Background
The Clearwater National Forest has recently completed a forest-wide assessment of the need for outfitted fishing. The process was prompted by outfitter interest in providing fishing services or markedly expanding them in areas where they had been small-scale activities in the past.
In the context of a needs assessment, the word need has a specific definition. It is the Forest Service's need to fulfill it's mission. Part of that mission is allowing the Forests to be accessible to a diverse range of customers, and balancing activities with the recreation and resource capability of lands and waters. Outfitters have long been partners with the Forest Service in fulfilling that mission but the Forest Service has the responsibility and the authority to determine where outfitted services are needed to do so. That determination is made through a needs assessment.
Summary Results of the Needs Assessment
Outfitted fishing is currently permitted on 36 lakes and 247 miles of stream. The assessment concluded that with one exception, outfitted 
fishing was warranted on all lakes and streams where outfitted fishing is currently permitted. The assessment identifed 51 lakes and 378 miles of streams (including those currently outfitted) with a potential need for outfitted fishing services. The assessment also concluded that there is no need for outfitted fishing services on 456 miles of streams.
The Assessment Process
The assessment evaluated 74 lakes and 834 miles of streams known to have fish populations and considered to have some potential for fishing interest. Click on the map below for a more detailed map. (443K pdf)
Each stream and lake was scored against four different criteria and the scores totalled. Total scores above a certain minimum score were considered to have potential need for outfitted services. Total scores were then compared to several different screening criteria to see if these would affect the final call.
Needs Assessment Detailed Results
| Final Needs Assessment Document 436K pdf |  |
| Streams Table 61K pdf | |
| Lakes Table 57K pdf | |
| Existing Outfitted Fishing Map 774K pdf | |
| Outfitted Fishing Needs Map 773K pdf | |
| Streams and Lakes Assessed |
What Happens Now
The Clearwater National Forest will consider proposals for new or increased outfitted fishing service levels only on those streams and lakes where a need has been identified in the Needs Assessment. Then the Forest will complete future steps of determining total fishing capacity in the proposal area, and making an allocation of that capacity between outfitted and non-outfitted anglers. Proposals will be evaluated by the Forest and the Idaho Outfitter and Guide Licensing Board (IOGLB) according to existing policy established between the Forest Service and the IOGLB. Proposals and reasonable alternatives will be analyzed in a site specific National Environmental Policy Act (NEPA) analysis that includes opportunity for public comment.
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Clearwater NF Home |
Frequently Asked Questions
| Why did the Clearwater National Forest complete an assessment of the “need” for outfitted fishing? | |
| What gives the Forest Service the authority to regulate commercial use of public lands? Undertake a needs analysis? | |
| Is a NEPA analysis required for a Needs Assessment? | |
| Is the Needs Assessment subject to appeal? | |
| How did the Forest arrive at the definition of need used in the assessment? | |
| Who were the focus groups and how did you choose them? | |
| For need to really be met shouldn’t there be outfitted fishing in every recreational setting since there are some people who really do need expert assistance in even the most highly developed settings? | |
| Why are outfitters considered partners in helping the Forest Service fulfill its mission of public service? | |
| What about people who would just rather go with an outfitter to avoid all the hassle of bringing gear, setting up camp, cooking etc? | |
| It seems like most other major streams and rivers in developed recreation settings around Idaho and the Northwest offer outfitted fishing. Why would a needs assessment on the Clearwater conclude the service was not needed on similar streams here? | |
| 11. How does the assessment address the relationship between fishing and diversification of the economy in Central Idaho? | |
| How was historical use by existing outfitters addressed? | |
| Doesn’t fishing with an outfitter provide an angler with a better chance of catching a fish? | |
| Why is the Forest doing a Forest-wide assessment when only a few outfitters have asked for increases? | |
| What direction requires the agency to provide non-outfitted areas in order to provide a diverse range of opportunities? | |
| If an area is legally open to fishing and no resource damage is occurring, why would the Forest Service limit access to outfitted anglers? | |
| What is the difference between a state outfitter license and a federal outfitter permit? | |
| If an outfitted client has a valid general fishing license, can they fish “on their own” without their outfitter’s assistance? | |
| Does Forest Service policy limit the role of outfitters to providing a public service in back-country or other inaccessible settings? | |
| What is the relationship between the Needs Assessment and the Selway-Bitterroot Wilderness General Management Direction (SBW GMD)? | |
| Are outfitted fishing opportunities handled differently inside a designated wilderness area? | |
| Does the assessment discriminate against outfitted anglers by concluding there is no need for outfitted fishing in the roaded and most accessible areas of the Forest? | |
| Does the Selway-Bitterroot Wilderness General Management Direction (SBW GMD) preclude outfitted fishing in Wilderness? |
