Watershed Protection Advocates Release Report Card on State Aquatic Invasive Species Program
By Moosetrack Megan

Posted: April 11, 2019

 

Watershed Protection Advocates Release Report Card on State Aquatic Invasive Species Program

Watershed Protection Advocates (WPA) was established in 2018 to protect and conserve the natural resources of Northwest Montana.  To further our mission, WPA is releasing a State Aquatic Invasive Species (AIS) Report Card related to Montana’s 2018 field season results.


The purpose of this Report Card is to identify areas in need of improvement to safeguard the integrity of the headwaters of the Columbia River ecosystem from the threat of aquatic invasive species.  Protecting the current mussel-free status of the Flathead River system has become increasingly urgent.  If we fail to take immediate corrective actions, it is almost guaranteed that invasive mussels will colonize not only the last mussel-free watershed in the continental U.S., but also other waters that are currently mussel-free in the State of Montana.

 

It is important to note that this Report Card does not advocate for a reduction in funding for state agencies to implement the AIS program.  Rather, our goal is to maintain or increase funding levels, and ensure that the funding allocated by the legislature is well-spent and subject to both oversight and transparency.

 

This Report Card is designed to highlight programmatic shortfalls in order to address these deficiencies during the 2019 legislative session and facilitate programmatic changes at the agency level.  The analysis does not cover every aspect of the state’s AIS program but focuses on key areas to shed light on long-standing issues which merit correction.

 WPA recognizes the numerous improvements made by Fish, Wildlife and Parks to the AIS prevention program over the last two years.  However, further improvements are urgently needed to further protect the Columbia Basin ecosystem. It is our hope that by highlighting areas in need of improvement, the program can be made to function more effectively and efficiently.  See the attached report for documentation related to the findings below.

Key Findings include:

 

  • Season of operation and hours of operation at the vast majority of watercraft inspection stations (WIS) are insufficient to provide levels of protection needed to prevent further mussel introductions in the State of Montana;

 

  • Watercraft inspectors at many, though not all, stations are poorly trained and managed, resulting in many of the highest risk boats being inadequately inspected prior to launching in Montana waters;

 

  • The state should be applauded for the introduction of an electronic database to record WIS data, however, its application and on-the-ground use indicates that the database entry process is currently fraught with error which makes tracking trends difficult, if not impossible;

 

  • Inspection of high-risk boats is lacking, resulting in many high-risk boats launching in Montana waters without being adequately inspected

 

  • In 2018, mussel-fouled watercraft were detected at only a small number of WIS operating throughout Montana, which may indicate that not all mussel-fouled boats are being detected prior to launch.

 

Grade:  C-

 

Priority Recommendations Include:

 

  • Via the 2019 state AIS biennium budget and other measures, ensure Watercraft Inspection Stations operate at full capacity

  

After 8+ years of FWP management, inspection stations, and perimeter stations in particular, continue to suffer from (a) lack of infrastructure; (b) insufficient season/days/hours of operation resulting in reduced levels of protection for Montana waters; (c) staffing shortages and (d) lack of enforcement presence.   Two recommendations could be implemented to begin to correct these issues:

 

  • allocate funds directly to MDT for the operation of border inspection stations at ports of entry and weigh stations.
  • allocate FWP funding for specific WIS, along with a stated minimum season and hours of operation.

 

  • Via the 2019 state AIS biennium budget, provide for independent oversight to address program deficiencies

 

Provide funding for the Environmental Quality Council (EQC) to hire independent contractor(s) to ground truth conditions during the field season and review existing protocols.  At a minimum, two reports should be made to EQC each year – one early in the season to remedy deficiencies, and the second at the end of the season to determine how/if the agencies remedied identified deficiencies.

 

 

 

Watershed Protection Advocates of Northwest Montana

AIS Program Analysis and Report Card

2018 Field Season

 

April 8, 2019

Executive Summary, Part I

Watershed Protection Advocates (WPA) conducted a review of the State of Montana’s Aquatic Invasive Species (AIS) prevention program in the fall of 2018 and winter of 2019.  This report summarizes the key findings from this analysis.  Results of the review include but are not limited to the following: watercraft inspection stations (WIS); containment; monitoring and rapid response.  Part I of the assessment focuses exclusively on WIS management and operations.

 

The purpose of this Report Card is to identify areas in need of improvement to safeguard the integrity of the headwaters of the Columbia River ecosystem.  Protecting the current mussel-free status of the Flathead is time sensitive.  If we fail to take immediate corrective actions, it is almost guaranteed that invasive mussels will colonize the last mussel-free watershed in the continental U.S., as well as other waters that are currently mussel-free in the state.

