George Bradshaw
President
Larry Collins
Vice-President
Lorne Edwards
Secretary
Lori French
Treasurer

PACIFIC COAST FEDERATION
of FISHERMEN’S ASSOCIATIONS California Office

P.O. Box 29370
San Francisco, CA 94129-0370
Tel: (415) 638-9730
Dewww.pcffa.org
Reply to: fish1ifr@aol.com

Glen H. Spain
Acting Executive Director
Northwest Regional Director
Vivian Helliwell
Watershed Conservation Director

In Memoriam:

Nathaniel S. Bingham
Harold C. Christensen
W.F. “Zeke” Grader, Jr.

Please Respond to: Northwest Office
P.O. Box 11170
Eugene, OR 97440-3370
Tel: (541) 689-2000

PCFFA STATEMENT
ON THEVALUE OF SALMON TO THE STATE OF OREGON
28 October 2022
There are many rule-making processes now underway in Oregon as part of major public
programs to recover and restore the valuable salmonid habitat resources of this state that,
unfortunately, have suffered in recent decades from steep declines. As more and more salmonid
habitat has been blocked, dewatered, over-logged, over-grazed or industrialized, this historic lossof a major Oregon natural resource has had tragic consequences for many salmon-dependent
economies, communities and jobs.
Many of those salmonid species (such as salmon and steelhead) are also the basis of
economically and culturally important commercial, recreational, and Tribal fisheries which haveenormous value to Oregon and the Pacific Northwest economically, ecologically and culturally.
They are also a valuable food resource for America’s tables.
Yet all too often these “salmon values,” including the enormous socio-economic benefits to thepeople of Oregon from salmonid habitat restoration and watershed protections, are often ignoredin the typical costs vs. benefits analyses for watershed protection measures. These “salmon
values” (both monetizable and non-monetizable) should instead all be factored into the analysis as
benefits of any proposed watershed restoration rules, and as losses when those rules are weakened,
as noted below and in Appendix A.

1.0. Identifying and Accounting for Non-monetized Values
In the following discussion of the value of intact river ecosystems, we use the PacificNorthwest’s salmon and steelhead runs (both classed as “salmonids” as closely related species 1)
and their related commercial, recreational and Tribal fisheries as but one obvious example of the
For purposes of this discussion, unless a specific species is referred to, all salmonids are included in the commonlyused term “salmon,” including coho, Chinook, sockeye, chum, pink salmon, steelhead and cutthroat. All are
anadromous, all are in the genus Oncorhynchus, and all require similar watershed characteristics.

1

1

The Value of Salmon to Oregon
28 October 2022

many economic and other societal values that will be improved by having more protective Oregonwater quality standards than currently exist. 2 Salmon harvests are also monetarily quantifiable interms of “fiscal and economic effects.” But additionally, there are numerous other salmon-related
values and benefits that will flow from improved water quality standards in Oregon, including both
cultural and ecosystem benefits, which are termed “non-monetized values,” but which – althoughdifficult to translate directly into dollars – are nonetheless of great value to the Pacific Northwest
as well as to society as a whole, including multiple other stakeholder groups, communities andeconomies.
These non-monetized cultural and ecosystem values cannot just be ignored! When asking thebigger question not just of monetary values, but rather, “What are all the values of an intact andfunctioning riverine ecosystem?” these so-called “non-monetized values” may include multiple
cultural, lifestyle, food production, clean water and other social benefits that, if they could bemonetized, would likely greatly exceed in monetary value whatever purely localized monetary
value could be obtained by industrializing (or polluting) those same river systems.
Indeed, Oregon’s still relatively healthy river systems and watersheds are a major componentof what makes life livable in our state, providing multiple benefits which in turn create multiple
economic opportunities, including providing the vast majority of Oregonian’s potable drinking
water for its growing population. Those healthy (and especially important, unpolluted) river
systems also support nearly all of our state’s irrigated agriculture, which in turn provides jobs aswell as healthy food for Oregon’s citizens. They also support a multitude of other industries andcommunities.
Even well-water sources depend, ultimately, on inflows that are unpolluted and naturally
filtered through soils into aquifers that also must remain unpolluted. Other states (notably
California) are suffering from growing pollution problems in their remaining aquifers, problems
which in turn are closing down drinking water wells in a number of towns and cities, and forcing
the closures of some farms and related businesses. That could be Oregon’s fate also – but for ourstrong water quality standards, which will also be improved by the proposed Rules.

2.0. Economists’ Guidance Principles for Salmon Restoration
Project Costs vs. Benefits Analysis
When considering whether or not to go forward with any particular salmon habitat restoration
proposal (water quality improvements being one type of this restoration), one needs to lookobjectively at both the social costs as well as the social benefits of such an action, and on bothsides of the equation. This is usually done at the agency decision-maker level through some type
Since salmon are a highly migratory set of species, and circulate widely throughout the North Pacific Ocean,
Oregon-origin salmon runs are a major component of the entire Pacific Northwest’s salmon fisheries, especiallysince Oregon-origin salmon mostly migrate north into cooler waters where they can be harvested in Washington,
British Columbia and Alaska fisheries. Oregon also shares the worlds’ most important salmon producing river – theColumbia River – as its northern border with Washington. Oregon’s water quality protections thus contribute to thehealth of all Pacific Northwest salmon fisheries, because Oregon-origin and Columbia basin-origin salmon runs are
all protected by those standards.
22The Value of Salmon to Oregon
28 October 2022of “costs-benefits” analysis. DEQ Staff are required to do something similar in assessing theimpacts of the proposed Rules.
However, as a number of professional natural resource Economists have noted, while purely
economic costs of compliance are important in many analyses of impacts, both the economic andnon-monetized social benefits of salmon habitat restoration proposals are often given short-shrift
or ignored in most current, standard, agency “costs-benefits” analyses. This initial analytical bias
greatly distorts the economic balance sheet and thus unfairly pre-biases public policy decisionmaking toward one end of the spectrum.
Professional Economists tell us that in any legitimate “costs vs. benefits” analysis, we mustaccount for the fact that salmon recovery (and by extension, water pollution mitigation efforts)
will generate economic benefits as well as costs. To understand the net benefit (a net cost if
negative) to the economy as a whole, one must consider the effects on the production of all goods
and services. The effects on goods and services that are traded in markets, such as commercial
salmon, timber production, and agricultural production, should receive the same consideration as
those, such as recreational fishing, clean streams, and biodiversity (i.e., non-market values) thatare not. Economists also tell us that a full accounting must be provided of the true value of eachaffected good or service, taking into account the market price, where appropriate, as well as all
factors, such as subsidies, taxes, and environmental externalities, that may distort the level ofsupply or demand.
In addition, a true “costs vs. benefits” analysis should take into account “the costs of doing
nothing.” In a highly degraded system (which all too many Oregon watersheds are now sufferingfrom) and in streams with already poor water quality resulting from human-caused pollution, there
is an often very large social cost of maintaining the degraded status quo. That social cost is a net
drag on the economy that could include economic costs that are monetizable as well, including:(a) greatly depleted (even ESA-listed) salmon runs, which then foreclose harvest opportunities andcost coastal fishing-dependent communities jobs and incomes; (b) additional water treatment costs
to local municipal water providers who are required to filter out pollutants and treat water for
additional pathogens; (c) lost recreational activities because of health-code restrictions onrecreational use of polluted water bodies (including closures caused by toxic algae blooms that arebecoming much more common), thus reducing the recreation-based income of local affected
communities ; (d) loss of local property values triggered by poor water quality as well as the above
impacts. These externalized costs of water pollution to society, especially to many water qualitydependent businesses, as well as from pollution-caused threats to public health, are often ignoredin typical costs vs. benefits analysis – but this “cost of doing nothing” can be very high.
That said, attached for reference are two well-respected Guidance Letters from numerous
western-based professional resource Economists that contain principles of costs-benefits analysis
they believe should apply to all salmon habitat and water quality protection efforts such as those
proposed by DEQ’s Rules, as well as to all other western U.S. natural resource decisions. (SeeAPPENDIX A)

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The Value of Salmon to Oregon
28 October 2022

3.0. The Value of Pacific NW Salmon
There are a multitude of good policy as well as economic, ecological and cultural reasons forthe protection and restoration of the Pacific Northwest’s dwindling salmon runs. Furthermore,since Oregon’s and the Pacific Northwest’s salmon runs are all highly migratory, the value theybring to society is distributed over a wide geographical region, from at least central California tosoutheast Alaska, where these salmon, when harvested, provide food, jobs and economic value tomany people and businesses, and support multiple food chains and ecosystems.