1. Why did the Clearwater National Forest complete an assessment of the “need” for outfitted fishing?
There are two reasons the Forest decided to complete a needs assessment. First, our local outfitters were interested in diversifying their businesses by offering fishing as a primary activity or increasing the amount of fishing they offer. While some outfitters have provided limited levels of outfitted fishing in the past, this use has generally been intermittent and secondary to other activities like big game hunting or summer pack trips. Traditionally, each outfitter had a “pool” of service days which were used for hunting a variety of big game animals. In the last few years, some outfitters have begun advertising fishing as a primary activity and using more of their total service days for guided fishing. Several additional outfitters on the Clearwater Forest have expressed an interest in providing guided fishing trips. This interest in providing additional commercial use on National Forest lands triggered an assessment of the need for such activity. The second reason is because we have a responsibility to evaluate whether there is a need for any commercial use that is proposed on National Forest lands (FSM 2712.2) (see Appendix E for additional discussion).
2. What gives the Forest Service the authority to regulate commercial use of public lands? Undertake a needs analysis?
The Code of Federal Regulations (261.10(c)) prohibits “selling or offering for sale any merchandise or conducting any kind of work activity or service unless authorized by Federal law, regulation, or special-use authorization”. A special-use permit is required when any individual or organization (including institutional and nonprofits) are conducting outfitting and guiding activities or services for gain on National Forest lands. The Forest Service Manual (2712.2) states that a permit may be issued when there is a demonstrated need for the proposed service. This document represents the required agency analysis of the need for outfitted fishing on the Clearwater National Forest.
3. Is a NEPA analysis required for a Needs Assessment?
No. An assessment is the written documentation of an agency analysis that reviews existing resource or social conditions within the context of applicable laws and regulations as well as appropriate agency policy and direction. The outcome of an assessment is generally an identification or recommendation of opportunities that exist for some activity. As an example, the Clearwater Forest has completed several resource assessments, called Ecosystem Analysis at a Watershed Scale or EAWS, which compare existing resource conditions to desired conditions and identify opportunities for some activity in the watershed to achieve the desired objectives. These EAWS assessments simply identify the possible opportunities that would meet direction, policy, and objectives in a specific area. The EAWS doesn’t include the analysis of environmental effects of a site-specific proposal required by NEPA.
Similarly, the purpose of this Needs Assessment was to examine existing law, regulation, policy, and direction regarding commercial use of National Forest lands and identify where a need exists for commercial outfitted fishing. The outcome of this assessment is a list of stream segments where an opportunity has been identified for outfitted fishing, not a decision to allow fishing to occur. This assessment fulfills the National Forest Management Act (NFMA) portion of the analysis process. If a proposal to provide new or additional (above existing use) outfitted services on any of the identified streams is received, a NEPA analysis of the specific proposal would be completed prior to issuance of a special-use permit for that activity.
4. Is the Needs Assessment subject to appeal?
As described in the previous question, the outcome of the Needs Assessment is a list of opportunities for outfitted fishing, not a site-specific NEPA decision. Since no NEPA decision exists, the assessment is not subject to appeal. Any decision resulting from the NEPA analysis of a proposal for outfitted fishing on a specific stream would be subject to appeal.