It is important to note that this Report Card in no way advocates for a reduction in funding for state agencies to implement the AIS program.  Rather, our goal is to work to maintain or increase funding levels, but at the same time ensure that the funding allocated by the legislature is well spent and subject to both oversight and transparency.

 

This Report Card is designed to highlight programmatic shortfalls in order to address these deficiencies (1) during the 2019 legislative session; and (2) to facilitate programmatic changes at the agency level.  The analysis does not cover every aspect of the state’s AIS program but focuses on key areas to shed light on long-standing issues which merit correction.

While WPA recognizes that the Fish, Wildlife and Parks has made numerous improvements to the AIS prevention program over the last two years, further improvements are urgently needed in order to protect the Columbia Basin ecosystem from an invasive mussel introduction.  It is our hope that by highlighting areas in need of improvement, the program can be made to function more effectively and efficiently, thereby protecting those aquatic resources now at risk.  See the attached report for documentation related to the findings below.

 

Key Findings include:

 

  • Season of operation and hours of operation at the vast majority of watercraft inspection stations (WIS) are insufficient to provide levels of protection needed to prevent further mussel introductions in the State of Montana;

 

  • Watercraft inspectors at many, though not all, stations are poorly trained and managed, resulting in many of the highest risk boats being inadequately inspected prior to launching in Montana waters;

 

  • While we applaud the introduction of an electronic database to record WIS data, its application and on-the-ground use indicates that the database entry process is currently fraught with error which makes tracking trends difficult if not impossible;

 

  • Inspection of high-risk boats is lacking, resulting in many high-risk boats being launched which without adequate inspection

 

  • In 2018, mussel-fouled watercraft were detected at only a small number of WIS operating throughout Montana, which may indicate that not all mussel-fouled boats are being detected prior to launch.

 

Grade:  C-

 

Priority Recommendations Include:

 

  • Via the 2019 state AIS biennium budget and other measures, ensure Watercraft Inspection Stations operate at full capacity

 

After 8+ years of FWP management, inspection stations, and perimeter stations in particular, continue to suffer from (a) lack of infrastructure; (b) insufficient season/days/hours of operation resulting in reduced levels of protection for Montana waters; (c) staffing shortages and (d) lack of enforcement presence.   Two recommendations could be implemented to begin to correct these issues:

 

  • allocate funds directly to MDT for the operation of border inspection stations at ports of entry and weigh stations.
  • allocate FWP funding for specific WIS, along with a stated minimum season and hours of operation.

 

  • Via the 2019 state AIS biennium budget, provide for independent oversight to address program deficiencies

 

Provide funding for the Environmental Quality Council (EQC) to hire independent contractor(s) to ground truth conditions during the field season and review existing protocols.  At a minimum, two reports should be made to EQC each year – one early in the season to remedy deficiencies, and the second at the end of the season to determine how/if the agencies remedied identified deficiencies.

 

  • Promote and Enhance Inspector Training and Oversight

 

Additional training for inspectors in the pre-season, on-going training during the season, more robust quality control and management oversight are needed to ensure all stations function in an optimal fashion.

 

 

 

 

AIS Program Analysis Introduction         

The purpose of this analysis is to identify areas in need of improvement to safeguard the integrity of the headwaters of the Columbia River ecosystem.  Protecting the current mussel-free status of the Flathead is time- sensitive.  If we fail to take corrective actions in short order, it is almost guaranteed that invasive mussels will colonize the last mussel-free watershed in the continental U.S.  We bear a grave responsibility, and the impacts of failing to succeed will be life-altering for the people and species calling the northwest home.

Before proceeding, this analysis in no way advocates for a reduction in funding for state agencies to implement the AIS program.  Rather, we support maintaining or increasing current funding levels.  We recognize that over the past two years, improvements have been made to the State’s AIS program, including but not limited to:  an increase in the number of inspections undertaken annually; the introduction and use of tablets at all inspection stations to record data in real time; the introduction of “passports” to enhance station efficiency and boater compliance; and a heightened willingness and ability to pursue working partnerships with tribal governments, counties, conservation districts and other interested stakeholder groups.  All of this represents significant and positive changes as compared to previous program management.

However, our hope is that by highlighting areas in need of further improvement, the program can be made to function more effectively and efficiently, thereby protecting those aquatic resources now at risk.  During the legislative session, many stakeholders feel compelled to gloss over unpleasant facts and bury data that is less than positive in order to preserve funding.  However, the refusal to confront programmatic challenges do not make them disappear, and improvements are impossible without bringing to light the issues that have plagued the program for almost a decade.   The code of silence which prevails during the legislative session has not led to the robust program that we hoped to achieve when the first AIS legislation was approved in 2009.

