 
including the criteria for evaluating fishery management plans, is 
established by the Magnuson-Stevens Act, transferring approval 
authority to the Secretary of the Interior would not change fishery 
management decisions. 

Potential to Sever Connections between NMFS and Other NOAA Offices: 

Another key potential drawback cited by some officials and 
stakeholders is that a merger of NMFS and FWS could sever the 
connections between NMFS and other NOAA offices. NMFS relies on a 
variety of services performed by other offices within NOAA to conduct 
its work. Alternative methods for obtaining those services could be 
developed, but moving NMFS out of NOAA might affect the efficiency or 
effectiveness of obtaining them, according to officials and 
stakeholders. Important connections between NMFS and other parts of 
NOAA highlighted by stakeholders include the following: 

* Legal services. NOAA provides legal services to NMFS and the other 
NOAA offices through its Office of General Counsel. Officials and 
stakeholders pointed to the important role played by that office in 
reviewing fishery management plans to ensure they comply with 
requirements of the Magnuson-Stevens Act and were concerned that 
moving NMFS out of NOAA could disrupt the review process. If NMFS 
merged with FWS, its legal services would be provided by Interior's 
Office of the Solicitor, which does not have experience with the 
requirements of the Magnuson-Stevens Act. Some officials noted, 
however, that some of NOAA's lawyers with fishery expertise could be 
moved to Interior if NMFS merged with FWS, in which case separating 
NMFS from NOAA's Office of General Counsel could have little effect. 

* Law enforcement. NMFS's Office of Law Enforcement also supports 
other NOAA programs, in particular, by enforcing laws and regulations 
in national marine sanctuaries, which are managed by NOAA's National 
Ocean Service. NOAA would need to find another way to provide this 
service if NMFS merged with FWS. 

* Research fleet. NOAA, through its Office of Marine and Aviation 
Operations, manages a fleet of ships and aircraft that NMFS and other 
NOAA offices use for scientific research. According to fleet 
officials, NOAA could, depending on the agreements reached as part of 
a merger, continue to provide NMFS access to these assets. The 
officials noted, however, that demand for access to NOAA's ships and 
aircraft exceeds their availability and that if NMFS were no longer 
part of NOAA, it could receive a lower priority for access. Currently, 
NMFS is a major user of the NOAA fleet, using approximately 50 percent 
of ship days. Fleet officials said that if NMFS's access to NOAA's 
fleet were reduced, NMFS might try to develop its own fleet capacity, 
which they believed could be less efficient than having a single 
fleet. Moreover, according to officials, having NMFS in NOAA makes it 
easier to identify missions where more than one NOAA office--for 
example, NMFS and the Office of Oceanic and Atmospheric Research--can 
use a ship at the same time. 

* Programmatic connections. Programmatic connections exist between 
NMFS and other offices within NOAA, in particular the National Ocean 
Service and the Office of Oceanic and Atmospheric Research. According 
to some officials and stakeholders, taking NMFS out of NOAA could make 
it harder for the programs to coordinate activities and research or to 
share information. The National Ocean Service, for example, is 
responsible for managing national marine sanctuaries. Fishing is 
allowed in most sanctuaries, although the National Ocean Service has 
restricted fishing in some sanctuaries. In such cases, the National 
Ocean Service works with NMFS and the appropriate regional fishery 
management council to set fishing restrictions, and some stakeholders 
said they believed that having both agencies located within NOAA made 
it easier to resolve issues and reach agreement. The Office of Oceanic 
and Atmospheric Research sponsors research on a variety of topics 
relevant to fishery management, such as studying the relationship 
between fisheries and ecosystems and the potential effects of climate 
change on fish populations or distribution. The office's National Sea 
Grant College Program, along with NMFS, also funds a number of 
fellowships for research on topics, such as stock assessments and 
resource economics, of direct relevance to NMFS. NMFS officials told 
us they work closely with the Office of Oceanic and Atmospheric 
Research to identify opportunities for joint research between Sea 
Grant fellows and NMFS scientists. Officials told us they were 
concerned that separating NMFS from the Office of Oceanic and 
Atmospheric Research would hinder their ability to coordinate research. 

Potential to Incur Transition Costs: 

Another potential drawback mentioned by some officials and 
stakeholders is that merging the agencies could entail substantial 
transition costs. Some of these officials and stakeholders, however, 
also said that the transition costs of a merger would be temporary and 
do not in and of themselves constitute a reason to avoid reorganizing 
the agencies. Transition costs would arise in large part because a 
merger would entail NMFS's changing a number of business and 
information technology systems, including those related to budgeting, 
finance, and human capital. These systems provide information critical 
to effective management by, for example, accurately tracking 
expenditures to ensure that funds are appropriately spent. If the 
agencies merged, NMFS would need to move from systems supported by 
NOAA or Commerce to systems supported by Interior. Since no specific 
proposal has been put forward to merge NMFS into FWS, neither 
Commerce, Interior, nor the Office of Management and Budget has 
developed detailed estimates of the cost to consolidate the agencies' 
budgeting, financial, information technology, and other business 
systems. 

