ODFW Proposes Changes to Sandy River Regulations

Under the guise of increasing opportunity and reducing the impact of hatchery fish on wild populations, ODFW is proposing to open up the Sandy River above Oxbow Park to angling from boats or floating devices. Currently, regulations only allow fishing from a boat below Oxbow Park while the river above the park offers some sanctuary for wild fish and anglers wishing to wade fish without conflict from other river users.

This proposal is without merit and does nothing to protect wild fish. It would be detrimental to the guides working this section of the river and to the local economy.

You can read the proposal here and make comments to ODFW.

Marty and Mia Sheppard of Little Creek Outfitters are two of the guides that would be affected and have addressed this proposal and present this compelling argument in a letter to Ben Walczak, District Fish Biologist.

Ben Walczak

District Fish Biologist

17330 SE Evelyn St

Clackamas, OR 97015

May 20, 2020

RE: Economic Impact of existing guides from proposing fishing from a boat on the Sandy River above Oxbow Park and counterpoints to reasons for a rules change.

Dear Ben Walczak,

Little Creek Outfitters is an established fly-fishing guide service in Oregon. We have been guiding anglers on the Sandy River since 2004 for steelhead. On average, we guide 150 people a year on the Sandy River between December 15 through May 1st.

We have local clients and guests that travel from all over the United States and Canada that come fishing with us. These anglers are dedicated and choose to fish the Sandy with us because of the unique and particular experience they have. The Sandy River is designated Wild and Scenic and is managed for its recreational values and to accommodate a mixed group of anglers and boaters. The section of the river we primarily float is from Dodge Park to Oxbow Park. In this section, there is no motorized boating, fishing from a boat is prohibited, angling pressure is manageable and the river is recognized for its scenic value of the steep canyon and diverse vegetation. All these qualities are what makes boating Dodge Park to Oxbow Park so inviting to visitors.

Also, there is no safe boater access or legal boat ramps above Dodge Park (See OSMB list of Sandy River boat launches: https://geo.maps.arcgis.com/apps/webappviewer/index.html… and attachment included at bottom of the letter) and the type of water above Dodge is not conducive to the style of fishing we provide visitors. The section of the river from Marmot Dam to Revenue Bridge has class 3 and 4 rapids and is not safe for most experienced boaters but perfect for hardcore kayakers. From Revenue Bridge to Dodge Park is mostly private, there are no public boat ramps in this section, and you cannot launch a boat from the bridge safely (see photos in link: https://bridgehunter.com/or/clackamas/6570002150/ ). Private property launches are the safest and least accessible to the public.

There are many types of anglers on the Sandy River; bank anglers, anglers who choose to fish from a non-motorized boat, anglers who choose to fish from a motorized boat, and anglers who use a boat for transportation then get out and wade the run.

People who want to fish out of a motorized boat can do so on the Sandy below Dabney Park or they can go choose many other places in the region including the Clackamas River, Willamette River, Columbia River, and others. Those who wish to fish out of a non-motorized boat have that opportunity from Oxbow Park down as well as the coastal rivers, Clackamas river, and other rivers in the region. Those who wish to have the experience of fishing without motorized boats or people pulling plugs, side drifting, or indicator fishing through the same water, is very limited in Oregon. One would need to travel to the Deschutes River to find a similar experience but there are no winter steelhead on the Deschutes. This is why many guides choose to make the Sandy River from Dodge to Oxbow their winter steelhead destination.

Keeping the river from Dodge Park to Oxbow Park managed under the current regulation; prohibiting anglers from fishing out of a boat; 1) cuts down on conflicts that can arise between user groups, 2) decreases pressure on wild steelhead, 3) is easily enforced.

Currently, enforcement is not an issue. Boaters adhere to the rules and if someone does break the rules, other boaters report the violation and call the Oregon state police. If this section does open to fishing out of boats, there will be more angling pressure, people illegally keeping wild fish and conflict between user groups, there will need to be a full-time officer enforcing regulations.