3.1. Salmon Ecosystem Benefits
The once-great salmon runs of Oregon and the Pacific Northwest never existed in an ecologicalvacuum, but are instead an integral part of an entire food-web that still supports many other species.
Salmon are a major or important food source not just for humans, but for at least 138 species ofbirds, mammals, amphibians and reptiles native to the Pacific Northwest that have been identified
by scientists as predators or scavengers of salmon at one or more stages of the salmon lifecycle.
Of this group of 138 species, 9 species have a strong-consistent relationship with salmon, andanother 58 have a recurrent relationship with salmon. Yet another 25 species have indirect
relationships that depend upon healthy salmon runs to support their direct prey base.
As a recent survey of these salmon-driven ecological relationships notes:“Salmon act as an ecological process vector, important in the transport of energy andnutrients between the ocean, estuaries, and freshwater environments...... As a seasonal
resource, salmon directly affect the ecology of many aquatic and terrestrial consumers, andindirectly affect the entire food web.” 3
Indeed, the return of salmon back to their natal watersheds as adults is the one known
mechanism for returning irreplaceable land-based nutrients, otherwise lost by erosion, back to theland. But as the region’s salmon runs have collapsed, so has this important nutrient recycling
mechanism. Recent calculations by Gresh, et al. indicate that only about 3 percent of the marinederived biomass once delivered annually by anadromous salmon to the rivers of the Puget Sound,
the Washington coast, Columbia River, and the Oregon coast is currently still reaching thosestreams. 4 In other words, lack of returning salmon in recent decades is starving whole inland
ecosystems, with unknown ultimate consequences.

Species numbers and quote from introductory Abstract in Cederholm, C. J., D. H. Johnson, R. E. Bilby, L. G.
Dominguez, A. M. Garrett, W. H. Graeber, E. L. Greda, M. D. Kunze, B. G. Marcot, J. F. Palmisano, R. W.
Plotnikoff, W. G. Pearcy, C. A. Simenstad, and P. C. Trotter. 2000. Pacific Salmon and Wildlife – EcologicalContexts, Relationship, and Implications for Management. Special Edition Technical Report, Prepared for D. H.
Johnson and T. A. O’Neil (Managing directors), Wildlife-Habitat Relationships in Oregon and Washington. WA
Dept. of Fish & Wildlife, Olympia, WA. (Hereinafter “Pacific Salmon and Wildlife.) Available at:https://wdfw.wa.gov/publications/00063 (last viewed 10/27/22).
4
Gresh, T. J., Lichatowich, and P. Schoonmaker. 2000. An estimation of historic and current levels of salmon
production in the Northeast Pacific ecosystem: Evidence of a nutrient deficit in the freshwater systems of the PacificNorthwest. Fisheries 25(1):15-21. Available from American Fisheries Society at: https://fisheries.org/booksjournals/fisheries-2/ (last viewed 10/27/22).
3

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The Value of Salmon to Oregon
28 October 2022

Table 2.2.1-1: The nine wildlife species identified as having (or historically had) a strong, consistent relationship with salmon in
Oregon and Washington. An “X” identifies the life stage(s) of salmon applicable to the species (from Appendix 1, PacificSalmon and Wildlife, supra).
Incubation
CommonMerganser
Harlequin
Duck

X

Freshwater
Rearing
X

X

Saltwater

Spawning

Carcass

Comments

X
X

OspreyBald Eagle

X

X
X

Caspian TurnBlack Bear
Grizzly Bear
Northern River
Otter
Killer Whale

X

X

X

Strong relationship w/drift eggs andalevin; indirect relationship with carcassderived insects.

X
X

X

X
X
X

X
X
X

Strong relationship w/salmon; also
indirect relationship – feeds on gulls,
terns, and waterfowl that eat salmon;
occasionally have been seen catching andconsuming smolts.

X

The Plight of Southern Resident Killer Whales as an Example of this BiologicalInterdependence: As just one current popular example of the intimate food-web dependency ofmany species on healthy Northwest salmon runs, consider the plight of endangered Southern
Resident killer whales (Orcinus orca). In 2005, due to their small population size and significant
threats to their survival, NOAA Fisheries issued a final rule designating Southern Resident killer
whales as “endangered” under the U.S. Endangered Species Act. 5 Scientific studies have shownthat this whale population is food-limited, with declines in survival, 6 fecundity, 7 and social
cohesion 8 during years with low Chinook salmon availability.
As it turns out, these orcas depend almost exclusively on salmon, with salmonids comprisingover 98 percent of their diet. 9 Of that, roughly 80 percent of their diet is Chinook salmon. As many
key salmon runs have declined, lack of prey, principally of their favored Chinook, is among thegreatest threats to Southern Resident killer whale recovery and survival. The science shows thatthese orcas are feeding on salmon off the outer coast of Washington, Oregon, and California
70 Fed. Reg. 69,903 (November 18, 2005).
Ford JKB, Ellis GM, Olesiuk PF, Balcomb KC III (2009). Linking killer whale survival and prey abundance: food
limitation in the oceans’ apex predator. Biol Lett 6:139–142.
7
Ward EJ, Holmes EE, Balcomb KC (2009). Quantifying the effects of prey abundance on killer whale
reproduction. J Appl Ecol 46:632–640.
8
Parsons KM, Balcomb KC III, Ford JKB, Durban JW (2009). The social dynamics of the southern resident killer
whales and implications for the conservation of this endangered population. Anim Behav 77:963–971.
9
Ford MJ, Hempelmann J, Hanson MB, Ayres KL, Baird RW, Emmons CK, et al. (2016). Estimation of a Killer
Whale (Orcinus orca) Population’s Diet Using Sequencing Analysis of DNA from Feces. PLoS ONE 11(1):e0144956.doi:10.1371/journal.pone.0144956.
565The Value of Salmon to Oregon
28 October 2022

between January and June, and that these orcas concentrate near the mouth of the Columbia River
at times that coincide with the return of spring Chinook. 10
The 2008 NOAA Fisheries Southern Resident killer whale recovery plan states: “Perhaps the
single greatest change in food availability for resident killer whales since the late 1800s has been
the decline of salmon in the Columbia River basin.” 11 Salmon restoration efforts at a region-widebasis are necessary to help achieve Southern Resident killer whale recovery goals. Oregon DEQ’s
improvements to existing salmon habitat protection Rules under consideration are an importantelement of Oregon’s statewide salmon restoration efforts.
Salmon and Healthy Forests: Ecologically, trees need salmon as much as salmon need trees.
Throughout the Pacific Northwest and northern California, where forest soils are often nutrientpoor, the salmon lifecycle is an important driver of the overall forest nutrient cycling system that
supports forest health. Salmon are “anadromous” – this means they start their lives in freshwaterlakes, streams and rivers, then migrate to saltwater where they spend, according to species, fromtwo to seven years at sea before returning to freshwater to spawn and then die.
But when they return to spawn then die, salmon become a conveyor belt for key forest nutrients
to come back from the ocean to land. For example, an adult chum salmon returning to spawn
contains an average of 130 grams of nitrogen, 20 grams of phosphorus and more than 20,000
kilojoules of energy in the form of protein and fat; a 250-meter reach of salmon stream in southeast
Alaska, for instance, receives more than 80 kilograms of nitrogen and 11 kilograms of phosphorousin the form of chum salmon tissue in just over one month. 12
As the bodies of spawning salmon break down, nitrogen, phosphorus and other nutrients
become available to streamside vegetation. According to Robert Naiman of the University ofWashington, streamside vegetation in the Pacific Northwest gets just under 25 percent of its
nitrogen from salmon. Other researchers report up to 70 percent of the nitrogen found in riparianzone foliage comes from salmon. One study concludes that trees on the banks of salmon-stockedrivers grow more than three times faster than their counterparts along salmon-free rivers and,growing side by side with salmon, Sitka spruce take 86 years, rather the usual 300 years, to reach
50 cm thick. 13
In short, if the Pacific Northwest loses its salmon runs, this places many of its native forests at
long-term ecological risk as well.

Haneson MB, Emmons CK, Ward EJ (2013) Assessing the coastal occurrence of endangered killer whales using
autonomous passive acoustic recorders. J. Acoustic Soc. Am. 134(5) 3486-3495.
11
National Marine Fisheries Service (2008) Recovery Plan for Southern Resident Killer Whales (Orcinus orca).
National Marine Fisheries Service, Northwest Region, Seattle, Washington. At: II-82.
12
For an overview of the many studies of this phenomenon, see Robert J. Naiman, et al. Pacific Salmon, Nutrients,
and the Dynamics of Freshwater and Riparian Ecosystems, Ecosystems, Vol. 5, No. 4 (June 2002), pp. 399-417,
available on the Internet at: https://www.jstor.org/stable/3658977
13
Helfield, James M., “Effects of Salmon-Derived Nitrogen on Riparian Forest Growth and Implications for Stream
Productivity"(2001). Environmental Sciences Faculty Publications. 19. https://cedar.wwu.edu/esci_facpubs/19;
Reimchen, T., et al. 2003. Isotopic evidence for enrichment of salmon-derived nutrients in vegetation, soil andinsects in riparian zones in coastal British Columbia. American Fisheries Society Symposium 34:59–69.
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The Value of Salmon to Oregon
28 October 2022