Potential to Disrupt Agency Programs in the Short Term: 

Some officials and stakeholders also said that another potential 
drawback is that a major reorganization unavoidably disrupts agency 
programs in the short term. Some officials and stakeholders estimated 
that such disruptions could last for as long as 5 or 10 
years.[Footnote 47] As with those who said a merger would result in 
transition costs, however, some who cited program disruptions 
emphasized that disruptions are temporary and not necessarily a reason 
to avoid reorganizing the agencies. These officials and stakeholders 
said it is more important to take a long-term perspective and 
determine whether the overall benefits of reorganization outweigh the 
drawbacks. 

Disruptions to agency programs cited by officials and stakeholders 
include the following: 

* In the short term, employees may have less time to direct toward 
their programs while they may have to move offices, integrate into a 
new organizational structure, and learn new policies and procedures. 
In some cases, employees might gain new programmatic responsibilities, 
which would take time to learn. The stress and uncertainty often 
accompanying major reorganizations would likely also temporarily take 
employees' attention away from their programs. 

* For many of the agencies' programs, officials would need to review 
regulations, policies, procedures, and other guidance to identify and 
resolve any differences between the agencies. For example, as 
previously discussed, NMFS and FWS currently have different 
regulations implementing parts of the Endangered Species Act and 
Marine Mammal Protection Act. If the agencies merge, they may need to 
adopt a single approach. Similarly, officials said the two agencies' 
law enforcement programs currently have different protocols--for 
example, for conducting investigations or collecting and maintaining 
evidence--which would need to be reconciled. Resolving differences 
between the agencies' policies and procedures would take time away 
from running the agencies' programs, both for the staff revising the 
policies and for the staff who would need to learn the changes. 

* The differences in the two agencies' cultures and certain elements 
of their missions could make it difficult to combine the two staffs 
into a single agency. Some officials and stakeholders said that 
employees are committed to their respective agencies' missions and 
could be slow to embrace any changes, particularly if they felt that 
part of "their" mission was a lower priority in the combined agency. 
Other officials and stakeholders, however, said that some employees 
would believe that merging the agencies would benefit fish and 
wildlife and would welcome the change. Moreover, others said that 
employee resistance to change should not be a factor in determining 
whether to reorganize the agencies and that employees who did not like 
the change could always leave. 

Key Management Practices That Could Help Mitigate Program Disruptions 
and Transition Costs: 

GAO has issued numerous reports examining different aspects of 
reorganizing and improving the efficiency of government (a list of 
selected GAO products related to these topics is included at the end 
of this report). This previous work has identified a number of key 
management practices that could help mitigate program disruptions and 
transition costs inevitably accompanying reorganization (see table 1). 
Such key practices include the importance of leadership and of 
establishing a clear mission and strategic goals to guide the 
transformation. Some officials and stakeholders we interviewed 
recognized the importance of incorporating these practices if NMFS 
were merged into FWS. For example, some emphasized that strong agency 
leadership would be needed to clearly explain the rationale behind the 
merger and ease the cultural disruption accompanying reorganization. 
Strong leadership, they said, could help ensure that employees do not 
see a merger as creating "winners and losers," fostering internal 
support for the move and minimizing disruption to agency programs. 
Some officials and stakeholders said it is also important to clearly 
define the problem a reorganization is intended to address and the 
goals it is expected to achieve. 

Table 1: Key Practices Found in Successful Mergers and Organizational 
Transformations: 

Ensure top leadership drives the transformation. 
Leadership must set the direction, pace, and tone and provide a clear, 
consistent rationale that brings everyone together behind a single 
mission. 

Establish a clear mission and integrated strategic goals to guide the 
transformation. 
Together, these define the culture and serve as a vehicle for 
employees to unite and rally around. 

Focus on a key set of principles and priorities at the outset of the 
transformation. 
A clear set of principles and priorities serves as a framework to help 
the organization create a new culture and drive employee behaviors. 

Set implementation goals and a timeline to build momentum and show 
progress from day one. 
Goals and a timeline are essential because the transformation could 
take years to complete. 

Dedicate an implementation team to manage the transformation process. 
A strong and stable team is important to ensure that the 
transformation receives the needed attention to be sustained and 
successful. 

Use the performance management system to define responsibility and 
assure accountability for change. 
A "line of sight" shows how team, unit, and individual performance can 
contribute to overall organizational results. 

Establish a communication strategy to create shared expectations and 
report related progress. 
The strategy must reach out to employees, customers, and stakeholders 
and engage them in a two-way exchange. 

Involve employees to obtain their ideas and gain their ownership for 
the transformation. 
Employee involvement strengthens the process and allows them to share 
their experiences and shape policies. 

Build a world-class organization. 
Building on a vision of improved performance, the organization adopts 
the most efficient, effective, and economical personnel, system, and 
process changes and continually seeks to implement best practices. 

Source: GAO. 

[End of table] 

Officials and Stakeholders Also Identified Several Key Potential 
Benefits and Drawbacks of Alternative Organizational Options: 

Officials and stakeholders we interviewed also identified potential 
benefits and drawbacks of several alternative organizational 
structures that have previously been proposed, including moving NOAA 
into Interior, creating a new department of natural resources, and 
establishing NOAA as a stand-alone agency. Officials and stakeholders 
also identified potential benefits and drawbacks of keeping the 
current organizational structure. 