Moreover, many of the same issues appear year after year, with apparently little incentive to correct deficiencies once the legislators return home. Simply put, we are running out of time, and can no longer be remain silent to safeguard funding that in many cases has been poorly spent.  While FWP has implemented some positive changes in the last two years, there is no room for error or shortfalls.  An urgent need for further improvements exists.  Our goal is to work to maintain existing funding but ensure that the funding allocated by the legislature is well-spent and subject to both oversight and transparency.

It should be noted that the Confederated Salish and Kootenai Tribes, the Blackfeet Nation, the City of Whitefish/Whitefish Lake Institute and others now play a critical role in protecting key resources in the Columbia Basin headwaters.  However, it is beyond the scope of this analysis to evaluate each of these programs in detail.  Therefore, this Report Card focuses solely on the state agencies currently tasked with AIS program management.

It is virtually guaranteed that the agencies referenced herein will dispute much of what is presented in this analysis, but that is part and parcel of a democratic society.  The agencies are entitled to their dissent.  However, we encourage the readers of this analysis to put politics aside in favor of protecting a unique and precious resource – the headwaters of the Columbia River system.

Purpose:

This Program Analysis is designed to highlight programmatic shortfalls in order to address these deficiencies (1) during the 2019 legislative session; and (2) to facilitate programmatic changes at the agency level.  The analysis does not cover every aspect of the state’s AIS program but focuses on key areas to shed light on long-standing issues which merit correction.

Prevention

Mandatory watercraft inspection stations (WIS) are one of the key prevention tools used by the state.  While WIS can serve as key sentinels in both perimeter defense and at specific water bodies, the usefulness of WIS can be extremely compromised if: stations are not opened early enough in the season; stations fail to remain open later in the season; stations curtail hours of operation; and stations employ poorly trained and/or unmotivated inspectors.  This first section of the analysis examines selected WIS to assess the functionality of both the perimeter defense and Continental Divide prevention efforts.  WIS may also perform containment functions and will be discussed in a later section of the analysis.

Mandatory Watercraft Inspection Station (WIS) Program

The mandatory WIS program is, in theory, designed to protect Monana waters from the threats associated with the introduction of new AIS, and from invasive mussels in particular.  To summarize, the program features four tiers of protection:[1]

  • Perimeter stations — sited to intercept watercraft from out-of-state;
  • Continential Divide stations — sited to intercept watercraft crossing the Divide from the east to the west (Columbia River ecosystem);
  • Containment stations — designed to contain watercraft that exit suspect or fouled waters within Montana (currently Tiber and Canyon Ferry Reservoirs); and
  • Regional stations — designed to protect particular watersheds (i.e. Flathead Basin), Reservations (i.e. Blackfeet Nation, Confederated Salish and Kootenai Tribes); sub-watersheds (i.e. Seeley chain of Lakes); and individual lakes (Whitefish Lake). Regional WIS have generally been operated by partner organizations rather than FWP.

On paper, this configuration makes a great deal of sense and can be tailored to ensure that (1) waters that are not currently infested with invasive mussels remain mussel-free; and (2) areas of unique value with interested stakeholder groups can ratchet up the level of protection for local waters/basins.  However, in order for this prevention program to work as intended, all four tiers must be fully functional.  Unfortunately, as discussed below, systemic failures mean that Montana waters are often completely or partially unprotected from the threat of AIS generally, and of mussels specifically.

 

Season of Operation[2]

As noted by FWP, the number of inspection is 2018 rose dramatically, and the number of inspections stations across the state increase.  This is good new for the prevention effort.  However, the details surrounding inspection station operation as still a matter of concern as the details below illustrate.

Within the State of Montana, the vast majority of perimeter and Continental Divide stations are operated directly by FWP, and all containment related stations at Tiber and Canyon Ferry Reservoirs are operated by this agency.  During the 2019 field season, FWP operated over 15 Class I WIS, multiple decontamination stations and at least one roving inspection station.   Given time and funding constraints, as well as the extreme limitations of the FWP watercraft inspection database, WPA focused on those stations most critical to successful program implementation, including border stations such as Wibaux, and stations sited for containment purposes, such as those at Tiber Reservoir. (See Containment section of this report).