Salmon and Healthy Estuaries: Salmon occupy the estuaries of the Pacific Northwest in twolife-stages: (1) as very small out-going juvenile smolts that are adapting to ocean life in brackishsalt-water marshes and estuaries as a transition stage to ocean migrations, and; (2) as returning, inmigrating adults. In the first stage they are important prey species for many other types of fish,
but in the adult stage they are both predator as well as important prey to marine mammals such as
sea-lions and orcas, and to much larger fish. In both roles they are an important contributor to theecological health of the region’s estuaries, as well as linked to the overall health of these estuaries
as critical habitat for many other species.
All river estuaries are ecologically important. As an example, the Columbia River estuary
ecosystem contains more life per square inch than the richest farmland and provides for multiple
species of wildlife. The greater number of distinct habitats there are within an ecosystem, the more
species it supports, the more ecological processes and functions it provides, and the better it
withstands disturbances. Unfortunately, its historically wide range of complex, diverse habitats is
now greatly diminished in the lower Columbia estuary. In the last 100 years more than 114,000
acres of lower Columbia River estuary floodplain have been converted to agricultural, urban, orother uses – a habitat loss in excess of 50%. Loss of critical estuary habitat has also been a factor
driving regional salmon declines. Similar losses have occurred in many of Oregon coastal
estuaries as well. Therefore, restoration of critical estuarine habitat for salmon should also be apart of any comprehensive salmon restoration strategy.
Salmon as Highly Migratory Ocean Species: Most salmon species are highly migratory, andonce they reach the ocean they can travel literally thousands of miles both north and south as they
search for food and grow to maturity, with established coastal-shelf migration routes down thewest coast to as far south as San Diego, and far north well into the waters of southeast Alaska. See
Chart 1.
Oregon coastal salmon thus constitute a significant portion of ocean harvests in all these otherareas. More important, these widely migrating salmon become a major component of the entire
west coast ocean ecosystem, in the roles of both predator and prey, during the years of their wholejuvenile and adult life stages in the oceans. Their value in supporting and contributing to abundant
ocean ecosystems and food webs is of incalculable (but clearly large) value to those rich ocean
biological systems.

3.2. Specific Salmon Economic/Monetary Benefits
Commercial, recreational and Tribal subsistence fisheries support many communities andeconomies in the Pacific Northwest, including (as examples) the following:
Ocean Commercial Salmon Fisheries: Commercial salmon fishing generates thousands ofjobs in smaller coastal Pacific Northwest communities that lack the diversity of economic
opportunity present in major urban areas. 14 Oregon’s valuable commercial and recreationalsalmon fisheries are no exception.

Community Attributes Inc., Washington State Maritime Sector Economic Impact Study at 37-40 (2017) at:
https://www.maritimefederation.com/wmf-2017-impact-study.html. See also Wash. Dept. of Fish and Wildlife,
Final Report: Economic Analysis of the Non-Treaty Commercial and Recreational Fisheries in Washington State at
14

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The Value of Salmon to Oregon
28 October 2022

Chart 1: Ocean migration routes of the major west coast salmon runs.
According to the Oregon Department of Fish & Wildlife, even greatly reduced in size as they
have been in recent years, Oregon’s ocean coastal commercial salmon fisheries still generated anaverage over the years 2010-2017 of 396,728 landed pounds of salmon in its multiple coastal ports,
representing an ex-vessel (i.e., essentially at the wholesale price at the boat-processor delivery
point) of an average of $2,073,481 – which would have created, because of typical economic

https://wdfw.wa.gov/publications/00464. [hereinafter Final Report]; Gordon Gislason & Gunnar Knapp, Economic
Impacts of Pacific Salmon Fisheries, Pacific Salmon Comm’n, at 27 (2017), available for download at:www.psc.org/download/333/special-reports/9337/economic-impacts- of-pacific-salmon-fisheries.pdf.

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The Value of Salmon to Oregon
28 October 2022

multipliers, more than $5,000,000 in net economic impacts to mostly poor Oregon coastal
communities through the chain of commerce. 15
Oregon coastal salmon landings during 2019, however, were improved over seriously
depressed immediately prior year averages: 985,000 landed pounds, valued at (ex-vessel prices)$4.1 million – an increase of 34,000 pounds (4%) but a decrease of $1.5 million (27%) ex-vessel
value compared with landings for 2018. In that same year, Washington’s salmon landings (towhich Oregon-origin salmon contribute) were 7.2 million pounds valued at $13.1 million ex-vessel
prices. 16 But both of these harvests were still far below what was landed in earlier decades,
reflecting overall declines of salmon runs coastwide.
Because Oregon-origin coastal Chinook salmon are also highly migratory, most of themseeking colder and food-richer upwelling waters by swimming (once they have hit the ocean)
northward up the coast to enter Washington State’s ocean salmon fisheries. While it is true
historically (and even today) that many more salmon came from Oregon’s rivers and tributaries
emptying into the mighty Columbia River than came from purely coastal rivers, Oregon-origin
salmon (particularly Chinook) from both Columbia Basin and coastal river contribute signficantly
to ocean commercial salmon fisheries landings offshore the coast of Washington, British Columbia
and even Southeast Alaska. 17
Alaska’s fishing families also depend heavily on the Columbia River’s salmon runs (a large
portion of which originate in Oregon) because so many of the salmon caught off the coast ofSoutheast Alaska are from the Columbia River Basin. 18 In 2019, commercial salmon landings in
Alaska were 827.1 million pounds, valued at $673.4 million (again the ex vessel price). 19
The Columbia River Basin was historically the largest salmonid producing river in the world,with annually returning salmon runs estimated at between 5.0 and 16.3 million returning adults,
including spring, summer and fall runs of Chinook, as well as coho, chum, sockeye and both winterand summer runs of steelhead. 20 Even though most of the juvenile salmon emerging from theColumbia estuary would normally migrate northward where they would contribute heavily to
Washington, British Columbia and southeast Alaska ocean fisheries, Columbia River-origin
salmon runs are still so large that they also contribute significantly to ocean salmon fisheries
See ODFW publication (Sept. 2019): https://www.dfw.state.or.us/MRP/docs/Backgrounder_Comm_Fishing.pdf.
National Marine Fisheries Service (NMFS), Fisheries of the United States (FUS 2019) at xxii and xxiii (2019),
available for download at https://www.fisheries.noaa.gov/resource/document/fisheries-united-states-2019.
17
Typically about 50% of the salmon harvested in the abundant Southeast Alaska ocean fisheries originated fromthe Columbia Basin, with perhaps half of those coming from Oregon natal streams and rivers. In short, perhaps
about 25% of the salmon landed in southeast Alaska fisheries could have originated from Oregon’s Columbia Basinrivers, with additional fish from Oregon coastal streams from outside the Columbia Basin also significantly
contributing.
18
See Penelope Crane, W. D. Templin, D. M. Eggers & L.W. Seeb. Genetic Stock Idenficiation of Southeast Alaska
Chinook Salmon Fishery Catches (January 2000), Alaska Dep’t of Fish and Game, available throughhttps://www.adfg.alaska.gov.
19
Fisheries of the United States (FUS 2019) at xxii, supra.
20
See A Vision for Salmon and Steelhead, Phase 2 Report of the Columbia Basin Partnership Task Force, pg. 44 for
a comparison of several different estimates of historic run sizes: https://www.fisheries.noaa.gov/vision-salmon-andsteelhead-goals-restore-thriving-salmon-and-steelhead-columbia-riverbasin#:~:text=MAFAC%20convened%20the%20Columbia%20Basin,and%20its%20salmon%20and%20steelhead
15
16

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The Value of Salmon to Oregon
28 October 2022

throughout the Oregon and northern California coastlines. This is in addition to the also significant
contribution of Oregon coastal-only salmon runs, also highly migratory.
A “snapshot” economic study of the impacts of salmon fisheries on the entire Pacific Northwest
for the year 1988 showed that commercial salmon fishing in northern California contributed morethan $95 million in personal income impacts to the regional economy, supporting 4,000 familywage jobs, and the recreational salmon fishery in that state contributed $372 million and supported
19,000 family wage jobs; Oregon’s commercial salmon fisheries in 1988 generated $89 million,
supporting 4,450 family-wage jobs, while its recreational salmon fishery generated $186 million,
supporting 9,500 family-wage jobs. Idaho has no commercial salmon fishery, but recreationalsalmon and steelhead fishing that same year in Idaho generated nearly $93 million in income,supporting 4,750 family-wage jobs. 21 These numbers show the great potential that salmon
watershed restoration efforts have to return great economic value to once salmon-dependentcommunities, if we can only clean up their habitat and give them a way to get there.
From boat builders to seafood processers, even greatly reduced in recent years, commercial
salmon fishing still generates many thousands of additional jobs throughout northern California,
the Pacific Northwest and Alaska. Like direct the commercial fishing jobs, many of these
additional jobs generated by the salmon fishing industry are located in smaller coastal communities
whose economies are heavily dependent on the fishery. 22
Oregon’s Inland Recreational Fisheries: In-river recreational fishing (particularly for muchprized steelhead) is also a major economic driver in the Oregon economy, especially in smaller
rural communities.
According to a recent economic impacts study by the American Sportfishing Association(ASA), Economic Contributions of Recreational Fishing in Oregon (published Jan. 21, 2021) in2018 year alone (as a typical sample year) ASA estimated that 569,600 Oregon recreational
anglers spent $871.8 million. 23
Tribal Subsistence and Some Tribal Commercial Fisheries: There are also multiple Tribal
Nations throughout the Pacific Northwest, including in Oregon, to whom the U.S. owes Treaty
obligations to provide for the protection of their native river systems and the salmon runs that use
those systems. The value of the Tribal fisheries to their people and their Tribal economy, bothsubsistence fisheries and small commercial fisheries, cannot be easily quantified but is clearlyenormous in terms of support for Tribal cultures and providing these sovereign First Nations andtheir communities a secure economic future, as noted below.