Moving NOAA into Interior Could Better Integrate Management of Land 
and Ocean Resources but Might Diminish Attention to Ocean Issues: 

Officials and stakeholders said that although merging NMFS into FWS 
would be a good first step toward better integrating natural resource 
management and addressing large-scale environmental challenges, moving 
all of NOAA into Interior could better achieve this integration by 
bringing even more aspects of federal land and ocean management under 
the same department. Specifically, officials and stakeholders 
identified the following potential benefits of improved integration: 

* Addressing land-freshwater-ocean issues more effectively. Some 
agency officials and stakeholders said moving NOAA to Interior could 
allow the federal government to more effectively address issues such 
as "dead zones" in the Gulf of Mexico;[Footnote 48] impacts of 
offshore energy development; climate change; and other challenges that 
span land, fresh water, and oceans because NOAA's other ocean-
management-related offices, including the National Ocean Service and 
the Office of Oceanic and Atmospheric Research, would be included in 
such a move. For example, FWS officials told us they believe the 
government could restore fish and wildlife habitat more effectively 
and efficiently after offshore oil spills if Interior also included 
the National Ocean Service. This NOAA office plays a significant role, 
along with FWS, in habitat restoration efforts after such events. 

* Better management coordination. Some agency officials told us that 
another potential benefit of having the National Ocean Service in 
Interior is that the agencies could better coordinate the management 
of marine refuges, monuments, and sanctuaries with management of 
national wildlife refuges, managed by FWS, and national parks, managed 
by the National Park Service. The National Ocean Service manages 13 
national marine sanctuaries and, in conjunction with FWS, NMFS, and 
the state of Hawaii, 1 marine national monument. National marine 
sanctuaries and monuments have some characteristics similar to those 
of national wildlife refuges and national parks. For example, certain 
types of disturbance or development--such as disturbing or altering 
the seabed and developing oil, gas, and mineral resources--are 
prohibited or regulated in some national marine sanctuaries. 

* Combining earth-ocean research and data collection. Some agency 
officials and stakeholders said it could be beneficial to combine the 
earth and ocean scientific research currently found in Interior and 
NOAA under one department. One former agency administrator said it 
could be beneficial to bring together NOAA and Interior scientists, 
especially those in NOAA's Office of Oceanic and Atmospheric Research 
and National Weather Service and Interior's U.S. Geological Survey, to 
tackle ecological challenges concerning terrestrial, freshwater, and 
marine natural resource management. Other officials pointed out that 
the agencies both generate and analyze similar types of data, 
including (1) location-based data used, for example, to create 
topographic maps and assess coastal health and (2) seismic data used, 
for example, in planning responses to earthquakes.[Footnote 49] These 
officials said it could be beneficial to further integrate these 
efforts. 

In addition to improved integration of natural resource management, 
officials and stakeholders noted other potential benefits of moving 
NOAA into Interior. Some said they believed that moving all of NOAA to 
Interior would maintain the key connections between NMFS and the rest 
of NOAA's offices. Officials and stakeholders also pointed to the 
similarities that NOAA, as a resource management and science agency, 
has with Interior, which shares similar missions. A senior Interior 
official noted that Secretaries of the Interior are often fully 
engaged with science and natural resource management issues, which is 
generally not the case for Secretaries of Commerce, given that the 
bulk of Commerce's work consists of business-and trade-related 
activities. Recognizing this dynamic, some stakeholders said moving 
NOAA out of Commerce could benefit Commerce, since it would allow the 
department to focus on its trade and competitiveness mission. 

Officials and stakeholders told us that moving NOAA into Interior 
posed a number of potential drawbacks as well, some of which are 
similar to the drawbacks of merging NMFS into FWS. Some stakeholders, 
for example, suggested that moving NOAA to Interior could diminish the 
attention directed to NOAA's mission of protecting living marine 
resources and managing marine fisheries. They said that if NOAA were 
in Interior, it would be competing with Interior's other agencies for 
budgetary resources, which could lead to less funding for the 
protection of living marine resources and fisheries, particularly 
since such protection can conflict with some of Interior's offshore 
oil, gas, and wind energy development missions. Some stakeholders 
explained that because NOAA is dissimilar to the rest of Commerce, it 
does not compete directly with other agencies for funding, as it might 
if it were part of Interior. In addition, some officials and 
stakeholders questioned whether portions of NOAA, especially NOAA's 
satellite program and the National Weather Service, would fit within 
Interior's mission. 

Creating a Department of Natural Resources Could Further Integrate 
Land and Ocean Resource Management but Could Be a Substantial 
Implementation Challenge: 

Some officials and stakeholders told us that if the goal is to fully 
integrate land and ocean resource management, creating an overall 
department of natural resources could be the best way to do it. These 
officials and stakeholders proposed that such a department could 
include agencies such as the Forest Service, Environmental Protection 
Agency, and the Army Corps of Engineers' civil works 
programs,[Footnote 50] in addition to agencies within Interior and 
NOAA, although opinions differed as to the department's exact makeup. 
Officials and stakeholders said that the benefits of creating a 
department of natural resources include consolidating science 
functions from across the government and shifting toward managing 
natural resources on a large scale. Some officials and stakeholders 
said creating a department of natural resources could be the best way 
to achieve significant budgetary and management efficiencies. For 
example, one former Interior secretary said a large-scale 
reorganization is needed to truly reduce the cost to the federal 
government of natural resource management. A senior Interior official 
noted that it takes a long time to negotiate interagency memorandums 
of agreement and to process decisions through agency bureaucracies; 
one department overseeing natural resource decisions would eliminate 
the need for such coordination. One former Commerce secretary told us 
the efficiencies achieved by such a reorganization could also improve 
the public's perception of government overall. 