One of the most critical components related to programmatic success centers on the season of operation for each WIS.  Given the relatively small number of mussel-fouled boats detected each year, it is difficult to predict when and where fouled boats will enter Montana.  Therefore, it is critical that the season of operation be extended to reflect watercraft transit patterns.[3] If stations are not open, fouled boats can enter the state unimpeded, carrying unwanted invasive hitchhikers with them.  And given the unpredictability regarding the arrival of fouled boats, stations should be operational based on the travel patterns of the boating public.[4]

In 2018, the season of operation for each Class I WIS operated directly by FWP,[5] indicates that the stations did not open early enough — with opening dates as late as May 18 – and closed earlier than was optimal – approximately 43% of the FWP stations closed the first week in September, see Table 1 below.

Table 1 also shows that the earliest opening occurred on March 31, 2018 (Dillon) and the latest closures occurred on October 14, 2018.  The justification for this March 31 open date is unclear, but it is highly likely that snowbirds returning to Montana from the southwest entered the state with their watercraft prior to the opening date for this WIS.  The question is whether these returning watercraft are launched immediately in Montana waters.  An earlier opening date for Dillon, as well as other perimeter stations is required.

Slightly over 50 percent of the remaining FWP stations opened in May, ranging from May 5-18, 2018.  For most of these stations, a May open date is simply too late, and fails to provide adequate protection for Montana waters.  For example, opening the Nashua station on May 18, 2018, left Montana waters east of the Blackfeet Reservation susceptible to potentially mussel-fouled boats.[6]  It is our understanding that Idaho opens select border stations in February, and Montana should consider earlier season open dates to more fully protect our waters.  Similarly, many WIS closed earlier than optimal, with the earliest closure occuring on September 3rd, and the latest closures occuring on October 14, 2018.

FWP has operated the inspection program as per the State’s AIS statute since 2011, and we are now entering the ninth year of FWP management.  Unfortunately, it appears that the 2019 field sesaon will continue to follow past trends in terms of the season of operations.  As of March 31, 2019, FWP has yet to publish their WIS season/hours of operation.  Moreover, not a single Class I FWP managed station[7] was open by the end of March.[8]  Based on information provided on the FWP website as of April 5, 2019, only four FWP stations will open in April including: Dillon (April 6); Anaconda (April 12); Hardin (April 15) and Wibaux (April 16).  Hours of operation were not posted.   This continued management strategy of delayed opeing dates and limited hours of operation demonstrates a lack of urgency and the need to take corrective action at the legislative level.

 

TABLE 1:  FWP WIS Season and Hours of Operation, 2018

WIS Opening Time[9] Closing Time Opening Date Closing Date Avg. Hrs. of Operation[10]
Nashua

Hwy 2

    5/18 10/14 10
Wibaux

I-94

    4/15 10/14 12
Tongue River

State Park

    4/20 9/9 9
Hardin

I-90

    4/19 10/14 10
Fresno Reserv.

Havre

    5/11 10/14 9
Dillon

I-15

    3/31 10/14 12
Anaconda

I-90

10 am 7 pm 4/6 10/14 14
Sula

US 93

6 am 6 pm 5/11 9/3 14
Lincoln

Hwy 200

9 am (M-Th)

8 am (Fri – Sun)

7 pm (M-Th)

7 pm (Fri – Sun)

4/27 10/14 12
Dena Mora

Saltese

    5/11 9/5 11
Eureka

US 93

8 am 8 pm 5/14 9/4 13
Troy 8 am 8 pm 5/8 9/5 14
Thompson Falls

MT 200

7 am 9 pm 5/8 9/5 15
Helena

Hwy 12

8:30 am (M-Th)

7:30 (Fri – Sun)

7:30 pm (M-Th)

7:30 pm (Fri – Sun)

5/5 10/14 13

Source:  http://cleandraindry.mt.gov/Watercraft-Inspections and FWP Watercraft Inspection Station Annual Report, 2018

Hours of Operation

Similar to the season of operation, the hours of operations are critical to the success of any AIS preven tion program.  With reduced hours of operation comes the risk of fouled watercraft slipping through the established web of protection represented by WIS located throughout the state.  Therefore, the hours of operation for WIS should be extended to the greatest extent possible or a minimum of 16 hours a day,[11] seven days a week during the height of the field season.

Based on Table 1 above, not a single inspection station was open after 9:00 pm.[12]  In the case of the Thompons Falls station which stayed open until 9:00 pm and operated 14 hours a day, the station provided protection 58% of each operational day.  And Thompson Falls was the best case scenario, as the vast majority of stations did not operate 14 hours a day.[13]  The majority of stations operated 12 hours or less each day – providing a maximum of 50% protection each day.