The Economic Imperative of Protecting Riverine Habitat in the Pacific Northwest, Pacific Rivers Council(January, 1992) Publication No. 5 (1992). These numbers are much greater in 2022 dollars than cited in 1988
dollars in the original report.
22
See Final Report, supra n.6, at 12 (These jobs are “important at the community level along the Washington
Coast, the Strait of Juan de Fuca, and the Puget Sound areas.”).
23
For the ASA Oregon Report see: https://asafishing.org/state-reports/economic-impacts-of-recreational-fishingoregon/. For a wider Northwest economic impacts summary report see:https://www.psc.org/download/333/special-reports/9337/economic-impacts-of-pacific-salmon-fisheries.pdf.
21

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The Value of Salmon to Oregon
28 October 2022

3.3. Salmon Cultural Values
Writer Tim Egan once defined the Pacific Northwest as “Wherever salmon can get to.” In fact,salmon are a major cultural icon for the entire region, and are woven into the lives and cultures ofmany communities throughout northern California, Oregon and Washington. Coastal fishingdependent communities celebrate the return of the salmon every year, and hundreds of inland
communities and businesses depend upon recreational salmon fishing as a regular part of theirincomes and annual family recreational.
But nowhere is the connection between salmon and culture more direct than within the various
Native American communities throughout the region. Restoring the salmon runs these Tribes
depend upon for both their subsistence and fish marketing economies, their cultures and their
futures as Tribal people is a legal as well as high moral obligation.
In the words of these sovereign Tribal governments whose lands span the Columbia basin, fromthe recent Columbia Basin Partnership’s 100-year salmon and steelhead restoration plan, A Vision
for Salmon and Steelhead, the Columbia River Treaty Tribes particularly remind us:“The Columbia River Treaty Tribes are still here and are still committed to the same ancientcovenant with salmon. We will continue to speak for those that cannot. Columbia River
Treaty Tribes have been fighting for the rights and perpetuation of Columbia River salmon
since 1855 and will always hold the government, and those that settled here, accountable
to the intent of the treaties that were signed…. The treaty tribal baseline for tribal salmon
restoration and harvest remains 1855. This entitlement is a fair share of the salmon harvest
from all streams in their ceded areas – measured at the fully functioning product levels
observed in the mid-1800s. This was the tribal entitlement at the time of treaty signing. It
is still so today, and into the future.”
And as to looking at the “costs” of salmon protections, the Columbia River Treaty Tribes also havethis to remind us of:“Over the last 200 years, tribal resource losses, including reduced availability of salmon
and steelhead, are a direct consequence of the resource gains of others in the Columbia
Basin. It is a false equivalency to propose that all parties on this Task Force should be
willing to give up equally, because historical gain/loss balances weight heavily against
tribes…..”“Rather than debating how many salmon we need to meet everyone’s needs, we should
also ask how many apples the river reasonably needs to produce. How many potatoes do
we need? How many cows do we need? And to what cost are we willing, as a society, to
pay in the currency of salmon for the various economies the region now supports? To date,most can only demonstrate their anxiety by the money they will lose and how it will hurt
them, you, or me right now. Few have talked about their own ability for adaptation andchange.” 24

Quotes from Tribal Statement in A Vision for Salmon and Steelhead, Phase 2 Report of the Columbia Basin
Partnership Task Force, supra., pages 110 & 114-115.
24

11

The Value of Salmon to Oregon
28 October 2022

4.0. Declining Salmon Runs Threaten Entire Communities
One of the most dramatic natural resource tragedies of our times, and one that has directly
affected our coastal commercial salmon fishing industry by destroying thousands of fishing jobs
coastwide, has been the thoughtless and sometimes deliberate destruction of the west coast’s once
abundant salmon-bearing rivers. Everywhere on the west coast (both U.S. and Canada) these once
abundant wild salmon runs are in steep decline, with many of them already extinct.
The steady decline of west coast salmon runs was an unacknowledged disaster until theprestigious American Fisheries Society (AFS) published a peer-reviewed, comprehensive
scientific survey of the problem in “Pacific Salmon at the Crossroads: Stocks at Risk from
California, Oregon, Idaho, and Washington,” (Nehlsen, et al., Fisheries, Vol 16, No. 2, pp. 4-21
(March-April, 1991)). 25 That first-ever rigorous survey of all west coast salmonid stocks foundthat of the 214 separate stocks still existing, 101 were at high risk of extinction, 58 at moderaterisk of extinction, 54 of special concern, and one (California Central Valley winter-run Chinook)
already by that time classed as threatened with extinction under the federal Endangered Species
Act (ESA) and as endangered under California’s separate ESA statute. It also found from
historical records that at least 106 to more than 200 other distinct stocks of salmonids had alreadyby that time been extirpated from their native habitat.
Human actions driving salmon declines are many: thoughtlessly over-engineered rivers withtoo many dams that block migratory salmon and destroy downstream water quality; massive
dewatering of key salmon-producing rivers, some of which – like the once great San Joaquin Riverin California – were totally dewatered for decades; poorly thought out logging and agricultural
practices that drive sediment loads up to fatal levels for fish, and fill our rivers with toxic, fishkilling pesticides; widespread land-use, urbanization and water diversion policies that ignore
natural river processes and fish needs, and which destroy key salmon spawning and rearing habitatfrom estuaries to far inland. Widespread and accelerating climate change (also driven by humangenerated greenhouse gases) just exacerbates all these problems.
Even though greatly diminished from historic baselines, and both coastal Oregon andColumbia-origin salmon runs still contribute greatly to the Pacific Northwest’s economy, fordecades salmon have also been disappearing from the Pacific Northwest at alarming rates. Once
too numerous to count, these fish today persist at only a small fraction of their historic abundance.
The collapse of what were once the world’s largest runs of salmon has led the National Marine
Fisheries Service (NMFS, also known as “NOAA Fisheries”) to protect 28 different salmonid
populations as either threatened or endangered under the federal Endangered Species Act. 26 For
many other populations it is too late – they are already extinct. The industrialization and pollutionof Oregon’s watersheds in ways, including diminished water quality, that have caused theelimination and degradation of available salmon spawning and rearing habitat has been a major
factor in these declines.
Available from AFS archives at: https://fisheries.org/books-journals/fisheries-2/
See NOAA Fisheries ESA listed salmon & steelhead list at: https://www.fisheries.noaa.gov/species/pacificsalmon-and-steelhead.
25
26

12

The Value of Salmon to Oregon
28 October 2022

Despite some recent efforts to recover damaged salmon runs, Oregon’s once-abundant salmon
are still very much in trouble, and so are the Oregon commercial fishing families and coastal
communities who depend upon them for their livelihoods. Salmon landings in our Oregoncommercial ocean fisheries have dropped off dramatically in recent years, with long-term trends
downward, in spite of annual fluctuations (see Chart 2). 27 To separate out the long-term trends
from annual fluctuations, we simply take landing averages derived from several-year periods, andthen compare those to similar ranges of other years, such as these ranges:
1950-1960 average annual landings = 10,910,050 pounds
2010-2020 average annual landings = 2,651,122 pounds
LOSSES between these two periods = 76% lost productivity
What those losses mean in practice is that, as compared to the average landings in the years 19501960, some 8,258,928 landed pounds of salmon are now effectively missing annually, on average,from Oregon’s commercial ocean salmon fisheries. At an ex vessel price of $3.33/pound landed(which was what was received in 2020, using the figures in Chart 2), this means that more than
$27.5 million dollars in economic value has been taken from Oregon’s coastal salmon-dependentcommunities, on average, each recent year because of pervasive salmon declines. This has meant
lost jobs, collapsing fisheries infrastructure, and lost economic opportunities for thesecommunities’ futures.
Oregon salmon runs also contribute considerable numbers of salmon to viable ocean salmon
fisheries in Washington State, where north-migrating Oregon-origin salmon are intermingling withstocks from other states, and thus Oregon-origin salmon greatly contribute to Washington Stateocean salmon harvests.
When fewer Oregon-origin salmon migrate into and though Washington’s waters, however,this translates directly into lower salmon catch limits, shorter seasons, and a reduced ability forcommercial fishing families to earn a living. Chinook (king) salmon and Coho salmon are also themost commercially valuable of western Washington’s salmon species, 28 and these are the species
that have seen some of the steepest declines in Oregon as well as in Washington. 29 From 1950 to1955 in Washington, commercial landings of Chinook salmon averaged 10,248,683 pounds andcoho averaged 11,779,067 pounds, but from 2011 to 2016, chinook landings averaged only
5,866,870 pounds, a reduction of about 43%, and coho landings averaged only 3,102,894 pounds,