Nevertheless, some officials and stakeholders said a significant 
potential drawback of creating a department of natural resources is 
that it could be a substantial implementation challenge, given the 
number and size of distinct organizational entities that would have to 
be transformed. Some stakeholders mentioned the creation of the 
Department of Homeland Security as an example of the difficulties 
inherent in large transformations, including the length of time 
necessary to complete them. In our 2011 report on this department, we 
found that, 8 years after its creation, it had implemented key 
homeland security operations and achieved important goals, but the 
department's transformation remained high risk because of continuing 
management challenges.[Footnote 51] Some stakeholders also noted that 
the sheer size of a department of natural resources, with its multiple 
missions, could make it difficult to manage. 

Establishing NOAA as a Stand-alone Agency Could Raise the Profile of 
Ocean Resources, According to Some, but Could Marginalize the Agency 
According to Others: 

Officials and stakeholders we interviewed generally disagreed on the 
potential effects of establishing NOAA as a stand-alone agency 
independent from Commerce and other departments. Some stakeholders 
suggested that such a move could lead to more attention for ocean 
issues, which, over time, could lead to more funding for addressing 
ocean management challenges. One former NOAA administrator said that a 
stand-alone NOAA could provide a strong, independent voice for ocean-
related issues as the country grapples with emerging challenges, such 
as managing deep-sea mining and increasing offshore energy 
development. A member of NOAA's advisory committee for living marine 
resources noted that establishing NOAA as an independent agency could 
send a message that oceans are a national priority. Others said 
establishing NOAA as a stand-alone agency could help direct attention 
to ocean-based policy, including the National Ocean Policy, and such 
an agency could be in the best position to execute this policy. 
[Footnote 52] Some stakeholders said it would be very important for 
the new agency to be included in the President's cabinet, since doing 
so could provide greater access to high-level budget and policy 
decision making than if NOAA were made an independent, non-cabinet-
level agency. Other stakeholders also noted that this option may be 
less disruptive than others and that it could confer the same benefits 
to Commerce as moving NOAA to Interior by allowing Commerce to focus 
exclusively on its trade and competitiveness mission. 

Some other officials and stakeholders, however, told us they believed 
that making NOAA an independent agency would not yield these benefits, 
and some said it could be harmful to the agency's mission. For 
example, some stakeholders expressed concern that NOAA's small size 
relative to other agencies could limit its ability to obtain 
sufficient support, as well as sufficient funding, both within the 
administration and in Congress. For example, one NMFS official 
described NOAA's budget as "decimal dust" when compared with the other 
agencies it would be competing with for funds, making it susceptible 
to budget cuts and weakening its ability to advocate for ocean 
resources and policy. Some officials and stakeholders said these 
negative effects would be particularly likely to occur if the new 
agency did not have a cabinet-level secretary, but others said it 
could be difficult for NOAA to compete with other agencies and 
interests even as a cabinet-level agency. In addition, some 
stakeholders said that Commerce provides certain important services to 
NOAA, which they would not want to see lost. For example, one fishing 
industry organization representative said she is concerned that moving 
NOAA out of Commerce could hurt parts of the industry, pointing out 
that most of what her sector catches is exported, and the industry has 
benefited from Commerce's trade policies. Further, some officials and 
stakeholders said making NOAA an independent agency would add to the 
stovepiping of government that the other reorganization options are 
trying to counter by integrating agencies. Some of the former agency 
directors and department secretaries we interviewed said that making 
NOAA an independent agency would not contribute to streamlining the 
government. Two former department secretaries said increasing the 
number of executive agencies makes it more difficult for the President 
to manage actions of the executive branch as a whole and to hold all 
the agencies accountable. Moreover, some officials and stakeholders 
noted that making NOAA an independent agency would not yield some of 
the key potential benefits that could come with the other 
reorganization options, such as having a single agency manage similar 
programmatic responsibilities. 

Maintaining the Current Organizational Structure Would Avert 
Disruptions but Not Better Integrate Resource Management; Interagency 
Collaboration Could Help the Agencies Work Together More Effectively: 

Agency officials and stakeholders also identified potential benefits 
and drawbacks of maintaining the current organizational structure. 
They cited benefits such as averting the disruption to programs that 
could accompany a reorganization and the uncertainty of whether a 
reorganization would achieve its goals. Some stakeholders noted, 
however, that keeping the current structure would also mean missing an 
opportunity to better integrate natural resource management. Overall, 
officials and stakeholders generally said the drawbacks of 
reorganizing the agencies outweigh the benefits. As a few put it, "The 
juice is not worth the squeeze." In contrast to this general view, 
however, of the 10 former heads of Commerce, Interior, NOAA, NMFS, and 
FWS we spoke with, 9 of them told us they preferred making some kind 
of organizational change, although there was no consensus on what the 
best structure would be. 

