Comment:

The ISRP has identified all tribal enforcement projects in this review as "not applicable" because scientific assessment of the enforcement activities to biological conservation objectives is not possible.

There is a need for proponents of this and other enforcement projects to coordinate with biologists from CRITFC and other agencies to obtain estimates of the biological metrics and relate these estimates to enforcement activities.

All of the tribal enforcement projects have documented their activities. A separate effort is needed to track trends in enforcement activities among tribes, quantify their cumulative enforcement actions, assess changes over time, and relate these activities to biological conservation objectives.

1. Objectives, Significance to Regional Programs, and Technical Background

The proposal describes the overall goal of this salmon conservation enforcement effort within the Nez Perce Tribe 1855 Treaty Area, Zone 6 of the mainstem Columbia River and Usual and Accustomed fishing areas. A simple, general objective (i.e., statement of purpose) is stated, but it is not possible to determine if or when such an objective is achieved. The objective does not refer to biological outcomes relevant to the Fish and Wildlife Program (e.g., increased survival of salmon). Specific quantitative objectives with timelines are needed.

There is no discussion of anticipated benefits. While it is accepted that law enforcement is necessary, benefits to be achieved by the proponents' law enforcement program are not explained.

2. Results and Adaptive Management

It is assumed that enforcement of resource protection regulations benefits salmon populations throughout the middle Columbia Basin. Benefits to the Council's Fish and Wildlife Program are not explained. There is no discussion of what has been achieved by the law enforcement program since its beginning in 2007. Simple statistics of enforcement activities (e.g., license checks, warnings, hours and miles patrolled, hours investigated, meetings) are documented in annual reports. There is no evaluation to identify whether these activities have improved compliance with the laws or how enforcement procedures could be improved. Lessons learned about enforcement strategies or tactics have not been documented.

Law enforcement activities are documented as statistics in annual reports. It would be useful to compile these statistics by year over the history of the project to examine temporal trends in legal infractions and patrol efforts. Such a synthesis would facilitate analyses to assess improvements in coverage and public compliance and help to reveal new challenges for the project.

No information was provided in the proposal on the use of results from law enforcement activities for adaptive management. Quantitative objectives with timelines coupled with monitoring and assessment of metrics stated in objectives would enable an adaptive management cycle. An adaptive management cycle would allow for more effective review of methods, evaluation of performance outcomes, and sharing of lessons learned.

In the ISRP 2010 review, the ISRP listed two qualifications that pointed to opportunities to improve and coordinate data collection through spatial representation (GIS) to allow a more analytical and scientific representation of what is occurring in enforcement across the Basin. These qualifications do not appear to have been addressed and are still pertinent.

The proposal does not describe public outreach activities or how such activities will be assessed.

3. Methods: Project Relationships, Work Types, and Deliverables

Methods need to be described in greater detail. Neither the proposal nor the most recent annual report (2017) documents methods in sufficient detail for scientific review. The documents provide a general overview of police patrol procedures, but they do not provide details about the survey design or standard procedures that determine patrol coverage.

Monitoring and evaluation (M&E) are not described. There is an opportunity to evaluate temporal and spatial trends in enforcement actions based on summaries in the annual reports. A useful first step would be to compile data in the annual summaries to facilitate statistical evaluation of trends.

This proposal adequately describes the type of enforcement support needed and the legal-geographic context, but is weak in providing a summary of activities or an assessment of limiting factors. The September 2010 oral presentation to the ISRP in Portland provided more detail about limiting factors challenging enforcement actions: the lack of a boat suitable to night patrol and high-wave conditions, the large size of the enforcement area, and the need for more public education about fish and wildlife conservation.

The proposal would be more informative if it described the enforcement challenges, discussed adaptive changes in approach as a result of operational learning, and included an assessment of the educational needs and the project approach to meet these. Major compliance issues could be described. In common with other enforcement projects, useful lessons could be learned by taking a more analytical approach to evaluate the overall picture of compliance. The ISRP encourages the recording and mapping of information on illegal activities.

The presentation made it clear that the project is working toward a more synthetic approach and is developing a database.

Qualification 1: Address ISRP comments on data development and summary analysis through a progress report as the database is developed.

Qualification 2: Address ISRP comments on the need for a more synthetic approach to the mapping and analysis of enforcement issues through a progress report summarizing actions taken in mapping and data analysis.