Nat’l Marine Fisheries Serv., Annual Commercial Landing Statistics (searchable by state, species, and year),https://www.fisheries.noaa.gov/national/sustainable-fisheries/commercial-fisheries-landings. Sorted from 1950 to2020 for Chinook and Coho salmon (pink, chum and Sockeye salmon are not usually caught in Oregon oceancommercial fisheries so landings for those species are not significant in Oregon ocean commercial fisheries).
28
See Gislason & Knapp, supra n.6, at 12 Exh. 2 (compare weight landed with ex-vessel value).
29
See Wash. State Recreation and Conservation Office, Governor’s Salmon Recovery Office, State of Salmon in
Watershed 2016 at 2 (showing declining trend in non-Tribal Chinook and Coho harvests from the 1970s through2015), https://stateofsalmon.wa.gov/
27

13

The Value of Salmon to Oregon
28 October 2022

a reduction of about 74%. 30 This is the same pattern of declines as in Oregon’s salmon populations,and for many of the same reasons – pervasive loss of in-stream spawning and rearing habitat.
And these numbers represent only the declines in ocean salmon harvests. Similar declines haveoccurred in inland recreational salmon fisheries, particularly in the Columbia Basin, as well as
declines of harvestable salmon for the various Treaty Tribes who have a right to catch fish that all
too often these days are simply not there!
The good news is that much of what has been lost over the past decades in salmon
economic contributions could be recaptured through appropriate salmon habitat restoration
investments. The restoration work needed to return Oregon’s salmon runs back to health are thus
not purely “costs”-- they are investments that over time, and with the return of these salmon, will
generate more jobs and prosperity for our rural coast economies indefinitely and on a sustainablebasis. It also means investing in improved water quality in our coastal and inland salmon-bearing
rivers, which is the whole point of currently proposed TMDL water quality standards
improvements.
Salmon watershed restoration also includes investing not only in the protection and restorationof Oregon’s coastal salmon-producing watersheds, but also for salmon produced in ColumbiaRiver watersheds, as for instance in the Columbia Basin Partnership’s currently active 100-year
salmon restoration plan. 31 One estimate of how much purely monetary value such a Columbia
Basin salmon restoration program could return to our Pacific Northwest economy is that restoredsalmon fisheries in the Columbia Basin could generate up to $500 million/year in regional personal
income and support up to 25,000 additional family wage jobs. 32
Learning to make those watershed restoration and water quality investments wisely andefficiently is one of the underlying themes of Oregon’s ongoing efforts to restore its damaged
salmon runs – and is ultimately also the purpose of this Rulemaking.

#####Salmon Values Report (OR) (10-28-22)

National Marine Fisheries Service (NMFS), Annual Commercial Landing Statistics, supra, for Washington
numbers.
31
See citation in footnote 19.
32
The Cost of Doing Nothing: The Economic Burden of Salmon Declines in the Columbia River Basin, Institute forFisheries Resources (Oct. 1996), available at: http://pcffa.org/wp-content/uploads/2016/10/CDNReportColumbia.pdf. These numbers are also in 1996 dollars, so would be higher today given changes in the value ofmoney over time.
30

14

The Value of Salmon to Oregon
28 October 2022

CHART 2: OCEAN COMMERCIAL SALMON LANDINGSIN THE STATE OF OREGON(Chinook and Coho salmon only)
YEAR

PoundsMetric Tons Ex Vessel Value

1950

11,194,000

5,078

2,509,761

1951

13,173,500

5,975

3,282,294

1952

12,266,800

5,564

2,573,092

1953

9,685,400

4,393

1,989,508

1954

8,153,000

3,698

1,824,483

1955

12,230,100

5,548

3,098,872

1956

13,952,300

6,329

4,014,994

1957

10,927,000

4,956

2,820,523

1958

7,479,700

3,393

2,410,984

1959

4,753,600

2,156

1,489,460

1960

5,285,100

2,397

2,074,687

1961

6,912,800

3,136

2,531,718

1962

7,130,000

3,234

2,550,455

1963

8,198,700

3,719

2,591,074

1964

9,802,100

4,446

3,036,117

1965

11,570,400

5,248

3,442,846

1966

12,355,000

5,604

3,971,916

1967

16,011,400

7,263

5,722,746

1968

9,562,100

4,337

3,553,894

15

The Value of Salmon to Oregon
28 October 2022
1969

10,176,300

4,616

4,126,915

1970

19,396,000

8,798

8,974,127

1971

16,795,500

7,618

5,595,758

1972

11,571,800

5,249

6,471,882

1973

16,904,700

7,668

11,765,135

1974

15,188,100

6,889

12,796,698

1975

12,375,900

5,614

9,422,249

1976

15,246,700

6,916

18,895,482

1977

10,257,176

4,653

16,354,814

1978

8,691,429

3,942

12,024,512

1979

10,965,282

4,974

21,849,449

1980

7,209,972

3,270

10,936,910

1981

6,595,933

2,992

10,734,465

1982

8,563,376

3,884

12,354,579

1983

2,586,279

1,173

2,980,345

1984

2,940,843

1,334

4,433,389

1985

5,674,745

2,574

8,526,602

1986

13,415,519

6,085

14,970,122

1987

14,542,534

6,596

26,380,110

1988

17,441,956

7,912

38,499,238

1989

11,447,111

5,192

14,076,519

1990

5,244,099

2,379

9,437,230

1991

5,216,452

2,366

5,750,836

1992

2,123,329

963

3,530,246

16

The Value of Salmon to Oregon
28 October 2022
1993

1,697,997

770

2,348,154

1994

1,209,282

549

1,422,401

1995

2,792,859

1,267

3,551,677

1996

2,828,275

1,283

3,283,966

1997

2,234,306

1,013

2,768,342

1998

1,971,040

894

2,587,673

1999

1,549,070

703

2,040,279

2000

3,123,204

1,417

4,026,514

2001

5,254,772

2,384

5,841,059

2002

6,115,468

2,774

6,932,424

2003

6,719,581

3,048

8,868,128

2004

5,929,546

2,690

12,988,9782005

4,681,290

2,123

10,434,476

2006

1,777,806

806

4,931,865

2007

1,341,732

609

4,622,494

2008

1,789,490

812

4,117,299

2009

2,281,782

1,035

3,529,415

2010

2,746,295

1,246

7,676,296

2011

2,387,824

1,083

6,719,210

2012

1,918,901

870

6,935,089

2013

3,502,259

1,589

12,415,609

2014

6,374,659

2,892

20,066,563

2015

3,134,308

1,422

11,826,615

2016

1,818,812

825

8,259,155

17

The Value of Salmon to Oregon
28 October 2022
2017

1,184,322

537

5,529,111

2018

950,632431

5,653,121

2019992,740450

4,148,577

2020

1,500,464

681

4,997,309

1950-1960 average annual landings = 10,910,050 pounds
2010-2020 average annual landings = 2,651,122 pounds
LOSSES as between these two periods = 76% lost productivity

Data from National Marine Fisheries Service (NMFS), Annual Commercial Landing Statistics (searchable by state,
species, and year), https://www.fisheries.noaa.gov/national/sustainable-fisheries/commercial-fisheries-landings.
Sorted from 1950 to 2020 for Chinook and Coho salmon only (Pink, Chum and Sockeye salmon are not usuallycaught in Oregon ocean commercial fisheries so landings for those species are not significant in Oregon oceancommercial fisheries). Values are estimated ex vessel (i.e., wholesale at the dock by processors) prices, and are notadjusted for inflation in annual citations. These are also raw pounds, not dressed pounds.

18

The Value of Salmon to Oregon
28 October 2022

APPENDIX A
Economists’ Guidance Principles for Salmon
Restoration Costs vs. Benefits Analysis
References:
A Letter from Economists to Governors of Oregon (Kitzhaber), California (Wilson), Washington(Loche) and Alaska (Knowles) and Premier of British Columbia (Clark). (Sept. 9, 1998) [77signatures]

A Letter from Economists to President Bush and the Governors of Eleven Western States
Regarding the Economic Importance of the West’s Natural Environment. (December 3, 2003)[95 signatures]19

09 September 1998
Governor John A. KitzhaberState Capitol Building
Salem, Oregon 97310

Governor Tony Knowles
Office of the Governor
P.O. Box 110001
Juneau, Alaska 99811

Governor Gary Locke
Office of the Governor
P.O. Box 40002
Olympia, Washington 98504-0002

Governor Pete Wilson
State Capitol Building
Sacramento, California 95814

Premier Glen Clark
Office of the Premier
Room 156, West Annex
Parliament Buildings
Victoria, BC V8V 1X4 Canada
Dear Governors Kitzhaber, Knowles, Locke, and Wilson, and Premier Clark:
Decisions regarding the management of Pacific salmon, many of which are experiencing
deep declines in numbers, can affect a vast landscape along the western edge of North
America and markedly influence the region's future economy. With this letter, we hope tohelp lay the foundation for the public debate over the economic aspects of these decisions.
Most of the discourse on the economic issues of salmon recovery has focused too narrowly,
concentrating almost exclusively on the costs of recovery. Costs are indeed important, butthey tell only part of the economic story. We encourage you and the members of yourAdministrations to adopt a broader perspective and consider the full range of economic
consequences of salmon-management decisions. Toward this end, we recommend that you
examine and weigh all these factors:* Costs, Benefits, and Net Benefits.
Salmon recovery will generate economic benefits as well as costs. To understand the net
benefit (a net cost if negative) to the economy as a whole, one must consider the effects on
the production of all goods and services. The effects on goods and services that are traded inmarkets, such as commercial salmon, timber production, and agricultural production,
should receive the same consideration as those, such as recreational fishing, clean streams,
and biodiversity, that are not. A full accounting must be provided of the true value of eachaffected good or service, taking into account the market price, where appropriate, as well as
all factors, such as subsidies, taxes, and environmental externalities, that distort the levelof supply or demand. Some of the benefits and costs will manifest themselves in theConcerned Economists to Kitzhaber/Knowles/Locke/Wilson/Clark