Closing stations by no later than 9:00 pm each day does not adequately protect the aquatic resources at risk.[14]  In comparison, CSKT operates the Ravailli WIS 24-hours per day, and the Blackfeet operate the Browning station 16 hours each day during the height of the field season (Memorial Day through Labor Day).[15]  It is highly likely that boats coming from fouled waters in the southwest, surely passed by the Dillon station after 9:00 pm, and watercraft from the mid-west/Great Lakes passed the Nashua station after it was closed.  The same concern is evident for Contentinal Divide stations, and it is likely that watercraft originating from the destinations east of Montana passed by the Nashua and Hardin stations after 7:00 pm in the month of July.

The patchwork layer of protection is simply inadequate, and will lead to further invasive mussel infestations.  At best, perimeter stations are generally providing protection 50% of the time for each operational day during the height of the field season.  Even if the agency asserts that operation from midnight to 5:00 am each day is unneccesssary, the program is missing almost 30% of the operational hours each day.[16]

In reviewing the average hours of operation for each station, the average hours do not seem to reflect the realities on-the-ground.  Based on existing threats, Montana’s southern and eastern borders should be the most heavily protected.  In other words, the hours of operation at Nashua, Wibaux, Hardin and Dillon should be the highest in the State.  Yet these stations operated a maximum of 10-12 hours per day.  Conversely, Thompson Falls and Troy operated 14-15 hours per day.  Funding and staffing should be deployed based on threat levels and boating patterns.

Moreover, it would appear that the stated hours of operation at times differed from actual hours of operation listed.  For the purpose of this report,  we used Wibaux as a case study due to its important for intercepting east-west boating traffic.   We inferred the hours of operation for Wibaux by looking at the time of first and last inspections for each day of the month in July 2018.  While it was difficult to estimate the exact hours of operation for the Wibaux station[17], it appears that the station was never opened earlier than 7:30 a.m. and sometimes the first inspection did not occur until after 9:30 (and as late as 11:17).  It appears that the last inspections of the day were usually between 5:00 to 6:30 p.m, but occurred before 4:30 p.m. about one third of the days.  On Saturdays — which are generally considered higher traffic boating days — final inspections occurred from 1:43 to 4:23 p.m, see Table 2.

Based on these numbers it would appear that the Wibaux station was generally operational at maximum of 11 hours per day — from 7:30 am to 6:30 pm, with the station closing earlier on Saturdays and other random days, and opening later on random days throughout July.  The FWP Watercraft Inspection Station Annual Report, 2018 stated that Wibaux operated for an average of 12 hours per day.  Even if this is taken a face value, 12 hours of coverage for the primary east-west travel corridor in the state is insufficient.  Similar types of patterns can be seen at some other perimeter inspection stations.[18]

Table 2:  Wibaux Hours of Operation, July 2018

Day of Week Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Date 7/1/18 7/2/18 7/3/18 7/4/18 7/5/18 7/6/18 7/7/18
Time of 1st inspection 8:10 a.m. 8:56 a.m. 7:54 a.m. 8:25 a.m. 9:47 a.m. 8:29 a.m. 8:57 a.m.
Time of last insp. 12:18 p.m. 4:03 p.m. 5:24 p.m. 5:50 p.m. 5:03 p.m. 5:30 p.m. 1:43 p.m.

 

Day of Week Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Date 7/8/18 7/9/18 7/10/18 7/11/18 7/12/18 7/13/18 7/14/18
Time of 1st inspection 8:17 a.m. 6:01 p.m. 8:17 a.m. 7:50 a.m. 7:56 a.m. 11:11 a.m. 7:50 a.m.
Time of last insp. 4:00 p.m. 6:10 p.m. 6:29 p.m. 5:19 p.m. 5:44 p.m. 6:02 p.m. 4:23 p.m.

 

Day of Week Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Date 7/15/18 7/16/18 7/17/18 7/18/18 7/19/18 7/20/18 7/21/18
Time of 1st inspection 8:45 a.m. 9:36 a.m. 8:43 a.m. 9:50 a.m. 8:20 a.m. 9:48 a.m. 9:08 a.m.
Time of last insp. 5:56 p.m. 9:36 a.m. 5:52 p.m. 6:20 p.m. 3:31 p.m. 5:35 p.m. 3:54 p.m.

 

Day of Week Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Date 7/22/18 7/23/18 7/24/18 7/25/18 7/26/18 7/27/18 7/28/18
Time of 1st inspection 9:54 a.m. 8:00 a.m. 8:49 a.m. 11:17 a.m. 10:17 a.m. 8:29 a.m. 8:35 a.m.
Time of last insp. 3:13 p.m. 4:49 p.m. 3:03 p.m. 5:45 p.m. 4:14 p.m. 4:14 p.m. 3:51 p.m.