Some officials and stakeholders suggested that if the current 
organizational structure is retained, the agencies can still take 
steps to collaborate more effectively. At the program level, officials 
and stakeholders said efficiencies in the agencies' Endangered Species 
Act and Marine Mammal Protection Act programs can be realized without 
a merger. For example, some officials and stakeholders said that the 
agencies could expand their existing efforts to issue joint 
regulations and policies to ensure that the agencies implement the act 
in a similar manner. Other officials and stakeholders said that 
colocating field offices and staff for the agencies' endangered 
species programs could foster interagency collaboration and make it 
easier for the public to work with both agencies. The agencies have 
already colocated at least three of their field offices, one in 
California, one in Maine, and one in the state of Washington, where 
NMFS and FWS staff occupy the same building. According to agency 
officials familiar with these colocated offices, the close proximity 
fosters more conversations and face-to-face contact, which in turn 
builds relationships and trust. The close relationships have led 
agency officials to find other efficiencies as well; for example, FWS 
has placed a staff member in NMFS's Northwest regional office, and 
that person works on Endangered Species Act reviews on behalf of both 
agencies. In addition, FWS and NMFS regional officials noted that, in 
their view, the agencies collaborate better in states with colocated 
offices than in states where personnel are not as closely located. 

We reported in 2012 that a number of interagency collaboration 
mechanisms, including office colocation, are being used by a variety 
of federal agencies.[Footnote 53] For example, the Bureau of Land 
Management and the Forest Service have established more than 30 
offices under Service First agreements, where the agencies are 
colocated, combined, or commingled and where they share resources--
including staff, office space, and other materials--to varying 
extents. FWS also participates in six such colocated offices under 
Service First agreements with the Bureau of Land Management, the 
Forest Service, or both. As we reported, certain key features can help 
colocation and other collaborative efforts be effective, such as 
clarity of roles and responsibilities (see table 2). 

Table 2: Key Features of Interagency Collaborations and Issues to 
Consider When Collaborating: 

Key feature: Outcomes and accountability; 
Issues to consider: Have short-term and long-term outcomes been 
clearly defined? Is there a way to track and monitor their progress? 

Key feature: Bridging organizational cultures; 
Issues to consider: What are the missions and organizational cultures 
of the participating agencies? Have agencies agreed on common 
terminology and definitions? 

Key feature: Leadership; 
Issues to consider: How will leadership be sustained over the long 
term? If leadership is shared, have roles and responsibilities been 
clearly identified and agreed upon? 

Key feature: Clarity of roles and responsibilities; 
Issues to consider: Have participating agencies clarified roles and 
responsibilities? 

Key feature: Participants; 
Issues to consider: Have all relevant participants been included? Do 
they have the ability to commit resources for their agency? 

Key feature: Resources; 
Issues to consider: How will the collaborative mechanism be funded and 
staffed? Have online collaboration tools been developed? 

Key feature: Written guidance and agreements; 
Issues to consider: If appropriate, have participating agencies 
documented their agreement regarding how they will be collaborating? 
Have they developed ways to continually update and monitor these 
agreements? 

Source: GAO. 

[End of table] 

Agency Comments: 

We provided a draft of this report for review and comment to the 
Departments of Commerce and the Interior. Commerce provided technical 
comments that were incorporated, as appropriate. Interior did not 
provide comments. 

We are sending copies of this report to the Administrator and 
Assistant Administrator for Fisheries of NOAA, the Director of FWS, 
the appropriate congressional committees, and other interested 
parties. In addition, this report is available at no charge on the GAO 
website at [hyperlink, http://www.gao.gov]. 

If you have 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 II. 

Signed by: 

Anne-Marie Fennell: 
Director: 
Natural Resources and Environment: 

[End of section] 

Appendix I: Former Agency Officials and Stakeholders GAO Interviewed: 

We interviewed Secretaries of Commerce and the Interior and heads of 
the National Oceanic and Atmospheric Administration (NOAA), the 
National Marine Fisheries Service (NMFS), and the Fish and Wildlife 
Service (FWS) from each of the two previous administrations: 

Bruce E. Babbitt: 
Secretary: 
Department of the Interior, 1993-2001: 

D. James Baker: 
Administrator: 
NOAA, 1993-2001: 

William M. Daley: 
Secretary: 
Department of Commerce, 1997-2000: 

Carlos M. Gutierrez: 
Secretary: 
Department of Commerce, 2005-2009: 

H. Dale Hall: 
Director: 
FWS, 2005-2009: 

William T. Hogarth: 
Assistant Administrator for Fisheries: 
NMFS, 2000-2007: 

Conrad C. Lautenbacher, Jr.
Administrator: 
NOAA, 2001-2008: 

Gale A. Norton: 
Secretary: 
Department of the Interior, 2001-2006: 

Jamie Rappaport Clark: 
Director: 
FWS, 1997-2001: 

Rolland A. Schmitten: 
Assistant Administrator for Fisheries: 
NMFS, 1993-1999: 

We also interviewed officials from the following agencies and 
organizations: 

American Forest Resource Council: 

Association of Fish and Wildlife Agencies: 

Atlantic Coastal Fish Habitat Partnership: 

Atlantic States Marine Fisheries Commission: 

At-Sea Processors Association: 