9 September 98

page 2

immediate vicinity of the resources affected by salmon recovery, while others will manifest
themselves at greater distances.
* Jobs, Incomes, and Transitions.
Salmon recovery will have diverse impacts on labor markets, increasing some demands forlabor and decreasing others. It also may affect the spatial distribution of the supply of laborby influencing the location decisions of some households. To understand the resulting
impacts on jobs and incomes, one must consider the salmon-related changes in demand andsupply against the backdrop of the markets' ability to adjust. One should examine both theoverall change in jobs and incomes as well as the transitions for affected workers, theirfamilies, and their communities.
* Distribution of Economic Consequences.
The positive and negative effects of salmon recovery will not be distributed equally.
Identifying the winners and losers can create opportunities to explore options for breaking
political gridlock–by clarifying mechanisms, for example, for the winners to provide somecompensation to the losers.
* Rights and Responsibilities.
Owners of natural resources affected by salmon-recovery measures have both rights
regarding their use of these resources and responsibilities not to exercise these rights inways that unreasonably restrict the rights of others. This is true of both private- andpublic-property owners. To understand the costs and benefits associated with salmon
recovery, one first must have a clear understanding of the relevant rights andresponsibilities, because society might assign very different values to two recovery actions
that are otherwise identical but one restricts a property owner's rights and the other forces
it to comply with its responsibilities.
* Uncertainty and Sustainability.
Nobody can eliminate the uncertainty regarding how salmon-recovery decisions will affectsalmon populations and the economy, and it is inevitable that some decisions will not yield
the desired outcomes. Reversing undesired outcomes is always costly, however, someoutcomes are less costly to reverse than others. Some, of course, are irreversible. To
understand the full economic consequences of salmon-recovery decisions, one should
consider the potential reversal costs if the decision should yield undesired outcomes.
* Looking Beyond Salmon.
To understand the full consequences of salmon recovery, one must look beyond those tied tothe salmon, themselves, and examine those linked to the productivity and use of thesurrounding ecosystem. Changes in ecosystem productivity may occur through therestoration of the ecological functions of salmon-bearing streams and the surrounding
watersheds that will accompany salmon recovery. Changes in the use of the resources of thelarger ecosystem may have both positive and negative effects on the economy.

Concerned Economists to Kitzhaber/Knowles/Locke/Wilson/Clark

9 September 98

page 3

We hope you will consider the factors outlined here, and use this outline to improve thepublic's understanding of the full economic consequences of salmon recovery.
Sincerely,

W. Ed Whitelaw
University of Oregon/ECONorthwest

Ernest Niemi
ECONorthwest

And the following co-signing economists:
Russ Beaton, Willamette University
Peter Berck, University of California Berkeley
Bruce Blonigen, University of OregonPeter Bohmer, Evergreen College
Richard Brinkman, Portland State University
Gardner Brown, University of Washington
Walt Butcher, Washington State University
Kevin Calandri, California State University Sacramento
Arthur Caplan, Weber State University
Ken Casavant, Washington State University
Laura Connolly, Oregon State University
Jeffrey Connor, Oregon State University
Robert Curry, California State University Sacramento
Elizabeth E. Davis, Oregon State University
Robert Deacon, University of California Santa Barbara
David Donaldson, University of British Columbia
Bryan Ellickson, University of California Los Angeles
Mark Evans, California State University Bakersfield
Anthony Fisher, University of California Berkeley
David E. Gallo, California State University Chico
Alan Gin, University of San Diego
Eban Goodstein, Lewis & Clark College
Lawrence Goulder, Stanford University
Theodore Groves, University of California San Diego
A.R. Gutowsky, California State University Sacramento
Steve Hackett, Humboldt State University
Brent Haddad, University of California Santa Cruz
Dan Hagen, Western Washington University
Darwin C. Hall, California State University Long Beach
Jane Hall, California State University Fullerton
Robert Halvorsen, University of Washington
Bill Harbaugh, University of Oregon
Martin Hart-Landsberg, Lewis & Clark College
Stephen E. Haynes, University of Oregon
John F. Henry, California State University Sacramento
Steve Henson, Western Washington University

Concerned Economists to Kitzhaber/Knowles/Locke/Wilson/Clark

9 September 98

page 4

Richard B. Howarth, Dartmouth
Lovell S. Jarvis, University of California Davis
Desmond Jolly, University of California Davis
Mary King, Portland State University
Van Kolpin, University of Oregon
B. Y. Lee, University of Oregon
Cathleen Leue, University of OregonPeter Lund, California State University Sacramento
Bruce Mann, University of Puget Sound
Carlos Martins-Filho, Oregon State University
Ray Mikesell, University of Oregon
Andrew Narwold, University of San Diego
Noelwah Netusil, Reed College
Roger Noll, Stanford University
Dale O’Bannon, Lewis & Clark College
Arthur O’Sullivan, Oregon State University
Steve Polasky, Oregon State University
Thomas Potiowsky, Portland State University
Tom Power, University of Montana
R. Bruce Rettig, Oregon State University
Alan Richards, University of California Santa Cruz
Robert J. Rooney, California State University Long Beach
Tony Rufolo, Portland State University
Linda Shaffer, California State University Fresno
Barry N. Siegel, University of Oregon
Emilson Silva, University of Oregon
Ross Singleton, University of Puget Sound
Chuck Skoro, Boise State University
David Starrett, Stanford University
Kate Stirling, University of Puget Sound
Joe Story, Pacific University
Rod Swanson, University of California Riverside
Paul Thorsnes, Grand Valley State University, Michigan
Victor Tremblay, Oregon State University
Charles Vars, Oregon State University
John F. Walker, Portland State University
Norm Whittlesey, Washington State University
Yung Yang, California State University
Ross Youmans, Oregon State University
Zenon X. Zygmont, Western Oregon University
Note: Affiliations are for informational purposes and do not imply consent by organizations.
cc:David Anderson, Minister, Fisheries and Oceans, Canada
Will Stelle, National Marine Fisheries Service

December 3, 2003

A Letter from Economists to President Bush and the Governors of ElevenWestern States Regarding the Economic Importance of the West’s Natural
Environment.

To:
President George W. Bush
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
The Honorable Dave Freudenthal, Governor of Wyoming
State Capitol Building
Cheyenne, WY 82002-0010
The Honorable Kenny Guinn, Governor of Nevada
State Capitol
101 North Carson Street
Carson City, NV 89701
The Honorable Dirk Kempthorne, Governor of Idaho
700 West Jefferson, 2nd Floor
P.O. Box 83720
Boise, Idaho 83720-0034
The Honorable Ted Kulongoski, Governor of Oregon
160 State Capitol
900 Court Street
Salem, Oregon 97301-4047
The Honorable Gary Locke, Governor of Washington
PO Box 40002
Olympia, WA 98504-0002
The Honorable Judy Martz, Governor of Montana
P.O. Box 0801
204 State Capitol
Helena, MT 59620-0801
The Honorable Janet Napolitano, Governor of Arizona
1700 West Washington
Phoenix, AZ 85007
The Honorable Bill Owens, Governor of Colorado
136 State Capitol
Denver, CO 80203-1792
The Honorable Bill Richardson, Governor of New Mexico
Office of the Governor
Room 400, State Capitol Building
Santa Fe, NM 87501
The Honorable Arnold Schwarzenegger, Governor of California
State Capitol Building
Sacramento, CA 95814
The Honorable Olene Walker, Governor of Utah
210 State Capitol
Salt Lake City, UT 84114

Dear Mr. President;
Dear Governor Freudenthal;
Dear Governor Guinn;
Dear Governor Kempthorne;
Dear Governor Kulongoski;
Dear Governor Locke;
Dear Governor Martz;
Dear Governor Napolitano;
Dear Governor Owens;
Dear Governor Richardson;
Dear Governor Schwarzenegger;
Dear Governor Walker:

We are economists, and we are writing to express our concern about federal and state
actions that harm the West’s natural environment and, as a result, the economic outlook forthis region’s workers, families, firms, and communities.
The West’s natural environment is, arguably, its greatest, long-run economic strength. The
natural landscapes of the western states, with wide open spaces, outdoor recreational
opportunities, and productive natural-resource systems underlie a quality of life that
contributes to robust economic growth by attracting productive families, firms, andinvestments. The West’s natural environment, however, faces serious challenges thatthreaten to undermine its contribution to the economy. These include air and waterpollution, urban sprawl, the extension of roads and other development into roadless public
lands, and fragmentation of habitat for native fish and wildlife.
The economic importance of the West’s natural environment is widely recognized. Last
year, for example, the Western Governors’ Association, recognizing that “There is a lot atstake,” reaffirmed its adoption of the Enlibra Principles for guiding policy and decisionmaking regarding natural resources and the environment.1
The seventh of these principles is, “Recognition of Benefits and Costs – Make Sure All
Decisions Affecting Infrastructure, Development and Environment are Fully Informed.”2
We endorse this principle, and we commend each of you for your commitments to apply it to
the actions of your administration. Despite your commitments, however, many state andfederal actions are causing additional environmental degradation, increasing the risks offuture degradation, or slowing efforts to reverse past degradation. These actions harm theeconomy—across the West and in each of the states. They diminish the economic well-beingof many residents, divert natural resources from their highest and best use, reduce the1 Western Governors’ Association, “Principles for Environmental Management in the West.”
http://www.westgov.org./wga/policy/02/enlibra_07.pdf. p. 2.
2 Ibid. p. 6.