 

Day of Week Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Date 7/29/18 7/30/18 7/31/18        
Time of 1st inspection 9:30 a.m. 8:41 a.m. 8:48 a.m.        
Time of last insp. 5:35 p.m. 6:05 p.m. 5:06 p.m.        

 

The hours of operation for each WIS impacts the total number of inspections undertaken, and directly affects our ability to protect Montana waters.  Wibaux is designed to intercept out-of-state boats originating from points east of Montana, many of which are fouled with invasive mussels, including but not limited to the Great Lakes.  Failing to fully maintain minimum hours of operation at perimeter inpsection stations compromises the integrity of the AIS prevention program.

This issue of insufficient protection at our borders is not a new finding, but one which has been flagged for over five years.  Morever, at many stations this is not an issue of funding but of staffing and management.  Each year, FWP struggles to staff inspector positions in eastern Montana, and at some other Class I WIS and decontamination stations in part due to (1) low population in these remote areas; and (2) higher hourly rates in eastern Montana driven by the Bakken pay scale.  These are not insurmountable barriers to border protection, and previously the Flathead Basin Commission repeatedly identified a variety of ways to address these labor shortages, including but not limited to:

  • importing labor from western Montana and providing inspectors with temporary housing;
  • providing inspectors working in selected remote locations with bonuses for successfully working through the entire field season;
  • providing hiring preferences for inspectors who successfully complete work at remote stations They may then apply in the future for full-time employment at FWP for a position for which they are qualified;
  • increasing the pay scale at selected locations to ensure a competitive rate of pay commensurate with the surrounding area or partner with other entities to run these remote stations so that these partners can employ inspectors at a higher rate of pay;[19] and
  • hiring an outside firm or differenct agency to manage border inspection stations.

Each year FWP faces labor shortages at selected border stations, and each year the same set of limitations  are presented.  Solutions are not forthcoming, particularly not at a rate that would demonstrate the agency’s acknowledgement of the situation.

As of the 2019 field season, the AIS watercraft inspection program under FWP management will have been operational for almost a decade.  Unfortunately, it appears that the 2019 field sesaon will continue to follow past trends in terms of hours of operation.  As of March 31, 2019, FWP had yet to publish their WIS season/hours of operation.  However, it is our understanding that the vast majority of the perimeter and Continental Divide stations will only be operational 12 hours per day, despite the fact that a minimum of 16 hour days are needed.[20]  It is now long overdue – the state needs to solve these basic management issues, and implement a fully functional AIS prevention program.

High-Risk Watercraft:   Wibaux Case Study

2018 Montana Watercraft Inspection/Decontamination Station Operation Protocols (page 33) defined a high-risk watercraft as:

  • Any motorized watercraft that originates[21] from outside the state of Montana (unless

the watercraft originates in Idaho, Wyoming, Washington or Oregon).  The Provinces of Alberta and British Colombia are considered High Risk.

  • Any watercraft that is dirty, crusty, and/or slimy below the waterline.
  • Any watercraft that has plants, animals, mud, or standing water present.
  • Any watercraft that has launched in mussel-impacted water (i.e. Canyon Ferry, Tiber

Reservoir).

 

This same manual further stated (page 26): “Remember, any motorized watercraft that have been in states or provinces outside of the northwest must receive a HIGH-RISK inspection.”

 

Of the approximately 301 inspections conducted at the Wibaux station in July 2018, 144 were entered into the database as “High Risk.” Of that 144, 31 were non-motorized and 6 were listed as “other.” Based on the above criteria for high-risk and the geographic location of the Wibaux station (westbound only and approx. 10 miles from the North Dakota border) nearly all of the remaining motorized watercraft inspections (a total of 187) should have been considered high-risk and received a high-risk inspection; however, fewer than 60% (107) received such an inspection.

 

For motorized watercraft, the acronym H.E.A.D. is used to ensure that a complete and thorough inspection is conducted on all high-risk watercraft, which includes:

 

H = Hull and Trailer

E = Engine or Motor (including Transom)

A = Anchor, Anchor Rope and Equipment

D = Drain Interior Compartments

 

More specifically, at the Wibaux WIS, of the 301 boats inspected in July 2018:

 

  • 187motorized watercraft entered the station (all of these should have be classified as high risk unless they were sealed from another approved WIS); and
  • 114non-motorized/other entered the station.

 

Of the total 187 motorized boats:

  • 107obtained a high-risk classification from inspectors;
    • 13 of the 107 were reported as receiving the full HEAD inspection;
  • 80 motorized watercraft did not obtain a high-risk classification, and it is likely that a significant majority should have in fact be classified as high-risk.