Center for American Progress: 

Center for Biological Diversity: 

Coastal States Organization: 

Conservation International: 

Defenders of Wildlife: 

East Coast Shellfish Growers Association: 

Endangered Species Act Joint Task Force: 

Environmental Defense Fund: 

Federal Law Enforcement Officers Association: 

Groundfish Forum: 

Gulf of Mexico Fishery Management Council: 

Gulf States Marine Fisheries Commission: 

Joint Ocean Commission Initiative: 

Marine Fisheries Advisory Committee: 

Marine Mammal Commission: 

Massachusetts Department of Fish and Game: 

Massachusetts Fishermen's Partnership: 

Massachusetts Office of Coastal Zone Management: 

National Endangered Species Act Reform Coalition: 

Natural Resources Defense Council: 

Nature Conservancy: 

New England Fishery Management Council: 

Northeast Consortium: 

North Pacific Fishery Management Council: 

Northwest Indian Fisheries Commission: 

Oceana: 

Ocean Conservancy: 

Pacific Fishery Management Council: 

Pacific Marine and Estuarine Fish Habitat Partnership: 

Pacific States Marine Fisheries Commission: 

Puget Sound Partnership: 

Restore America's Estuaries: 

Southern Shrimp Alliance: 

Taylor Shellfish Farms: 

U.S. Army Corps of Engineers: 

U.S. Geological Survey, Western Fisheries Research Center: 

U.S. Institute for Environmental Conflict Resolution: 

Washington Department of Fish and Wildlife: 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

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

Staff Acknowledgments: 

In addition to the individual named above, Stephen D. Secrist, 
Assistant Director; Eric Bachhuber; Antoinette Capaccio; Ellen W. Chu; 
Jonathan Dent; Anu Mittal; Leslie Pollock; and Anne Rhodes-Kline made 
key contributions to this report. Also contributing to this report 
were Elizabeth Curda and Armetha Liles. 

[End of section] 

Related GAO Products: 

Managing for Results: Key Considerations for Implementing Interagency 
Collaborative Mechanisms. [hyperlink, 
http://www.gao.gov/products/GAO-12-1022]. Washington, D.C.: 

September 27, 2012. 

Government Efficiency and Effectiveness: Opportunities for Improvement 
and Considerations for Restructuring. [hyperlink, 
http://www.gao.gov/products/GAO-12-454T]. Washington, D.C.: March 21, 
2012. 

Streamlining Government: Key Practices from Select Efficiency 
Initiatives Should Be Shared Governmentwide. [hyperlink, 
http://www.gao.gov/products/GAO-11-908]. Washington, D.C.: September 
30, 2011. 

Department of Homeland Security: Progress Made and Work Remaining in 
Implementing Homeland Security Missions 10 Years after 9/11. 
[hyperlink, http://www.gao.gov/products/GAO-11-940T]. Washington D.C.: 
September 8, 2011. 

Federal Land Management: Observations on a Possible Move of the Forest 
Service into the Department of the Interior. [hyperlink, 
http://www.gao.gov/products/GAO-09-223]. Washington, D.C.: February 
11, 2009. 

Results-Oriented Government: Practices That Can Help Enhance and 
Sustain Collaboration among Federal Agencies. [hyperlink, 
http://www.gao.gov/products/GAO-06-15]. Washington, D.C.: October 21, 
2005. 

Results-Oriented Cultures: Implementation Steps to Assist Mergers and 
Organizational Transformations. [hyperlink, 
http://www.gao.gov/products/GAO-03-669]. Washington, D.C.: July 2, 
2003. 

Executive Reorganization Authority: Balancing Executive and 
Congressional Roles in Shaping the Federal Government's Structure. 
[hyperlink, http://www.gao.gov/products/GAO-03-624T]. Washington, 
D.C.: April 3, 2003. 

Highlights of a GAO Forum: Mergers and Transformations: Lessons 
Learned for a Department of Homeland Security and Other Federal 
Agencies. [hyperlink, http://www.gao.gov/products/GAO-03-293SP]. 
Washington, D.C.: November 14, 2002. 

Homeland Security: Critical Design and Implementation Issues. 
[hyperlink, http://www.gao.gov/products/GAO-02-957T]. Washington, 
D.C.: July 17, 2002. 

[End of section] 

Footnotes: 

[1] FWS's field stations, called ecological services field offices, 
generally work on activities involving endangered species, migratory 
birds, and habitat conservation. 

[2] Reorganization Plan No. 2 of 1939, 3 C.F.R. 254 1939, reprinted in 
5 U.S.C. app. at 73 (2006) and in 53 Stat. 1423 (1939). 

[3] Reorganization Plan No. 3 of 1940, 3 C.F.R. 1298 (1940), reprinted 
in 5 U.S.C. 1441 (2006) and in 54 Stat. 1231 (1940). 

[4] Reorganization Plan No. 4 of 1970, 3 C.F.R. (1970), reprinted in 5 
U.S.C. app. at 1557 (2006) and in 84 Stat. 2090 (1970). 

[5] Ocean and Coastal Management Improvement Act of 1993, H.R. 2761, 
103rd Cong. (1993). 

[6] Department of Commerce Dismantling Act, H.R. 1756, 104th Cong. 
(1995). 