1

environmental amenities that are essential ingredients of the West’s quality of life, andpass to future generations the costs of cleaning up this generation’s environmental messes.
We ask each of you to renew and strengthen your efforts to secure for the West both ahealthy environment and a prosperous economy. Toward this end, we ask you to initiate areview of your administration’s actions affecting the environment and the economy. This
review should:•

Identify actions having a significant impact on the environment and fully describe thebenefits and costs of each.

•

Reinforce those actions that strengthen the economy by protecting or restoring
environmental quality.

•

Arrest those actions that damage the economy by degrading the environment.

In the remainder of this letter we describe the linkage between environmental quality andeconomic prosperity, identify some of the environmental policies and activities harmful towestern economies, and express eight principles for capitalizing on the environmenteconomy linkage.

Environmental Quality Is a Major Source of the West’s Long-Run, Economic
Strength
In the distant past, the West’s natural resources were widely abundant and important to
the economy primarily when they were converted into something else. We converted forests,
mineral deposits, and streams into lumber, metals, and hydroelectricity; valleys, wetlands,
and hillsides into agricultural and urban landscapes; and land, water and air into waste
repositories.
Today, conditions have changed.
Some important elements of the environment are scarcer. The population anddistribution of many native species have diminished markedly. Similarly, the suppliesof roadless lands, free-flowing rivers, and unexploited marine areas have diminishedand, although there have been some notable improvements recently, much of the West’s
air and water remains degraded.
The structure of the western economy has changed. Though still important,extractive industries (logging, mining, and commercial fishing) and agriculture now
play a smaller economic role because their ability to generate new jobs and higher
incomes has declined. Across most of the West, a community’s ability to retain andattract workers and firms now drives its prosperity. But if a community’s naturalenvironment is degraded, it has greater difficulty retaining and attracting workers andfirms.
The economic costs of environmental degradation are rising. As the West’s
population increases, so too do the damages (current and future) from exposure tohazardous pollution and the degradation of environmental amenities. As their habitats2

shrink, many native species face an increased risk of extinction. Reversing this trend
becomes more expensive over time. As ecosystems are degraded, they provide fewer
economically valuable services, such as cleansing the water in streams, andcommunities therefore must provide replacement services with water-treatment plants
and other costly investments.
The economic benefits of protecting and restoring environmental quality arelarge and increasing. As the West’s population increases, the West enjoys greater
economic benefits by avoiding exposure to hazardous pollution, maintaining scenic
natural vistas, extending the availability of recreational opportunities in clean
environments and on public lands, and sustaining the existence of undeveloped lands
and healthy ecosystems.
Misleading price signals slow economic growth. Inefficient pricing of many natural
resources encourages waste and diminishes economic productivity by allocating
resources to low-value uses, while higher-value uses languish. Subsidies to irrigation,
logging, public-land ranching, and mining prop up activities that would not take place
under efficient, market conditions. Underpricing of urban roads, municipal-industrial
water, and pollution emissions sends false signals regarding the true cost of urban
sprawl, and the true value of free-flowing streams, and clean air and water.
Climate change poses significant economic risks. Global warming threatens to alter
winter snow fall in the West’s mountains, increasing the risk that runoff in important
rivers will fall short of summer demands for water; raise sea levels, increase the risk ofcoastal flooding, change the distribution of habitats, and increase the risk of extinction
for some threatened and endangered species.
As these and related changes evolve, the economic health of western communities
increasingly will depend on the health of the environment. Long-run prosperity will derivefrom efficient, effective efforts to conserve increasingly scarce environmental resources,
protect high-quality natural environments, reverse past environmental degradation, andmanage congestion in both urban areas and on public lands with high recreational use.
Resource-management policies and economic-development activities that significantly
compromise the environment will likely do more economic harm than good.

Many Current Policies and Activities Degrade or Threaten the West’s
Environment and Jeopardize the West’s Prosperity
Numerous governmental policies and activities affecting the West’s natural resources,
which purportedly help the West’s economies, are doing just the opposite. Here are a few
examples:Inadequate investment in parks. The federal government has failed to maintain theinfrastructure and environmental quality of national parks. State and local governments
have done the same with their own parks. These failures have weakened the West’s
economies by reducing the attractiveness of nearby communities to workers and firms andby eroding the foundation for the outdoor recreation and tourism industries.

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Reduced protection for roadless public lands. By opening roadless lands to vehiculartraffic, mining, logging, grazing, and other development, usually at a net cost to the US
taxpayer, the federal government has expanded the supply of that which is alreadyplentiful and common at the expense of that which is increasingly scarce and unique. Suchactions fail to account for the benefits non-motorized visitors receive from these lands andfor the loss of the considerable economic benefits—recreation, high-quality water, wildlife
habitat, spiritual values, and more—that public lands provide when they are undeveloped.
The loss of these benefits undermines one of the cornerstones of economic strength forcommunities throughout the West.
Slow action to conserve threatened and endangered species. Congress has failed toprovide adequate funding, and federal agencies have dragged their feet when called upon toconserve threatened and endangered species. These actions jeopardize the economic outlook
for western communities by increasing the risks to species with high economic value,
protecting inefficient and often subsidized activities harmful to both the species and theeconomy, and raising the ultimate costs of conserving the species.
Slow clean-up of polluted sites. Federal agencies have not requested and Congress has
not provided adequate funding to clean-up Superfund sites promptly. Some state and local
governments have slowed the clean-up process. Delayed clean-up of these sites harms the
economy by extending westerners’ exposure to hazardous materials, diminishing the valueof nearby properties, impeding economic-development activities near polluted sites, andgiving polluters additional incentives to pollute in the future.
Ineffective response to risks of global warming. Current research results are
sufficiently robust to conclude that global warming poses significant economic risks to theWest, including increases in coastal flooding, more frequent severe storms, and reductions
in snowpack resulting in lower summer flows of important rivers and streams. These risks
are perpetuated and strengthened by the failure of Congress and the White House to takedecisive action to curb emissions of carbon dioxide and other global greenhouse gases.
Inefficient management of public forests. Federal and state forest managers
emphasize the production of logs, forage, minerals, and other commodities without fully
accounting for adverse impacts on services, such as recreation, provision of clean water instreams, sequestration of carbon, and the existence of roadless lands. These actions reduce
the overall value of goods and services derived from public forests.
Lack of appropriate incentives for resource conservation. With subsidies andinefficient pricing, federal, state, and local policies encourage waste and discourageconservation by hiding from consumers the full costs of resource-intensive activities, suchas exploration for oil and gas, irrigation, public-land grazing, and congestion on urban
roadways and at public-land recreation sites.
Unreasonable exemptions from environmental review. Federal resource managers
have granted exemptions for military operations, logging, exploration for oil and gas,
operation of motor vehicles on roadless public lands, the use of some pesticides, theemission of air pollution, and other activities. Also, de facto exemptions occur when federal
and state agencies fail to enforce environmental laws. The economy is harmed when
activities are allowed to proceed even though their economic costs outweigh their benefits.

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Unnecessarily divisive approaches to economic/environmental issues. The
costs—to individual workers, families, firms, communities, and the economy as a whole—of
the changing relationship between the economy and the environment are worsened byfederal, state, and local actions that promote misunderstanding and divisiveness rather
than cooperative problem-solving. Especially divisive and costly are proposals and decisions
that presume the economic benefits of an increase in an extractive, agricultural, or
development activity necessarily exceed the costs, even when the evidence indicatesotherwise. Recent examples include proposals or decisions to:•

Encourage road development, vehicular traffic, and other development on lands withroadless or wilderness qualities, including national parks, national forests, andlands administered by the Bureau of Land Management.

•

Promote energy consumption rather than conservation.

•

Relax restrictions on emissions of water and air pollution.

•

Forgo U.S. leadership of efforts to shape a prompt, efficient and global response to
climate-change risks.

•

Relax restrictions on the use of or exposure to potentially harmful substances.

