FY 2002 Innovative proposal 34031

Section 1. Administrative

Project location

Reasonable and Prudent Alternatives (RPAs)

Section 2. Past accomplishments

Section 3. Relationships to other projects

Section 4. Budget for Planning and Design phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Planning and Design phase

Section 5. Budget for Construction and Implementation phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Construction and Implementation phase

Section 6. Budget for Operations and Maintenance phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Operations and Maintenance phase

Section 7. Budget for Monitoring and Evaluation phase

Task-based budget

Outyear objectives-based budget

Outyear budgets for Monitoring and Evaluation phase

Section 8. Estimated budget summary

Itemized budget

Total estimated budget

Cost sharing

Reviews and recommendations

This information was not provided on the original proposals, but was generated during the review process.

Comment:

The proposal states, "A key question is whether fishwheels can be successfully constructed and operated under the current regulatory and economic constraints that govern Columbia River fisheries" (p. 2). The ISRP raised these questions in our previous review of a similar proposal submitted for the FY2001 Innovative Solicitation ("Live Capture Harvest," #22066; www.cbfwa.org/2001/innovative/projects/22066.htm).

A fish wheel is a sampling appliance, like a gill net or a fish trap. Its success at capturing and keeping fish alive is well established. There should be no doubt that a fishwheel can be constructed. If they decide to give it a try, there are a number of companies (i.e. LGL Sidney, BC, Canada) that can install and demonstrate the operation of fish wheels for catching salmon alive. The implementation issue is a policy concern, about whether or not non-lethal harvesting makes sense in a situation where there is very high pressure to provide fishing opportunity to treaty fishing tribes, while at the same time the ESA requires separating endangered and threatened fish from hatchery fish.

Fishwheels were used extensively in the Columbia River prior to being outlawed by the initiative process in the state of Washington, followed soon by Oregon. The question is whether its operation will be permitted. The law does not apply to treaty tribes, as long as the tribe adopts an appropriate regulation for the fishery (U.S. v Oregon and Washington, 1969). Since the Cowlitz Tribe is sponsoring the proposal, it would seem reasonable for the tribe to adopt (or have adopted?) a regulation permitting the operation of fishwheels in the areas proposed, thus addressing the question whether operation of a fishwheel would be permitted pursuant to fishery regulations. The proposal does not address whether other regulatory agencies need to be consulted. These might include NMFS, the Corps of Engineers, other treaty tribes with rights to fish in the areas proposed, and others. We see no discussion of these points, which the sponsor itself identifies as key questions. These are administrative questions that are not dealt with in the methods or tasks section of the proposal.

Regarding the economics, not a lot of details are provided as to how the economics and regulatory issues will be analyzed. Reference is made to a "market analysis" and a simulation model to assess costs and benefits, but those references suggest that economic feasibility will depend on showing higher total returns (revenues minus costs) with fishwheel technology versus gillnets. This is really not an issue, as we know that fishwheels would be more cost-effective overall than gillnets, nor is it the point. With regard to the economics of fishing technology, the economic question is as much the distribution of net revenues as the amount. Economic issues related to allocation and distribution are what underlay the "political wrangling" the proposal cites as the reason for their discontinuance in the past. And the "carefully stated assumptions and constraints" on the simulation model (p.8), would probably have to assume away these complexities.

There is an inaccuracy in one statement in the proposal ... Aboriginal fishers in BC are not using these as a fishing technique to replace their past practices, at present the wheels operating in BC are experimental and associated with research or assessment programs. There are locations, however, where the wheels are very effective and could be used as a selective fishing tool. Their success is very site specific. From a strictly technical perspective, the ISRP supports developing this prototype fishwheel as a demonstration program, but any proposal would need to be more specific about the criteria to be used for evaluating performance, i.e. what gear types would it be compared against, and what potential advantages would be measured?

The original budget request was for $260,000, which exceeds the maximum specified in the RFP; the sponsor revised the budget to $199,945.

Comment:

Comment:

Comments
Not particularly innovative. As in past tests of fish wheels, success of catching fish will be site-specific. Thus, because this proposed test does not involve fisheries directly affecting RPA ESUs, its relevance to the BiOp would be minimal.

Already ESA Required?
No

Biop?
Yes

Comment:

Comments
Not particularly innovative. As in past tests of fish wheels, success of catching fish will be site-specific. Thus, because this proposed test does not involve fisheries directly affecting RPA ESUs, its relevance to the Biop would be minimal.

Already ESA Req? No

Biop? Yes