[7] Weather and Oceans Resources Realignment Act, H.R. 4368, 108th 
Cong. (2004). 

[8] Office of Management and Budget, President's Reorganization 
Project: Report on Reorganization Study of Natural Resource Functions 
(Washington, D.C.: June 1979). 

[9] National Oceanic and Atmospheric Administration Organic Act, H.R. 
3381, 98th Cong. (1983). 

[10] Pew Oceans Commission, America's Living Oceans: Charting a Course 
for Sea Change (Arlington, VA: May 2003). 

[11] Endangered Species Consolidation Act, H.R. 4335, 105th Cong. 
(1998). 

[12] American Fisheries Society, "Summary Report and Recommendations 
on Federal Fisheries Responsibilities," Fisheries, vol. 11, no. 4, 
July-August 1986. 

[13] U.S. Commission on Ocean Policy, An Ocean Blueprint for the 21st 
Century (Washington, D.C.: 2004). 

[14] National Oceanic and Atmospheric Administration Organic Act, H.R. 
4607, 108th Cong. (2004). 

[15] GAO, Federal Land Management: Observations on a Possible Move of 
the Forest Service into the Department of the Interior, [hyperlink, 
http://www.gao.gov/products/GAO-09-223] (Washington, D.C.: Feb. 11, 
2009). 

[16] GAO, Government Efficiency and Effectiveness: Opportunities for 
Improvement and Considerations for Restructuring, [hyperlink, 
http://www.gao.gov/products/GAO-12-454T] (Washington, D.C.: Mar. 21, 
2012), and GAO, Streamlining Government: Questions to Consider When 
Evaluating Proposals to Consolidate Physical Infrastructure and 
Management Functions, [hyperlink, 
http://www.gao.gov/products/GAO-12-542] (Washington, D.C.: May 23, 
2012). 

[17] Authority for managing species under the Endangered Species Act 
has been delegated by the Secretary of the Interior to the Director of 
FWS and by the Secretary of Commerce to NMFS's Assistant Administrator 
for Fisheries. 

[18] As of December 2012, FWS manages 1,964 plant and animal species 
under the Endangered Species Act and 8 species under the Marine Mammal 
Protection Act. NMFS is responsible for 88 species under the 
Endangered Species Act and approximately 117 species under the Marine 
Mammal Protection Act. 

[19] In the 1974 memorandum of understanding, NMFS and FWS agreed that 
they would share jurisdiction for those species that did not clearly 
fit under the jurisdiction of one agency or the other. They agreed to 
make these determinations on a case-by-case basis. 

[20] Under the Endangered Species Act, NMFS and FWS must generally 
designate critical habitat for any species listed as endangered or 
threatened. Critical habitat includes (1) specific areas occupied by 
species protected under the act on which are found physical or 
biological features essential to the conservation of the species and 
that may require special management considerations or protection and 
(2) specific areas that may not be occupied by the species at the time 
it is listed under the act but that are essential for conserving the 
species. 

[21] Endangered and Threatened Wildlife and Plants; Revisions to the 
Regulations for Impact Analyses of Critical Habitat, 77 Fed. Reg. 
51,503 (Aug. 24, 2012). 

[22] The act states that a species is endangered if it is in danger of 
extinction throughout all or a significant portion of its range; it 
also states that a threatened species is one that is likely to become 
endangered in the foreseeable future throughout all or a significant 
portion of its range. 

[23] Draft Policy on Interpretation of the Phrase "Significant Portion 
of Its Range" in the Endangered Species Act's Definitions of 
"Endangered Species" and "Threatened Species," 76 Fed. Reg. 76,987 
(Dec. 9, 2011). 

[24] In addition to NMFS, NOAA's National Ocean Service and Office of 
General Counsel are also involved in assessing and seeking 
compensation for damages to natural resources. These resources include 
land, waters, and species within the agencies' respective 
jurisdictions. 

[25] Comprehensive Environmental Response, Compensation, and Liability 
Act, 42 U.S.C. §§ 9601-9675 (2006); Clean Water Act, 33 U.S.C. §§ 1251-
1387; and Oil Pollution Act, 33 U.S.C. §§ 2701-2761 (2006). 

[26] 16 U.S.C. §§ 791-830 (2006). 

[27] 16 U.S.C. §§ 1802(10) and 1855(b) (2006); 50 C.F.R. § 600.920 
(2012). 

[28] NMFS and FWS officials estimated the amount their respective 
agency spent on scientific research because research is not designated 
as a separate budgetary line item. FWS's estimate includes 
approximately $15 million FWS used to acquire scientific information 
from the U.S. Geological Survey, a separate agency within Interior 
that also conducts science that supports FWS management. 

[29] Under the Clean Water Act, the Environmental Protection Agency 
may authorize states to issue permits under the act; thus, aquaculture 
operations may need to obtain these permits from state agencies. 

[30] Federal waters generally extend from 3 to 200 nautical miles 
offshore, an area known as the Exclusive Economic Zone. 

[31] In recent years, NMFS has provided approximately $16 million 
annually under the Mitchell Act (16 U.S.C. §§ 755-757 (2006)) to fund 
hatcheries and other projects, such as irrigation diversion screens, 
to partially compensate for fish and habitat losses caused by 
construction of federal dams on the Columbia River. In fiscal year 
2012, more than $3 million of these funds supported FWS hatchery 
programs. 