 

To summarize:

  • Somewhere between 94-174 watercraft at the Wibaux station in July should have obtained a high-risk designation and HEAD inspection but did not.[22]

 

  • If these numbers are extrapolated for the entire field season, for all inspection stations across the state, we can deduce that significant numbers of boats launched on Montana waters with inadequate inspections.

 

“Standing water” is another criterion which should trigger the need for a “high risk” inspection.  A total of two watercraft during the month of July received standing water decontaminations, yet neither were entered as high risk in the FWP database.

 

Based on the above, it appears that Wibaux inspectors had not been adequately trained in that inspectors were failing to (1) carry out high risk inspections when needed based on FWP protocols; and (2) properly record data into the FWP database.  Procedures for high risk inspections are an area of concern and an inconsistency which needs to be immediately addressed.

WIS Database

WPA applauds FWP for transferring to an electronic data collection system, and while we appreciate that FWP purchased a pre-existing database from another state, it is important to address the outstanding issues with database configuration and management prior to entrenchment.  Selected issues with the database are noted below:

  • Database is not publicly accessible;
  • Database is not easily searchable;
  • Database cannot readily be amended to include new data categories, without considerable time and cost; and
  • Data gaps remain which skew data and infringe upon accurate assessment of trends.

The database does not include drive-bys (see Section on Compliance Rates below), nor does it include data relating to moored boats or boats possessing live wells.  As the section directly above indicates, the database does not trigger inspectors to undertake high-risk inspections as necessary.  In addition, the database is not structured to ensure that all ballast boats have at least one ballast tank.  More specifically, 3,281 wakeboard boats were inspected statewide according to the WIS database, however, only 468 of these boats were reported to have ballast tanks.  Since wakeboard boats by definition possess ballast tanks all of these boats should have been reported as possessing ballast tanks and high-risk inspections protocols should have been triggered (see above section) unless the boat had already been inspected and/or decontaminated.

 

See Entry No. 2 below (Anaconda Inspection)

 

 

 

Unfortunately, only 863 of the 3,281 wakeboard boats (26 percent) received high-risk inspections.

 

See Appendix A for additional information.

 

 

Detections of Fouled Watercraft[23]

FWP detected a total of 16 mussel fouled boats over the 2018 field season, out of a total of 109,789 inspections performed by FWP and its partners.  On its face, that is success since each of these boats was prevented from launching in Montana waters.  However, it should be noted that the Province of Alberta inspected a total of 31,799 boats in 2018, with a total of 15 detections of mussel fouled watercraft.  In other words, Montana inspected more than 3 times the number of boats as compared to Alberta, yet Montana had almost the same number of detects as Alberta.  This is a concern and though it cannot be definitively proven, one can deduce that a certain number of mussel-fouled boats in Montana were simply not detected.  To put this in context, Montana inspectors conducted 109,789 inspections, with 16 mussel fouled boat detected (.0001 of the total).  In comparison, Alberta inspectors conducted 31,799 inspections, with 15 mussel fouled boat detected (.0005 of the total).  Proportionally, Alberta detected 5 times as many fouled boats as Montana.  This represents a significant difference in performance and raises questions about the adequacy of the FWP training effort for state inspectors.

In addition, inconsistencies and anomalies were evident in the detection data from various Montana WIS.  At the Wibaux station, a total of 1310 boats were inspected, with 836 being recorded as out-of- state and 474 being recorded as in-state.  Since Wibaux is on the far eastern border of Montana it is highly likely that virtually all watercraft inspected at the station originated from out-of-state, whether or not the boater in question possessed a boat registered in Montana.  This would therefore trigger a greater number of high-risk inspections (see section High-Risk Watercraft, Wibaux Case Study above).  Resolving inconsistencies in data management and in triggers for high-risk inspections requires resolution.

In addition, it appears that significant discrepancies exist between the level of competency at different perimeter stations.  For example, Dena Mora inspectors conducted 5097 inspections, with 59 fouled boat detections (.0116 of the total).[24]  In comparison, Eureka inspectors conducted 1826 inspections, with 3 fouled boat detections (.0016 of the total).  Though we are admittedly dealing with small sample sizes for fouled boats, the contrast in detection rates represent an order of magnitude difference not likely due to random chance.  A similar trend can be seen when comparing Continental Divide stations.  For example, the Highway 12 Helena station inspectors conducted 4498 inspections, with 298 fouled boat detections (.066 of the total).  In comparison, Sula inspectors conducted 1460 inspections, with 6 detects fouled boat (.004 of the total).  Detection of illegal bait are also illustrative.  In 2018, Troy inspectors detected four cases of illegal live fish.  Troy inspectors were the only ones in the State to make such detections.