We Encourage You to Adopt Initiatives that Promote Both a Healthy Environment
and a Healthy Economy
We ask each of you to initiate a review of the economic effects of actions taken by youradministration that have a significant impact on the environment. The primary objective of
this review should be to identify and correct those actions that are harming the economy bydegrading the environment. It also should highlight the merits of those actions beneficial toboth the environment and the economy. We urge you to act promptly.
We also urge you to implement appropriate policies and procedures to increase thelikelihood that future governmental actions will capitalize on and reinforce the evolving
relationship between the West’s environment and its economy. These initiatives shouldincorporate these eight principles:
Principle #1: Environmental protection has economic benefits as well as economic costs. It
has positive as well as negative impacts on jobs and incomes.
Principle #2: Some economic interests in natural resources are mostly local but,increasingly, the interests are broader in geographic scope: regional, national,
and even global.
Principle #3: To discourage waste, prices for the use of environmental resources shouldreflect the full costs and benefits to the economy, exclusive of subsidies.
Principle #4: Given their stewardship responsibilities regarding the environment, it isappropriate for governments to encourage or undertake activities that protect
the environment and to discourage or prohibit those that do not. It is also
appropriate for government to own and use land and water resources to5

protect the environment and to support others who desire to own and use
resources for the same purpose.
Principle #5: Governments should continually seek to improve the efficiency of theirenvironmental- and resource-management programs without compromising
their responsibilities. These programs may include a mixture of regulations,
incentives, and public ownership of resources. They should aim to bring about
as high a level of environmental quality as possible for a given expenditure.
Principle #6: To understand the full, potential economic consequences of a pending
resource-management decision, one should consider the potential reversal
costs if the decision should yield undesirable outcomes.
Principle #7: The benefits and costs of environmental protection and degradation fall
unevenly on different groups. Anticipating and mitigating these effects can
reduce the controversies over the West’s environment and economy. Having
the winners compensate the losers, for example, could serve this principle.
Principle #8: Owners of natural resources have both rights and responsibilities. Bothprivate- and public-property owners have rights to use their properties inways that do not unreasonably harm others or restrict their rights. Clarifying
and respecting the rights of all parties—including future
generations—affected by the uses of environmental resources remains anecessary condition for effective environmental management.

Conclusion
We are not saying that resource-intensive industries (agriculture, timber, commercial
fishing, and mining) do not play an important role in the West’s economies. They areimportant today, and we expect they will remain important in the future.
We are not saying that the shift away from industries and activities harmful to theenvironment will not hurt some workers, families, and communities. It has in the past andit will in the future.
We are not saying that protecting and improving the environment can be accomplishedwithout costs, nor are we saying that governmental entities should disregard such costs. To
the contrary, we are calling for consideration of the full range of costs and benefits ofpolicies, decisions, and activities that affect the western environment and, hence, its
economy.
We are not saying that no progress is being made in capitalizing on the link between
environmental health and economic prosperity. Many private-sector firms and publicagencies have taken actions to reduce their negative impact on the environment and foundthat they saved money.

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Rather, we are saying that nearly all communities in the West will find they cannot havea healthy economy without a healthy environment. Moreover, there exist many
opportunities in the West to improve both the environment and the economy, for example,
the elimination of inefficient subsidies would make more money available for other public
services or to reduce debt. The longer these opportunities languish, the fewer will be theWest’s jobs, the lower its incomes, and the poorer its communities. Conversely, the sooner
we seize these opportunities, the sooner the West will enjoy more jobs, higher incomes, andgreater prosperity.
We are saying that the economic pressures to arrest and reverse environmental
degradation will increase. Those who promise that workers, firms, and communities tied toenvironmentally harmful activities can avoid these pressures if only the environmental
laws, such as the Endangered Species Act, were set aside raise false hopes. The pressures
are independent of specific laws. Even if such laws are repealed, the costs ofenvironmentally harmful activities will continue to rise and jeopardize the economic
outlook for affected communities. Public officials can best promote long-run economic
prosperity in the West by encouraging efficient transitions away from harmful activities
toward those beneficial to both the environment and the economy.
We are requesting that you recognize the important role the environment plays inwestern economies and take the steps we’ve identified to strengthen these economies byprotecting and enhancing the quality of the region’s natural environment.
Sincerely and respectfully,
The following individuals have endorsed the contents of this letter. Institutional references
are provided for identification only.

State
ArizonaName, institutional affiliation
Bonnie G. Colby, The University of Arizona
Dennis Cory, University of Arizona
Ron Trosper, Northern Arizona University

California

Dennis J. Aigner, University of California, Santa Barbara
Kenneth J. Arrow, Stanford University
Ted Bergstrom, University of California, Santa Barbara
Christopher Costello, University of California, Santa Barbara
Robert Deacon, University of California, Santa Barbara
Stephen J. DeCanio, University of California, Santa Barbara
Anthony Fisher, University of California, Berkeley
Lawrence Goulder, Stanford University
Steve Hackett, Humboldt State University
Michael Hanemann, University of California, Berkeley

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Amy Horne, Sierra Business Council
Daniel Ihara, Center for Environmental Economic Development
Charles Kolstad, University of California, Santa Barbara
Stephan Kroll, California State University, SacramentoPeter Kuhn, University of California, Santa Barbara
Carol McAusland, University of California, Santa Barbara
John M. Marshall, University of California, Santa Barbara
Wade E. Martin, California State University, Long Beach
Roger Noll, Stanford University
Richard B. Norgaard, University of California, Berkeley
Kenneth Small, University of California at Irvine
David Starrett, Stanford University

Colorado

Lee J. Alston, University of Colorado
Janis M. Carey, Colorado School of Mines
Katherine Carson, Affiliation: United States Air Force Academy
Brad Crowder, U.S. Environmental Protection Agency
Graham A. Davis, Colorado School of Mines
Nicholas Flores, University of Colorado
Philip E. Graves, University of Colorado
Marie Leigh Livingston, University of Northern Colorado
John Loomis, Colorado State University
Pete Morton, The Wilderness Society
Jennie Spelman Rice, Consulting Economist
Linda Stanley, Colorado State University

Idaho

Joel Hamilton, University of Idaho
Peter M. Lichtenstein, Boise State University
Christine Loucks, Boise State University
Gundars Rudzitis, University of Idaho
Tesa Stegner, Idaho State University
Robert Tokle, Idaho State University

Montana

Richard Barrett, University of Montana
Douglas Dalenberg, University of Montana
Tom Power, University of Montana
Ray Rasker, Sonoran Institute and Montana State University

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NevadaMary Riddel, University of Nevada, Las Vegas
Kimberley Rollins, University of Nevada, Reno
Douglass Shaw, University of Nevada, Reno

New Mexico

Robert Berrens, University of New Mexico
Alok K. Bohara, University of New Mexico
Chris Nunn Garcia, New Mexico Highlands University
Kristine M. Grimsrud, University of New Mexico
Tom McGuckin, New Mexico State University

OregonRandall Bluffstone, Portland State University
Trudy Ann Cameron, University of Oregon
Tom Carroll, Central Oregon Community College
Kimberly A. Clausing, Reed College
Ronald B. Davies, University of Oregon
David Ervin, Portland State University
Eban Goodstein, Lewis & Clark University
Joe Kerkvliet, Oregon State University
K. John McConnell, Oregon Health & Science University
Don Negri, Willamette University
Noelwah Netusil, Reed College
Ernie Niemi, ECONorthwest
Arthur O'Sullivan, Lewis & Clark College
Andrew J. Plantinga, Oregon State University
Carl M. Stevens, Reed College
Ed Whitelaw, University of Oregon

Utah

Arthur Caplan, Utah State University
Therese Grijalva, Weber State University
Robert J. Lilieholm, Utah State University

Washington

Gardner Brown, University of Washington
Ken Casavant, Washington State University
Dan Hagen, Western Washington University
Steve Henson, Western Washington University
Hart Hodges, Western Washington University
Ray Huffaker, Washington State University

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Karin Sable, University of Puget Sound
Kate Stirling, University of Puget Sound
Norm Whittlesey, Washington State University

Wyoming

David Aadland, University of Wyoming
Ed Barbier, University of Wyoming
Tom Crocker, University of Wyoming
Robert W. Godby, University of Wyoming
Jason Shogren, University of Wyoming
John Tschirhart, University of Wyoming

Other states

Daniel Bromley, University of Wisconsin
Dallas Burtraw, Resources for the Future
Ujjayant Chakravorty, Emory University
Paul N. Courant, University of Michigan
Ronald Cummings, Georgia State University (Univ. New Mexico, emeritus)
Robert Haveman, University of Wisconsin-Madison
Thomas S. Jayne, Michigan State University
Matthew Martin, Economy.com
Kenneth E. (Ted) McConnell, University of Maryland
Michael R. Moore, University of Michigan
Rodney B.W. Smith, University of Minnesota
Robert Solow, Massachusetts Institute of Technology
John Sorrentino, Temple University Ambler
Ivar Strand, University of Maryland
Dave Tschirley, Michigan State University

For information about this paper, please send inquiries to:
Ed Whitelawth
c/o 99 W. 10 Avenue, #400
Eugene, Oregon 97401
phone: 541-687-0051
email: whitelaw@eugene.econw.com

Please cite this paper to Ed Whitelaw, editor.

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