FY 2003 Mainstem/Systemwide proposal 200005600

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

Reason for change in estimated budget

FY2003 budget request is consistent with forecast from FY2001 -- it is about $7,000 less than forecast due to deferred non expendable equipment purchases each year.

Reason for change in scope

No change in scope

Cost sharing

Other budget explanation

None required

Reviews and recommendations

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

Comment:

Last year the ISRP recommended that outyear funding be contingent on the provision of more complete information on the magnitude of the illegal harvest problem and the expected benefits to fish and wildlife from enhanced enforcement. The ISRP also asked for more detail on how efficiency and compliance will be improved and cross-zone enforcement coordinated through this project.

Statistics are provided on the increase in patrol effort enabled by the funding of last year's project. Number of contacts and violations reported both increased. Seizures of illegal gear and fish increased. More detail is also provided on the effectiveness of the enforcement activities in terms of inputs, outputs, and outcomes. Patrol hours, enforcement contacts and arrests all increased between 1999 and 2000. The inclusion of specific monitoring criteria in tasks is very positive.

This proposal seems to demonstrate a potentially successful enforcement program. The incidence of violations appear very low with the current effort. Law enforcement is an effective tool and component part of the region's effort toward recovery of endangered species. Compliance rate for harvest in Zone 6 appears high, which is laudable.

In addition to the general comments provided above, the proponents should address the following comments specific to this proposal:

• Development of the website (www.Eco-Law) is listed as a task in proposal 35052. How are the activities in the two proposals different?
• More information on outcomes of interagency coordination should be provided.
• The funding request appears to be primarily for four FTE plus associated equipment (cars, radios, boats and air support). The budget needs review for particulars as this amounts to about $115,000 cost per FTE. The total increase in patrol hours for similar funding in 2000-2001 resulted an increase in patrol hours from about 7700 hours to 9100 hours, or about 1400 hours. This seems like a relatively low amount of leverage for an additional 8000 FTE hours added to the budget. The response should address why four FTEs increases patrol time by less than 15% of the hours being paid for by BPA.
• The results show total numbers of contacts and citations increased proportionally to the increase in patrol hours. Thus, it appears that the arrest rate is directly proportional to the effort rate. This suggests there is no increased deterrence at current levels of patrolling or fishing. In examining the crime rate (arrest/contacts), it is very low with compliance reported from 95%-99% (Table 10). Thus an important question is whether the costs of the BPA program dollars are significantly leveraging results over and above "normal levels of funding". For example, a very tangible benefit is number of illegal fish seized and live fish released. A total of 38 salmonids and 72 sturgeon were released alive. A total of 152 other dead fish were also seized. These are tangible benefits. But in proportion to the total run of fish or the total numbers of fish harvested, these represent an extremely small proportion of the population of fish. Assuming that without the additional funding, about 25% fewer fish would have been intercepted, the BPA dollars appear to be purchasing about 9 live salmon and 18 live sturgeon. This is based on the ratio of increased contacts and violations being about proportional to the increased hours of patrol.
• There is clearly a "tipping point" in law enforcement when insufficient force will facilitate a significant increase in violation. This is well known for automobile speeding. Unpatrolled highways have much higher violation rates than where motorists see patrol cars and citations issued. The question is how much is enough. It appears that CRITFE has been doing a good job historically in enforcing harvest. Compliance rates have been high and remain high. They should better justify why an additional half million dollars would be well spent considering the above numbers.
• The statistics that CRITFE uses to justify its operations are traditional and as such lack sufficient rigor to actually discern cause and effect questions and hence an effective "Adaptive Management" program. Quoting Peters et al., p.25, they use it to support the idea that law enforcement is a cost effective tool, which it is. However, the key phrase within the quote "while the outcomes are difficult to measure", places the problem front and center. They are difficult to measure because proper data have yet to be collected to discern effectiveness. These questions were evaluated at length in over 200 pages of Peters et al., including using new techniques of data collection, public involvement and experiments. If the proposal were clearly aimed at these new ideas and changes, it would be far more attractive. As it stands, much of the effort, data collection and M&E proposed is relatively unchanged from the historic approaches of the 1990's and critiqued in Peters et al.
• The proposal is vague about how it will actually accomplish "adaptive management". The author should explain in more detail what new data, and testable hypotheses can be used. Table 11 attempts to do this, however they are either untestable due to complex alternative hypotheses that could explain changes in metrics or the data already suggest that the program has reached a zenith in compliance at least for harvest violations. For example: Salmon passage through the FCRPS corridor is already as high as 98% to LGR and missing fish have not been statistically adequately accounted for because radio tag experiments are not designed to assess anything except "dam effects". Previous recommendations to track radio-tag harvested fish and tributary migrations were rejected primarily for policy rather than scientific reasons. Such experiments might have both scientific as well as crime deterrent value.
• Other metrics in Table 11 have not been historically recorded or analyzed but may be valuable such as compliance rates for pump operations, diversions and habitat destruction. However, no information is provided on enforcement in these arenas or the types of data that would be collected to demonstrate improvements over the status quo or baseline.
• Resident fish are generally not endangered, thus unless CRITFE has plans for bull trout, this is not supportable by the NPPC program. Although benefits accrued toward sturgeon management are also laudable, these too are not the primary goal of the NPPC program.
• Although interagency coordination/cooperation is an historic mode of operation, it is not clear how NPPC support enhances cooperation or leverages baseline efforts. Please indicate what metrics will be used to show the additional benefits of "more cooperation" over and above baseline cooperation.
• Peters et al.1997, recommended some new ideas for public involvement to enhance compliance. Few if any of those ideas appear within the proposed scope of activities.
• Removal of ghost nets or unmarked gill nets was considered a major task in the 1990's. Has this problem been solved? It represents a potential avenue of value for which a metric needs to be developed.

