2023 Salmon Disaster Assistance Spend Plan Letter to CDFW Director
April 19, 2024
Chuck Bonham, Director
Department of Fish and Wildlife
715 P Street, Sacramento, CA
RE: 2023 Salmon Disaster Assistance Spend Plan comments
SalmonDisaster@wildlife.ca.gov
Dear Director Bonham,
On behalf of the Northern California Guides and Sportsmen’s Association (NCGASA) I am writing to provide feedback on the proposed 2023 Salmon Disaster Spend Plan. As an organization we are tremendously disappointed in the manner in which the Department determined the 2023 financial loss to the inland charter guide sector, which is only further compounded by the fact that the Federal government did not honor the full financial loss request from the State of California, adding insult to injury.
NCGASA is an association of over 600 licensed guides and over 4,000 sportsmen and women that work together to protect and increase hunting and fishing opportunities throughout California. NCGASA acts as a voice to represent all people who use California’s waterways and lands. We work closely with many other conservation organizations to make sure we leave a legacy for our children and grandchildren; the same access to outdoor recreation and appreciation for abundant wildlife and fisheries that was instilled in so many of us.
Our Association has repeatedly stated our belief to you that there are approximately 120 licensed salmon guides that can prove an economic loss of $3.2 million for the 2023 season. Instead of working with us and our members to calculate this loss on the basis of tax returns, the Department chose (for the first time) to calculate losses based on logbook returns. As a result of that decision, your calculation for the sector loss was significantly below what we know to be the true impact, at a valuation of about $1 million dollars. This is the amount that you submitted as part of your federal disaster assistance request. Subsequently, the Federal government then only provided 66% of the total requested amount, resulting in an even smaller amount of available funding to our sector.
Therefore, a conservative economic loss calculation of $3.2 million becomes $1 million becomes $690,000, a fraction of the overall community need. Had you worked with us to establish the $3.2 million need we would be talking, at least, about distributing $2.1 million at this time.
Your decision to base economic disaster assistance payments off of guide logbooks, rather than a more reliable method like previously reported taxable income or proof of economic loss (like we have done in previous disasters and during COVID) is resulting in economic harm to the members of my industry. We have repeatedly voiced our concerns about the process you are using to calculate economic damages.
As documented in our January letter notifying you of our intent to litigate against the state, these our some of our observations that we have repeatedly made during this process:
1) Using guide logs to compute the economic value of the inland fishery is NOT an accurate methodology. Many of our guides, myself included, have discovered that you do not have a complete and accurate history of the records that we are required to give you, and as a result are shorting dozens of the members of our industry tens of thousands of dollars in economic disaster assistance.
2) In the last collapse of 2008-2009, the Department sent letters to everyone who checked the box as a guide for salmon on their guide application form and requested calendars, logbooks, and taxes to prove their loss with their applications. This was NOT done for 2023.
3) The Department does not state anywhere on these forms, or in any official documents, that guide logbooks will the used exclusively to calculate the economic vitality of the industry as a whole, or to track an individual guide’s economic output.
4) Your own record keeping is suspect and flawed. The Department does not and never has required signature confirmation of receipt that they have received our guide logbooks. We know for a fact that the Department’s records are inaccurate by having guides ask you for a record of their logs and comparing them to the actual log box retained by these businesses.
5) The Department does not track or monitor the condition of these logs once they are received by the state. We understand that you box them up and stick them in the proverbial “basement”. They are never opened, entered into any database electronically, or otherwise tracked once they are received.
6) The Department has moved the location of its guide logbook storage over time, and there is no system in place to verify that all records have been appropriately maintained and not lost or misplaced during these moves.
7) The Department changed the address that guide logbooks must be submitted to in 2021. Many logbooks were sent to the previous address and that has never been analyzed or addressed.
8) Because you will not release bulk logbook data to our organization to allow for an analysis on our part, I am restricted in the examples I can give you to myself personally and other guides I have spoken to. Here are several examples.
In my case the Department is missing 20+ logs from 2018, a few from 2019, and 50+ logs from 2021. Just looking at my specific example alone your calculations on income are close to $75,000 over these years which when averaged by 5 would be $15,000.
We have had 6 other guides contact the Department separately to get copies of their own records, and every single one of them attests that the records the Department has on file are not correct nor reflect what has been sent in by them over the past 5 years.
This situation is infuriating to our industry. When I was first elected President in 2016 one of the first items we petitioned to update was a move from handwritten to electronic logbooks. The Department and the Commission have always declined to address this issue, claiming you lack the resources to implement it. Imagine how much more accurate your records would be for this disaster situation if you had that system in place.
We believe, based on the analysis conducted by our organization, that the most accurate assessment of the impact to our industry is about 120 guides with an economic loss of $3.2M. The Department’s calculation is woefully short of this total, the Federal governments further reduction of the requested funding only exacerbates this situation significantly.
At this point we are at a loss for further recommendations beyond our observations that this money will not do much to alleviate the true economic impact of the 2023 closure. We must do better for the now imminent 2024 closure, both in terms of process and financial relief.
Sincerely, James Stone
Northern California Guides and Sportsmen’s Association
Link to draft “2023 Salmon Disaster Spending Plan”
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=221468&inline