5. How did the Forest arrive at the definition of need used in the assessment?
In preparation for completing this Needs Assessment we relied heavily upon the Outfitter–Guide Administration Guidebook (1997), which describes need and the factors that may be used to evaluate need. This Guidebook was developed with extensive involvement from representatives of the outfitting industry. We also reviewed numerous needs assessments completed by other Forests in several different Forest Service Regions. There are several different ways to define “need” - for further discussion refer to Appendix E.
6. Who were the focus groups and how did you choose them?
The Clearwater National Forest used two focus groups, one involving general public interests and the other including federal and state agencies and the Nez Perce Tribe. Members of the public focus group were selected to represent a variety of public interests:
- Fishing interests on a national or broad scale
- Fishing interests that are local (both outfitted and non-outfitted)
- River & stream users who aren’t necessarily involved in just fishing
- River & stream conservation and habitat interests
- Local environmental interests
The second group included the Nez Perce Tribe and regulatory agencies including the Idaho Department of Fish and Game, US Fish and Wildlife, NOAA Fisheries, and the Idaho Outfitters and Guides Licensing Board.
7. For need to really be met shouldn’t there be outfitted fishing in every recreational setting since there are some people who really do need expert assistance in even the most highly developed settings?
Undoubtedly there are people with little or no fishing skill and no equipment who desire to try their hand at fishing, and they should have the opportunity to have expert assistance somewhere. The key word is somewhere. Every possible client need does not have to be met in every recreational setting or stream for the overall need to be met. Highly developed recreation settings with outfitted fishing services are available on many rivers in Idaho and adjacent states all of which are within the range that people regularly travel to find their desired fishing experience.
8. Why are outfitters considered partners in helping the Forest Service fulfill its mission of public service?
The Forest Service’s R-1 Outfitter Policy Task Force stated in the report, “Partnerships for the Future” (1989, page 16) that, “From the Agency perspective, the outfitting industry is needed to provide certain recreational experience on the National Forests, particularly to people who have neither the skill nor the resources to provide the experience on their own. It is important to understand the definition of ‘partnership’ as used in this context. The partnership envisioned is the effort to jointly ensure that quality recreational opportunities are provided on public lands to the segment of the public which requires outfitted services. It is not an arrangement with the outfitting industry which provides special privileges or which reserves an inappropriate share of public land opportunities for guided clients. Permit holders are partners with the Forest Service to provide services to the public, protect public health and safety, and maintain the natural resources of the Forest.”
9. What about people who would just rather go with an outfitter to avoid all the hassle of bringing gear, setting up camp, cooking etc?
We recognize there are many folks who have the resources and desire to pay an outfitter simply because it is more convenient. However, while we acknowledge that an outfitter can provide this service, we don’t believe that convenience equates to a “need” for that service, or that it’s necessary for that service to occur on public lands.
10. It seems like most other major streams and rivers in developed recreation settings around Idaho and the Northwest offer outfitted fishing. Why would a needs assessment on the Clearwater conclude the service was not needed on similar streams here?
This question essentially answers itself. The availability of this outfitted opportunity regionally, well within the range that anglers travel to go fishing, indicates that this need is met. In contrast, it is very difficult to find a major stream or river in the region with easy road access that does not include outfitted fishing. The need for this recreational experience is not met elsewhere and should be provided on the Clearwater National Forest for that reason. For additional information, refer to the Needs Assessment discussion of Evaluation Criteria–Regional Availability (D. 3(f)).
11. How does the assessment address the relationship between fishing and diversification of the economy in Central Idaho?
Diversification of the economy is an important issue and outfitters certainly contribute substantially to the local economy. Direction in the R1 Outfitter–Guide Guidebook is specific about how business viability should be considered in needs assessments; the agency’s concern for viability should be to manage the availability of outfitted services and to see that they are distributed between a reasonable number of holders. This direction indicates the business viability is more an issue of capacity than of “need”. We also found using economic benefit as a criterion wasn’t effective because the rating didn’t differ by location or stream segment and therefore, didn’t assist in the determination of need. Accordingly, we did not use business viability as an evaluation criterion to determine need in this assessment.