General Comments on Conservation Enforcement Proposals: 35051, 35052, 200005500, 20005600, and 195505500

A response is needed for this set of law enforcement proposals. The set of law enforcement proposals stresses the interdependency between public education and effective law enforcement. A basic question these proposals should address is how to determine the best mix of enforcement personnel and education to produce the greatest net enforcement benefits.

The sponsors should also address concerns from the earlier BPA/Council review of the law enforcement program. Each proposal should justify the size of a core staff necessary for effective enforcement and place the current request in the context of core staffing needs. The Umatilla enforcement staffing level at .5 FTE appears to be the most deficient. The proposals should also describe the potential for matching effort; e.g. the Colvilles propose to train two officers from the existing force. Officers should be trained in fish and wildlife (as with the NPT).

More thought should be given as to how the impact of public education - e.g . changes in public awareness or increases in enforcement effectiveness - will be measured. Metrics to measure success and evaluate program performance need to be identified. These metrics and the monitoring program they enable should be described in advance of program enhancement.

Comment:

Comment:

Comment:

This group of responses addresses the review comments adequately. Responses include justifications of core staff and acknowledgement of how the size of a "core" changes as legal restrictions influence the demand for enforcement and funding changes affect the supply of enforcement. The responses provide thoughtful discussions of the interaction of enforcement and education as well as issues surrounding measuring the effectiveness of each. The enforcement proposals as a group and the responses provided to address ISRP review comments give a good impression of an evaluative approach to the performance of both enforcement and education. There is overlap in the responses of the individual proposals that derives from their coordination. The coordination among these proposals and responses is a positive factor that is likely to lead to collection of integrated data that will be useful for systemwide analysis of enforcement effectiveness.

ISRP Final Comments:

Fundable, agree with CBFWA that its fundable - CBFWA "urgent". This is a well-written proposal to increase the level and effectiveness of enforcement in Zone 6 tribal fishery and tributaries. Its relation to the Fish and Wildlife Program is clear. Objectives, tasks and methods are clearly defined. The proposal takes an evaluative approach to the components of enforcement.

Last year the ISRP recommended that out-year funding be contingent on the provision of more complete information on the magnitude of the illegal harvest problem and the expected benefits to fish and wildlife from enhanced enforcement. The ISRP also asked for more detail on how efficiency and compliance will be improved and cross-zone enforcement coordinated through this project.

Statistics are provided on the increase in patrol effort enabled by the funding of last year's project. The number of contacts and violations reported both increased. Seizures of illegal gear and fish increased. More detail is also provided on the effectiveness of the enforcement activities in terms of inputs, outputs, and outcomes. Patrol hours, enforcement contacts and arrests all increased between 1999 and 2000. The inclusion of specific monitoring criteria in tasks is very positive.

Law enforcement is an effective tool and component part of the region's effort toward recovery of endangered species, and this proposal seems to demonstrate a potentially successful enforcement program. The incidence of violations appears very low with the current effort. Compliance rate for harvest in Zone 6 appears high, which is laudable.

The response to ISRP concerns was thorough. A good discussion of the various possible definitions of "core" and "effective" is given, although despite the cited difficulty in deriving a single definition the response does in fact present one in the course of the discussion: to maximize the cost-effectiveness of BPA funded projects. A complete staffing analysis is provided. The responses provided more detail on the justification of budgets, indicating that BPA funding is not so much augmenting historic levels as replacing loss.

The ISRP agrees that the conservation enforcement data center has the potential to enhance the system-wide effectiveness and coordination of enforcement as well as to be a public education tool.

The graphs of trends in performance measures are useful. However, some questions about determining optimal levels of enforcement remain: (1) how can we determine how much additional funding is needed, if any, when compliance is already near 100%; (2) what metrics can be used to show cause and effect results; (3) Loss of fall chinook via unaccounted losses over dams has not been resolved because experiments had not been designed to account for all potential sources of mortality (dam loss, harvest, tributary turn off, other sources of mortality).

Comment:

Comments
This proposal does not concern the existing level of enforcement. NOAA Fisheries supports the current program. This proposal is for additional enforcement. We share ISRP's concern whether additional enforcement is necessary given the existing level of effectiveness.

Already ESA Required?
No

Biop?
No

Comment:

Comment:

Comments:
Other funding sources?

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