January 8, 2017

To: Jim Scott, WDFW
Ron Warren, WDFW
Gentlemen-

The Twin Harbors Fish & Wildlife Advocacy offers the following comments for your consideration as the two of you develop a briefing document on options for the Columbia River Policy C-3620 for presentation to the Commission at its upcoming meeting in Vancouver. We start with our impression of fish management policy in the state and end with some economic factor considerations.

The primary philosophies of fisheries management in Washington State as understood by the Advocacy are inserted in the questions that are shown below. Our answers to each follow in italics.

1. Do the options being presented the Commission prioritize conservation over harvest? No. To the contrary, the options would present risk to steelhead, sturgeon and other species of bycatch.

2. Do the options focus harvest on hatchery stocks and encourage selective fishing methods? No. The gear being proposed includes non-selective gillnets and the targeted run is natural spawning Chinook. Additionally, continued use of non-selective gear will discourage the commercial fleet from development of selective fishing gears in the Columbia and elsewhere. The message that would be delivered to the fleet is a failure or refusal to develop selective gears will result in the Department "adapting" back to the non-selective commercial fishing of the past. Those willing or able to invest in alternative gears will have to compete and divide the fish with those who won't adapt. A disincentive for the fleet to develop selective fishing alternatives will result.

3. Do the options reflect adaptive management? Yes and No. Yes, if one defines adaptive management to mean the Department has a duty to regularly modify long term conservation efforts as a means to guarantee today's commercial gillnetters receive a certain level of profitability. No, if one realizes the commercial fleet itself has a responsibility to adapt to the ever-changing world of fishing economics. The Department and the public should not be expected to manage the state's natural resources in a manner that assures a certain level of guaranteed profit to any commercial entity. Adaptive management for fish and wildlife resources should not be defined as a means to justify delivery of an entitlement of the public's resource to a small number of historical gillnet license holders.

4. Is adoption of an option by the Commission needed to fulfill the goal of achieving an economically viable fishing industry? No. Three citizens group comprise the harvesters within the state's industry (Tribal commercials, Non-treaty commercials, and recreational). The goal for a commercial sector is met by the tribal commercial fleets on their own. Additionally, while important to the gillnetter, the value of the fisheries delivered under the options for the Columbia gillnet license holders is insignificant compared to the fishing industry of the state.

5. Do the options fairly balance harvest between geographical areas? No. The relocation of gillnets from the lower reaches of the Columbia further upstream is intended to target a natural spawning fisheries utilized by the inland community. Historically, the inland community has not been provided the fishing opportunities granted to the gillnetters and others who fish the lower reaches. The proposals redirects the commercial harvest from lower reach stocks on to the opportunities that are slowly opening for those further inland.

Regarding the economic analysis to be presented to the Commission this weekend, the Advocacy does not believe adoption of one of the options will help assure the future of commercial fishing in the Columbia. The future of commercial fishing is reliant upon the gillnet license holders developing alternative gear and adopting selective fishing practices. While the Department can assisted in a cooperative fashion, WDFW staff can not develop new gears or evolve the fleet. The responsibility to adapt to changing times rests on the shoulders of the gillnetters themselves. While helpful to those "grey-haired" license holders who want to hang on for a couple more profitable years, the same number of boats will likely remain in the water. Fewer fish per boat equates to less profit available for those who would be willing to invest in alternative selective gears. Combined with an appearance that the Commission may not have a true committment to selective fishing, the adaption of the fleet towards alternative selective gears will likely be delayed, if not delivered a near fatal blow.
While recognizing the gillnet license holders wish to defend and maintain their historical income streams, the business model of many commercial gillnetters is often described as a part time en-devour or "a way of life". The limited profits from Columbia gillnetting is likely ancillary to other employment, retirement income, or another commercial use of the boat. Due to the shortness of seasons, few full time employee positions are likely reliant upon a WDFW commercial gillnet season in the Columbia.

While considered significant by the individual gillnetters, the investments required to purchase a boat, nets, and license is well below the norm for a typical small business. As an example, a single dispenser on a gas island at a local convenience store can exceed the investment in a boat and the hoses and nozzles sticking out of one of them can exceed the costs of nets.

As for the economic contribution to the state, compare the low level of license fees and taxes collected from a gillnet license holder with a "mom & pop" moderate size convenience store with 4 pumps and a deli inside. The annual fuel and sales taxes collected by the retailer for the state is approximately $711,120. The tax collection costs to the merchant (credit card processing fees) is $16,101. State licenses run $2,640. Business and Occupation tax charged the merchant comes in at $22,320. Total annual contribution costs out of pocket for the retailer is $41,061. If government staff gets involved to provide support (call that on-board observers), the merchant is billed at a rate of $200-225 per hour. It is important to note that the dealer does not receive a single piece of merchandise from the state. Unlike a commercial gillnet license holder who is supplied free fish, the retailers have to purchase all the products they sell.

We end with the following history lesson on economic reality. At the time of the Boldt Decision, hundreds of small cedar mills produced singles and shakes out of old growth cedar salvage. Often operated along side garages or barns as an ancillary income, the mill operators were reliant upon relatively cheap raw materials. Then, like the commercial gillnetter of today who faces competition from ocean ranching and imports from Chile or elsewhere, asphalt, tin, tile, and other roofing products grew in popularity and undercut the price of cedar products. The number of operations declined. Finally, the old growth were nearly exhausted and it was over for those who were unwilling or unable to invest in upgrading operations to handle second growth logs.

Did the state try to keep clear cutting the remaining publicly owned old growth forests as a means to prop up the "way of life" for the cedar mill operators? Did it offer to buy them out of their obsolete saw mill equipment? Was the public denied access to roofing as a result of the failure of the state to provide subsidies to the cedar shake and shingle producers?

The future of commercial harvest in the Columbia rests solidly on the shoulders of the current license holders. Rather than dis-encourage, the state should encourage those who are willing to adapt and invest for the future. While well intended, the options proposed delay the inevitable and at the same time, create a disincentive for the fleet to economically adapt to changing times.

Respectfully,

Tim Hamilton
Twin Harbors Fish & Wildlife Advocacy

cc: Fish & Wildlife Commission