12. How was historical use by existing outfitters addressed?
Some outfitters were never “permitted” specifically for the activity of fishing. For most outfitters, fishing occurred as a secondary activity and was always part of another use. There was a time period of confusion between being permitted (by the Forest Service) and licensed (by the State), and this fishing may have gone on until that confusion was cleared up, but fishing was never actually a permitted activity, so we couldn’t “take it away”. The State of Idaho started licensing in 1984 and during this time period (‘84 to ‘95) some outfitters may have been fishing as a secondary activity, but fishing was not included as a primary activity on their Forest Service permit. The level of historical use has been documented in some cases, see the description titled “Existing Outfitted Use” (D. (3. g)) in the Assessment.
13. Doesn’t fishing with an outfitter provide an angler with a better chance of catching a fish?
That may be why a person decides to use an outfitter, but it isn’t the reason the Forest Service authorizes outfitter use on federal lands. An outfitted individual may have a higher success rate than a non-outfitted individual. However, the reason the Forest Service partners with outfitters is to accomplish the agency mission to provide access to recreation opportunities on National Forests, not to increase the chance of success.
14. Why is the Forest doing a Forest-wide assessment when only a few outfitters have asked for increases?
Several outfitters across the Forest have expressed interest in providing outfitted fishing as a primary activity and increasing their marketing efforts to attract clients interested in guided fishing trips. This means fishing would be added to the permits of some outfitters, while others would request a significant increase in the number of fishing service days on their permits. It seemed prudent to us at this time, to evaluate where these activities were appropriate across the Forest and at what levels. By completing this Needs Assessment now, we can allow these new and expanded opportunities to occur at appropriate locations and use levels, with less risk of having to “move” or restrict use levels at a later date.
15. What direction requires the agency to provide non-outfitted areas in order to provide a diverse range of opportunities?
There is no regulation requiring us to provide non-outfitted areas to achieve a diverse range of recreation opportunities. However, our mission, the Clearwater Forest Plan, and other documents all discuss providing a range of recreational opportunities. Comments we received from members of the public and our partner agencies during this analysis (and previous analyses completed on this Forest) supported the concept that the public desires areas free from competition with commercial outfitters on National Forest lands.
16. If an area is legally open to fishing and no resource damage is occurring, why would the Forest Service limit access to outfitted anglers?
There are several reasons why the Forest Service might limit access to outfitters in a certain area. One reason would be if there was no need identified for commercial services in that area. Another reason might be specific direction in the Forest Plan or other applicable management direction which states that outfitted use is not appropriate because of some resource or social objective. Some people have expressed the opinion that the outfitted service must be available in every recreational setting and even on every stream a person might desire to fish for the public to be considered as having access to an outfitter. We don’t believe that was the intent. We believe a logical interpretation of this statement is that the public is not deprived of access to an outfitter just because stream A is not outfitted when outfitted services are available on stream B within a reasonable travel distance. Nonetheless, some people definitely need an outfitter more than others, and a greater percentage surely need an outfitter in more difficult recreation settings.
17. What is the difference between a state outfitter license and a federal outfitter permit?
The State of Idaho requires any individual providing outfitting services to obtain a license from the Idaho Outfitter and Guides Licensing Board (IOGLB). This license documents that an outfitter has met the state licensing requirements for training, insurance, financial procedures, background checks, etc. The state outfitter license lists which services the outfitter is authorized to provide and where in the state the outfitter may provide them. If an outfitter plans to provide any outfitting services on National Forest lands, that use must be authorized through a Forest Service special use permit. The special use permit, much like the state license, documents that an outfitter has met the federal requirements for outfitters, which services the outfitter is authorized to provide, the amount of those services allowed, and the specific locations on a National Forest where the services may occur. If an outfitter is providing a service on National Forest lands within the State of Idaho, they must have both a state outfitter license and a federal special use permitauthorizing them to provide that specific service in that location.