Many well-established guide services have spent decades marketing, building, and perfecting a program based on the current boating/fishing regulations on the Sandy. To destroy that will create a hardship for established outfitters, the local economy, and will impact the unique recreational values for visitors.

This one particular section of the river from Dodge Park to Oxbow Park supports at least 12 part-time and full-time guides. Those guides are (but not limited to): Marty Sheppard, Mia Sheppard, Brian Silvey, Dave Maroon, Travis Johnson, Mark Bachmann, Sam Sickles, Josh Linn, Nate Turner, Ted Neely, Phil Hawkings, and Brandon Bischof. The proposed new regulation would directly affect only this section of the river since there are no legal public boat launches above Dodge Park.

Not all guides work 5 days a week. Some work 7 and others 2 or 3. (For the tally below we easily prove this to equal 8 full-time guides):

The average of the 8 guides, work 5 days a week. About half the guest travel from out of state. These 100 guide days = 200 clients per guide during the season. 200 clients x 8 guides = 1,600 clients per guide. This equals $50,000 total revenue per guide or $400,000 in total bookings for all 8 guides.

The $400,000 does not include what clients spend in other necessities: Airfare, car rental, fuel, restaurants, grocery stores, fishing tackle, and appropriate licensing. Guests from out of state stay and book more consecutive days than local clients. These account for about half of the total bookings. According to the report by Dean Runyan Associates, Oregon Travel Impacts, Statewide Estimates; local clients (spend $48 per person per day.)

(Runyan and Associates, Oregon Travel Impacts Statewide Estimates 1992-2018, 2019, p. 6) x 800 guide days is approximately $38,400 back to the local economy.

Non-resident clients generate or spend $221 per person per day (Runyan and Associates, 2019) x 800 guide days creates approximately $176,800 of non-resident spending back into the Oregon economy. Total Oregon economic impact is $615,200 generated just from the section of the river, Dodge Park to Oxbow Park from December 15 - May 1st for winter steelhead. This overall dollar amount will be drastically and negatively affected if a rule change came into effect that allows fishing from a boat above Oxbow Park.

If the rule change is adopted, sadly, we will lose the unique value that our guests are drawn to and local businesses in Oregon will greatly lose. A recent poll with our clients has proved that they would be deterred to visit because of potential angling conflicts that will arise and the boater pressure that will increase.

The regulation to not fish out of the boat above Oxbow Park has been in place since 1949 and is in place to disperse user groups and provide a unique recreational experience for all boater and angling types. Visitors come fishing with us because of the way we fish, not out of a boat. Fishing this way offers anglers a unique experience that is not over-crowded or pressured by anglers fishing from boats. Take away the current regulation and it will have a negative impact on our business and many other businesses throughout Oregon from January 1- May 1. The rule change will offer no place for anglers and boaters searching for solitude and a low pressured section of a river close to Portland, a place to go.

Besides the economic disaster that would happen from the rule change, we would like to address each purpose below.

Purpose of the Change:

or

Purpose not to Change:

ODFW: Conservation. Increase the harvest of hatchery salmon and steelhead to reduce the number of hatchery fish that could potentially interact with wild fish in spawning areas.

Marty and Mia: Since winter steelhead are heavily fished for and huge percentage harvested by the many guides and general public they do not serve as a concern at all and the standards of hatchery steelhead ratio spawning with wild fish have continued to be met. Spring Chinook and fall Coho are of greater concern and based on the timing of their return (May through November) the water flows average too low to reasonably float the river. Any flows below 1,300 cubic feet per second at the USGS monitoring site: Sandy River below the Bull Run River is very hard to safely float (please see graphs attached at the bottom). Although considered unsafe, a small craft could do it but then fishing out of such a boat would be unrealistic. It would be pretty unrealistic to see someone pulling plugs or side-drifting from an inflatable kayak or inner-tube.