1. Purpose, Significance to Regional Programs, Technical Background, and Objectives

The proposal describes CTUIR enforcement and compliance education efforts that are a significant component of regional programs related to treaty rights for fish and wildlife.

The project has a single objective of enforcing tribal, state, and federal fish and wildlife laws. This is a reasonable objective. However, the proposal and presentation make clear that the project has other objectives that contribute to the overall enforcement objective. Public education of tribal and non-tribal members on the various fish and wildlife codes is mentioned in the project statement of purpose but is not listed as an objective. Data collection, management, and analysis, described as a work element, are also not listed as objectives, but could be.

2. History: Accomplishments, Results, and Adaptive Management

The project history focuses on financial expenditures. Previous under-expenditure of funds have provided some reserves which the proponents propose to enhance with additional funds to buy a new boat and motor that is capable of operating at night and in high-wave river conditions.

Although the proposal provides a summary of progress reports and a list of work deliverables completed, the key findings of these reports and work tasks are not summarized, nor are results of previous project compliance monitoring provided. Neither enforcement nor compliance statistics are provided. The proposal indicates that data collected are not electronically available. This data situation was discussed during the presentation, with information presented on current efforts to develop a database.

Monthly and annual progress reports, provided through links, do list numbers of enforcement actions, such as license checks or incidents investigated, as well as the area covered.

The project history indicates a change in personnel and efforts to learn desired content of annual reports and deliverables. “Adaptive management” is described as continuing to work with other agencies, but does not include a description of how operations have been adjusted based on what is learned from project actions. The project has an education program to educate tribal and non-tribal members about state fish and wildlife laws.

3. Project Relationships, Emerging Limiting Factors, and Tailored Questions for Type of Work (Hatchery, RME, Tagging)

Project personnel have been working on building working relationship with county, inter-tribal and state agencies. Details of how this is being done are not provided in the proposal. However, the annual report does provide more detailed description of joint enforcement efforts between agencies.

Monthly and annual enforcement reports describe activities but do not address any limiting factors that may be in operation, other than to describe the function and scope of the CTUIR enforcement officer. However, the proposal does note that the project has been working with other agencies to solve enforcement problems. Lack of a suitable boat prevents enforcement activities on the river in adverse water conditions.

The presentation led to a good discussion of challenges and compliance issues facing the enforcement project. The biggest challenges facing the project are the lack of a seaworthy boat and public education on fishing regulations (for tribal members) and restricted access areas (for nontribal members.) The biggest compliance issues are illegal nets and poaching of salmon, steelhead, and sturgeon. During the latest recession there has been an increase in unlicensed fishing by non-tribal fishers.

Since the start of 2010, enforcement officers have had 500 contacts with fishers, with numerous citations and warnings. They will input their information into a database to track these contacts.

4. Deliverables, Work Elements, Metrics, and Methods

The proposal lists a single deliverable as “Conservation Enforcement Officer.”

The proposal lists four work elements, although these are not tied to metrics or methods: 1. Disseminate Raw/Summary Data and Results; 2. Investigate Trespass; 3. Law Enforcement; 4. Outreach and Education

There are no metrics or methods described. However, the presentation did provide some detail on enforcement methods. Patrolling is done using a pickup equipped with police lights, radios, and siren. A laptop is used to record enforcement actions. Patrolling on the river is done using a boat equipped with police lights, radios, and siren. Radar, sonar, and night vision are used for river patrol day and night during fishing seasons, as well as for search and rescue.

The project is requesting a new boat so that greater enforcement efforts can be made on the river. The existing boat is old and not suitable for the river during stormy weather or at night. The frequency of patrols and the amount of area covered each day was not described.

Columbia River Basin enforcement projects coordinate their activities through an annual meeting.