18. If an outfitted client has a valid general fishing license, can they fish “on their own” without their outfitter’s assistance?
No. An outfitter must insure that their clients abide by the conditions contained in the special use permit. Outfitters may only provide the services authorized in their permit at the locations specified in the permit. If the outfitter is not authorized for fishing, the outfitter must insure their clients don’t fish while in the outfitter’s care (i.e., staying in the outfitter’s camp, being transported by vehicle or horseback, participating in some other authorized activity with the outfitter, etc.).
19. Does Forest Service policy limit the role of outfitters to providing a public service in back-country or other inaccessible settings?
There is no policy limiting all outfitters to providing services in back-country or otherwise inaccessible settings. The streams and lakes identified in this assessment as having a need for outfitted services are generally considered to be in back-country settings. However, that outcome is a function of the public input, evaluation criteria, and analysis completed for this assessment which focused completely on outfitted fishing (primarily walk and wade fishing). The same outcome wouldn’t necessarily be expected, if an entirely different activity were being evaluated. An example would be the activities associated with the Lewis & Clark Bicentennial planning on the Clearwater Forest, where van tours and other activities are taking place in what is considered the “front” country. The results are driven by the public input, the criteria developed, and the activity being evaluated.
20. What is the relationship between the Needs Assessment and the Selway-Bitterroot Wilderness General Management Direction (SBW GMD)?
The SBW GMD is part of the Clearwater National Forest Plan. It defines uses and experiences expected in each of 4 opportunity classes across the wilderness. This opportunity class direction is most applicable to the Needs Assessment where it defines expected levels of use and types of experiences wilderness visitors can expect in each of the opportunity classes. This is additionally explained in Appendix D: Wilderness Direction. Section M of the SBW GMD (Land Occupancy-National Forest Lands) provides specific management direction for outfitters operating under special use permits in the wilderness. This direction is primarily focused at the project specific evaluation phase where site-specific proposals for new outfitter and guide applications or changes in existing operations are evaluated. The direction found in Section M would be most applicable at the NEPA Analysis step.
21. Are outfitted fishing opportunities handled differently inside a designated wilderness area?
Only to the extent that additional management direction for wilderness is contained within the Forest Plan. In the Selway-Bitterroot Wilderness permitted commercial services need to be consistent with opportunity class definitions and direction (see additional information in Appendix D: Wilderness Direction).
22. Does the assessment discriminate against outfitted anglers by concluding there is no need for outfitted fishing in the roaded and most accessible areas of the Forest?
The question presumes that the outfitted angler is incapable of functioning in the accessible setting without assistance, which is rarely true. The Forest Service responsibility is to ensure that anglers with a broad range of skills have an opportunity to fish somewhere. “Somewhere” is not limited to the Clearwater Forest and opportunities abound for outfitted fishing in a developed setting on adjacent National Forests as well as outside National Forest lands.
23. Does the Selway-Bitterroot Wilderness General Management Direction (SBW GMD) preclude outfitted fishing in Wilderness?
No, the Clearwater National Forest plan, SBW GMD provides clear direction that outfitted uses are an appropriate use of wilderness. In fact Section M of the SBW GMD provides specific direction for outfitters operating within wilderness under special use permits. However, as noted in Questions 20 & 21 above these uses need to be managed to provide consistency with the opportunity class direction for the Selway-Bitterroot Wilderness (see additional information in Appendix D: Wilderness Direction).
The Selway Bitterroot Wilderness is characteristically known for its extremely rugged topography where craggy rock peaks, void of vegetation, and extremely steep terrain make the majority of the landscape topographically self-limiting for most visitors. This representation of the Selway-Bitterroot Wilderness, Opportunity Class 1 areas describes almost 98% of the landscape. The high mountain lakes and streams located in these rugged areas account for only an extremely small fraction of the land base comprising Opportunity Class 1 areas.