ODFW: ODFW is currently meeting the standards to limit the interaction of hatchery and wild salmon and steelhead on spawning grounds (pHOS) but wants to assure this conservation measure continues to be achieved.

Marty and Mia: Standards have been met. No need to change. It would be ODFWs management responsibility not to jeopardize the standards.

ODFW: The number of Sandy River hatchery spring chinook smolts released in 2020 was increased to 200,000 fish (from 132,000). Increased opportunities for angler harvest is desired to assure the pHOS standard continues to be met.

Marty and Mia: ODFW’s management should not have increased the number of hatchery releases unless a plan was made and they were certain the increase could be harvested. It would be backward tactics and bad management practices if the decision to create a rule change after making a problem in meeting the pHOS standard.

ODFW: The change would provide increased angling opportunity in a uniquely serene setting on the slopes of Mt. Hood in close proximity to the Portland Metro area.

Marty and Mia: Since there are no legal public boat launches above Dodge Park this only effects the section from Dodge Park to Oxbow (6.7 miles) to get any real use. That particular section already has high use. At least 12 guides utilize it from December through May and many members of the general public boat this section each and every day. It already has what many do consider too much pressure. Many days, every spot is occupied by anglers. This rule change would take away the opportunity to be able to fish from shore in this small stretch of river without anglers fishing from a boat into the same water. Allowing fishing from a boat would result in boat anglers cutting off bank angler’s fishing and damaging the experience for all anglers. The reason the mentioned guides do not work this section of the river during the months of June through November is the flows are not adequate to navigate safely (please see graphs attached at the bottom).

ODFW: The change should also increase the contribution of hatchery fish to anglers.

Marty and Mia: The change would not increase the contribution of hatchery fish to anglers. Anglers are already able to fish every piece of water available. Fishing out of a boat won’t change that. The only change would be the negative interactions between the ways people fish.

ODFW: The change would add over 25 miles of the Sandy River open for salmon and steelhead angling from a floating device. Currently, only about 12 miles are open.

Marty and Mia: This change would not add 25 miles because there are not any legal public boat ramp above Dodge Park. It would add 6.7 miles of fishable water and inject conflict amongst anglers that does not currently exist. This is also worth noting.

ODFW: Angling access in the Sandy River has steadily declined since the rule prohibiting angling from a floating device was adopted. Over time private landowners have become less tolerant of allowing anglers access across their lands due to increasing problems with river users, primarily non-anglers during summer months. Also, the topography of the Sandy River limits the ability to fish from the shore in many areas but in some of these locations angling from a boat is feasible.

Marty and Mia: Angling access has not declined. If anything the transfer of the PGE property from Western Rivers Conservancy and then to the BLM has increased opportunity to bank anglers. Even though there is not a legal public boat ramp the hikers are able to access the river to fish. Also, The Nature Conservancy has acquired many miles of the Sandy River and has transferred some of that to Metro Parks. All increasing opportunities for hike-in anglers in the proposed rule change stretch of river. No new boat ramps have been added or taken away.

ODFW: This change simplifies angling regulations by removing an outdated regulation originally adopted in 1949. The 1949 rule prohibited angling from a floating device upstream of the Viking (Stark Street) Bridge. In 1988 the prohibition was moved upstream to Oxbow Park. The current regulation is inconsistent with other Willamette Zone regulations, is difficult to enforce, and maybe a barrier limiting angler participation.

Marty and Mia: The rules are simple and easy to follow. I have seen two parties that were fishing from a boat in 17 years of full time guiding. They were politely educated and thankful for the clarification.

ODFW: The proposed rule change will not affect the existing prohibition on operating motorized boats upstream of Dabney State Park (Oregon Marine Board rule).

Marty and Mia: If simplification is truly the goal why not open up all of the river to motorized boating? I believe that is another rule easily understandable and not confusing. Just like the prohibition of fishing from a floating device above Oxbow Park. The current rule is simple enough and offers diverse and desired angling experiences as it stands.

Sincerely,

Marty and Mia Sheppard

Little Creek Outfitters