This proposal adequately describes the type of enforcement support needed and the legal-geographic context, but is weak in providing a summary of activities or an assessment of limiting factors. The September 2010 oral presentation to the ISRP in Portland provided more detail about limiting factors challenging enforcement actions: the lack of a boat suitable to night patrol and high-wave conditions, the large size of the enforcement area, and the need for more public education about fish and wildlife conservation. The proposal would be more informative if it described the enforcement challenges, discussed adaptive changes in approach as a result of operational learning, and included an assessment of the educational needs and the project approach to meet these. Major compliance issues could be described. In common with other enforcement projects, useful lessons could be learned by taking a more analytical approach to evaluate the overall picture of compliance. The ISRP encourages the recording and mapping of information on illegal activities. The presentation made it clear that the project is working toward a more synthetic approach and is developing a database. Qualification 1: Address ISRP comments on data development and summary analysis through a progress report as the database is developed. Qualification 2: Address ISRP comments on the need for a more synthetic approach to the mapping and analysis of enforcement issues through a progress report summarizing actions taken in mapping and data analysis. 1. Purpose, Significance to Regional Programs, Technical Background, and Objectives The proposal describes CTUIR enforcement and compliance education efforts that are a significant component of regional programs related to treaty rights for fish and wildlife. The project has a single objective of enforcing tribal, state, and federal fish and wildlife laws. This is a reasonable objective. However, the proposal and presentation make clear that the project has other objectives that contribute to the overall enforcement objective. Public education of tribal and non-tribal members on the various fish and wildlife codes is mentioned in the project statement of purpose but is not listed as an objective. Data collection, management, and analysis, described as a work element, are also not listed as objectives, but could be. 2. History: Accomplishments, Results, and Adaptive Management The project history focuses on financial expenditures. Previous under-expenditure of funds have provided some reserves which the proponents propose to enhance with additional funds to buy a new boat and motor that is capable of operating at night and in high-wave river conditions. Although the proposal provides a summary of progress reports and a list of work deliverables completed, the key findings of these reports and work tasks are not summarized, nor are results of previous project compliance monitoring provided. Neither enforcement nor compliance statistics are provided. The proposal indicates that data collected are not electronically available. This data situation was discussed during the presentation, with information presented on current efforts to develop a database. Monthly and annual progress reports, provided through links, do list numbers of enforcement actions, such as license checks or incidents investigated, as well as the area covered. The project history indicates a change in personnel and efforts to learn desired content of annual reports and deliverables. “Adaptive management” is described as continuing to work with other agencies, but does not include a description of how operations have been adjusted based on what is learned from project actions. The project has an education program to educate tribal and non-tribal members about state fish and wildlife laws. 3. Project Relationships, Emerging Limiting Factors, and Tailored Questions for Type of Work (Hatchery, RME, Tagging) Project personnel have been working on building working relationship with county, inter-tribal and state agencies. Details of how this is being done are not provided in the proposal. However, the annual report does provide more detailed description of joint enforcement efforts between agencies. Monthly and annual enforcement reports describe activities but do not address any limiting factors that may be in operation, other than to describe the function and scope of the CTUIR enforcement officer. However, the proposal does note that the project has been working with other agencies to solve enforcement problems. Lack of a suitable boat prevents enforcement activities on the river in adverse water conditions. The presentation led to a good discussion of challenges and compliance issues facing the enforcement project. The biggest challenges facing the project are the lack of a seaworthy boat and public education on fishing regulations (for tribal members) and restricted access areas (for nontribal members.) The biggest compliance issues are illegal nets and poaching of salmon, steelhead, and sturgeon. During the latest recession there has been an increase in unlicensed fishing by non-tribal fishers. Since the start of 2010, enforcement officers have had 500 contacts with fishers, with numerous citations and warnings. They will input their information into a database to track these contacts. 4. Deliverables, Work Elements, Metrics, and Methods The proposal lists a single deliverable as “Conservation Enforcement Officer.” The proposal lists four work elements, although these are not tied to metrics or methods: 1. Disseminate Raw/Summary Data and Results; 2. Investigate Trespass; 3. Law Enforcement; 4. Outreach and Education There are no metrics or methods described. However, the presentation did provide some detail on enforcement methods. Patrolling is done using a pickup equipped with police lights, radios, and siren. A laptop is used to record enforcement actions. Patrolling on the river is done using a boat equipped with police lights, radios, and siren. Radar, sonar, and night vision are used for river patrol day and night during fishing seasons, as well as for search and rescue. The project is requesting a new boat so that greater enforcement efforts can be made on the river. The existing boat is old and not suitable for the river during stormy weather or at night. The frequency of patrols and the amount of area covered each day was not described. Columbia River Basin enforcement projects coordinate their activities through an annual meeting.