[32] According to NMFS, the agency works with FWS to develop the U.S. 
position on species protected under the convention for which NMFS has 
management responsibilities. 

[33] The Magnuson-Stevens Act defines fishery as "one or more stocks 
of fish which can be treated as a unit for purposes of conservation 
and management and which are identified on the basis of geographical, 
scientific, technical, recreational, and economic characteristics and 
any fishing for such stocks." 

[34] 16 U.S.C. §§ 703-719c (2006). 

[35] 16 U.S.C. §§ 2901-2912 (2006), 16 U.S.C. §§ 668-668d (2006), and 
16 U.S.C. §§ 6101-6109 (2006). 

[36] Exec. Order No. 13,186, 66 Fed. Reg. 3,853 (Jan. 17, 2001). 

[37] NMFS does not have oversight responsibility for ensuring the 
safety of domestic or imported seafood. This responsibility lies with 
the Food and Drug Administration. 

[38] GAO, Endangered Sea Turtles: Better Coordination, Data 
Collection, and Planning Could Improve Federal Protection and Recovery 
Efforts, [hyperlink, http://www.gao.gov/products/GAO-12-242] 
(Washington, D.C.: Jan. 31, 2012). 

[39] The Endangered Species Act generally prohibits the "take" of 
endangered species, where take is defined as "to harass, harm, pursue, 
hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to 
engage in any such conduct." 16 U.S.C. § 1532(19) (2006). 

[40] The Endangered Species Act requires federal agencies to consult 
with FWS, NMFS, or both agencies when their actions may affect listed 
species or critical habitat. 

[41] The Endangered Species Act allows the agencies to extend some 
required protections for endangered species to threatened species. 

[42] Under section 6 of the Endangered Species Act, FWS and NMFS are 
authorized to enter into cooperative agreements with states that 
establish and maintain an "adequate and active" program for the 
conservation of endangered and threatened species. 

[43] Under the act, agency officials may, at the request of citizens 
seeking to engage in an activity that may result in the incidental 
take of a marine mammal, issue one of two types of authorization for 
take that meets certain criteria: (1) a 5-year authorization for any 
type of incidental take if the take meets certain criteria or (2) a 1-
year authorization limited to incidental harassment. 

[44] Forums where NMFS and FWS work together to conserve and restore 
habitat include the National Fish Habitat Partnership and the Estuary 
Habitat Restoration Council. 

[45] 16 U.S.C. § 1851(a)(8) (2006). 

[46] According to NMFS, "catch share" is a general term for several 
fishery management strategies that allocate a specific portion of the 
total allowable catch to individuals, cooperatives, communities, or 
other entities. By allocating allowable fish catch ahead of time, 
catch shares are intended to provide social and economic benefits to 
the industry, for example, by improving safety, since captains would 
feel less compelled to fish during dangerous weather; increasing the 
value of the catch, by reducing the likelihood that a large supply of 
fish will hit the market at one time; and reducing costs, by reducing 
the incentive to overinvest in new equipment, since captains would not 
be competing in a "race for fish," where they feel they need the best 
equipment to gain advantage over other captains. 

[47] Previous GAO work has noted that the experiences of successful 
major change management initiatives in large private-and public-sector 
organizations suggest it can often take at least 5 to 7 years until 
such initiatives are fully implemented, and the related cultures are 
transformed in a sustainable manner. See GAO, Highlights of a GAO 
Forum: Mergers and Transformations: Lessons Learned for a Department 
of Homeland Security and Other Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-03-293SP] (Washington, D.C.: Nov. 14, 
2002). 

[48] Areas in the ocean where the water has low levels of oxygen 
dissolved in it are referred to as "dead zones" because most marine 
life either dies or leaves the area. According to NOAA, the dead zone 
in the Gulf of Mexico in 2012 was about the size of the state of 
Delaware. 

[49] Location-based, or geospatial, data refers to information linked 
to specific geographic locations. 

[50] An agency within the Department of Defense, the Army Corps of 
Engineers provides a variety of engineering services through military 
and civil works programs. The civil works program is responsible for 
investigating, developing, and maintaining water resource projects. 

[51] GAO, Department of Homeland Security: Progress Made and Work 
Remaining in Implementing Homeland Security Missions 10 Years after 
9/11, [hyperlink, http://www.gao.gov/products/GAO-11-881] (Washington, 
D.C.: Sept. 7, 2011). 

[52] In 2010, the President established a national policy to "ensure 
the protection, maintenance, and restoration of the health of ocean, 
coastal, and Great Lakes ecosystems and resources, enhance the 
sustainability of ocean and coastal economies, preserve our maritime 
heritage, support sustainable uses and access, provide for adaptive 
management to enhance our understanding of and capacity to respond to 
climate change and ocean acidification, and coordinate with our 
national security and foreign policy interests." The president also 
established a National Ocean Council to implement this policy. 

[53] GAO, Managing for Results: Key Considerations for Implementing 
Interagency Collaborative Mechanisms, [hyperlink, 
http://www.gao.gov/products/GAO-12-1022] (Washington, D.C.: Sept. 27, 
2012). 

[End of section] 

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