The South Coast Angler STEP Association (SCASA) DOES NOT SUPPORT the Public Draft (January 2014) of the Coastal Multi-Species Conservation and Management Plan (CMSCMP) and strongly encourages that this planning effort be suspended until the two items that we have asked for are addressed. The SCASA has participated in this planning effort for over a year and do not feel that the following issues have been addressed: The proposed changes do not have relevant, local science to back up major changes to how we manage fisheries on the southern Oregon Coast. An assessment of the socio-economic impacts of this plan has not been conducted. For 30 years, our community has rallied around fish. We have raised money and donated time and labor to build two state of the art fishery education and hatchery facilities. These facilities have allowed our entire community to become personally invested in our fish resources. In addition to a world class environmental education, we have been able to enhance our quality of life and standard of living. For a struggling community that finds itself at the mercy of metropolitan politics, our fantastic angling opportunities have been a major success story. This plan has disregarded the 30+ years of cooperative restoration of both naturally spawning and hatchery reared fish on the southern Oregon coast. Our local hatcheries use state-of-the-art technology and practices aimed at reducing the negative impacts of hatchery reared fish on naturally spawning fish. We have also continued to include wild broodstock into our genetic population to help maintain genetic diversity of our fish. Additionally, our community, in partnership with the state, voluntarily set aside many major rivers/streams as conservation emphasis streams where hatchery fish are not released. These rivers have been designated for over 20 years and complement our successful education programs on the other rivers in our region. This planning process must be suspended until a reasonable analysis of the socio-economic impacts is conducted. The department is in fact legally required to complete this analysis. ORS 183.335(2)(b)(E) states, “the agency shall utilize available information to project any significant economic effect of that action on businesses which shall include a cost of compliance effect on small businesses affected.” But at a stakeholder meeting in Reedsport, department officials stated that they would not conduct an economic impact analysis as part of this planning process. We are not asking for an expensive economic analysis, but we are asking that the department use the two studies that it has already commissioned that summarize the economic contributions of commercial and recreational fishing on rural Oregon’s economy. These studies were conducted in 2008 and 2013 and are posted on the ODFW website. These reports indicate that each fish caught is worth over $300 in direct spending to our struggling local businesses. These monies are distributed widely through our small community and any reduction in hatchery releases or further reduction of angling opportunity in our isolated and economically hard hit region is catastrophic. These losses will add up to hundreds of thousands or millions of dollars in direct losses each year. The proposed reduction of 101,000 fall chinook on the Mid-South Coast stratum will take hundreds of thousands of dollars out of our struggling community. Additionally, reducing the daily bag limit will be a disincentive for out-of-town anglers to make the long trip to the South Coast which would be an additional blow to our tourism industry. In addition to the economic impact these proposed reductions will have on angling opportunities, we must not forget the social impact that these proposed management plans will have on our low-income families on the South Coast. It has been widely reported that the South Coast has an unusually high percentage of low-income families. As an example, nearly 80% of the students in one Coos Bay elementary school qualify for free or reduced lunches. This plan will impact these families in two ways. First, the reduction in bank angling opportunities reduces the chance that these lower income families without access to a boat will be able to harvest our hatchery reared fish. This takes fish out of the freezer for anglers that depend on this protein to feed their families and offset their grocery bills. And secondly, will less hatchery fish released, there will be less fish available to donate to our local food back. Our hatchery programs have for years donated food grade fish that have returned to the hatchery. Again, these are fish our entire community has invested its time and energy into and those fish are helping to feed our neediest families. According to Oregon Coast Community Action, our local food bank, nearly 1,700 pounds of salmon was distributed to over 800 families last year alone. Those 2,000 people will be directly impacted by reductions in hatchery releases from our river system. This is too high of a price to pay with no science to base these management changes on. Until adequate, relevant and local science can be shown to prove that these impacts are necessary, we need to focus on research that will support or refute these drastic actions. Thankfully, the Oregon Hatchery Research Center was built and is positioned to fill this information gap. And since our operating assumption is that no fishing or conservation crisis exists now, we have time to start focused research to answer these important questions that will determine if/what policy changes are needed. If the research at that center is prioritized and coordinated to answer these questions, we can have the science to justify proposed changes to the status quo and make decisions that are based in science and not politics or feelings. The CMSCMP mentions the impact of predatory fish, birds, and mammals but virtually dismisses the impacts of predatory species on our fish populations. We strongly encourage local research of predation on both hatchery-reared and naturally-spawning fish stocks be conducted and results utilized in the development of future conservation and management plans along the coast. It seems as if ODFW is concentrated only on hatchery impacts to naturally-spawning fish, and dismissing other significant impacts to the survival of all fish. Further research on predation impacts, and incorporation of that science, will be required to produce a realistic, balanced, and science based management plan. The SCASA is not against the idea of a multi-species conservation and management plan, but we demand that if one is developed, that it be based on relevant, local science and that the social and economic impacts of that plan be fully evaluated to ensure that they are outweighed by a significant environmental benefit. Please suspend this planning effort and direct the Oregon Hatchery Research Center to conduct research on our coastal rivers to determine if a policy change is required. Please ensure that Oregon continues to base its natural resource policy on science, and not politics.