For mussel fouled boats, the similar trends were evident.  Of the 16 mussel fouled boats in the State of Montana in 2018, detections occurred at the following station:

  • Anaconda (8);
  • Wibaux (4);
  • Dillon (3); and
  • Clearwater (1)

While we commend the inspectors at the Anaconda WIS for detecting 8 mussel fouled boats, given the location of this station, such boats should have been intercepted prior to reaching this WIS.   The Anaconda detections again illustrate the problems associated with current perimeter station protocols.

Differences in detection rates can be due to a variety of factors.  It appears that in this case, at least in part, training has been insufficient and quality control lacking.  Since FWP trained its inspectors initially with the same training protocols, differences in management oversight (or lack thereof) likely accounts for the lack of quality control.

It is recommended that mid-season assessments be undertaken in June at each WIS to (1) review data to identify and trouble shoot problems; (2) assess performance in the field; and (3) undertake individualized staff assessments.  This would ensure that problems occurring early in the season are minimized or eliminated altogether, including recurring recording errors on hand-held devices (see WIS Database above).  In addition, based on anecdotal evidence, it appears that one or two stellar inspectors can elevate the performance of virtually all inspectors at a given station.  Conversely, a couple of poorly performing inspectors can greatly reduce program efficiency.  Mid-season reviews will also give program managers the opportunity to elevate those inspectors that are performing well, and to retain or terminate those inspectors that continue to perform poorly.

Lastly, inspectors have a difficult job.  Boaters can be cantankerous.  In the spring, temperatures can be cold and gray.  In the summer, the sweltering temperatures and mosquitos can make the life of an inspector miserable.  It can be difficult to maintain focus when the vast majority of boats inspected are not fouled.  We recommend that inspectors be provided with performance incentives to assist them in maintaining focus and enthusiasm for their jobs.  The state of Montana now spends millions annually on inspection stations.  However, we only as good as our weakest inspector.  Therefore, providing incentives to increase and maintain productivity is money well spent.

Compliance Rates

Boater compliance with the state AIS program can be ascertained based upon by the number of boaters stopping at mandatory WIS.  Compliance is typically measured by the total number of boaters, both motorized and non-motorized, that drive-by mandatory stations without being inspected.  In 2018, the State WIS database did not capture drive-by rates.  Without this information it is impossible to determine compliance rates, and the need for enhanced enforcement actions.  In past years, drive-by rates varied greatly between stations.  For example, perimeter stations such as Wibaux and Nashua, typically experienced higher drive-by rates as compared to stations operated by tribal, county or city governments, as local law enforcement agents were generally more readily available to assist with enforcement.  Therefore, drive-by information is critical to programmatic effectiveness and the deployment of law enforcement staff.

Summary:  Improvements have been made to the AIS program in terms of the total numbers of inspections completed across the state.  However, the hours and season of WIS operation are currently insufficient to prevent mussels from spreading in Montana.  In addition, the state’s program is only as good as its weakest inspector and the quality of inspections at selected stations is lacking based on the analysis above.  Therefore, additional and ongoing training is required for WIS inspectors throughout the state.

Grade Determination:

Based on definitions from Lehigh University, the meaning of each grade is as follows:[25]

  • A, A–, excellent;
  • B+, B, and B–, good;
  • C+ and C, competent;
  • C–, continuation competency (program has achieved the level of proficiency needed to satisfy prerequisite requirements);
  • D+, D, and D–, passing, but performance is not adequate to satisfy prerequisite requirements; and
  • F, failing.

If the watercraft inspection program was in its first or second year of operation, the program would have been awarded a B+.  However, at a minimum, the agency is entering its 9th year of operation[26] and the outstanding issues which require redress are substantive.  This portion of the State’s AIS prevention program operated at a below average level despite the fact that funding was readily available.

The Watercraft Inspection Station Annual Report, 2018, page 6 states:

FWP has focused much of its effort on border stations to prevent AIS from entering the state and continued inspections at internal locations, popular waterbodies, and extra protection for the Columbia River watershed. The goal of this balanced approach is to:

  1. Intercept AIS at Montana’s borders;
  2. Prevent the internal spread of AIS already present in the state.

Intercepting AIS at Montana’s borders is correctly listed as the first priority for the program, along with containment as number 2.  However, as noted above, the season and hours of operation do not fully reflect this priority, nor does the training protocols and oversight of inspectors at many of the perimeter stations.

Given the issues identified above, the State of Montana AIS prevention program was awarded the following grade:

Grade:  C-

Issues and Recommendations:

  • Issue: Insufficient Watercraft Inspections at Montana Borders

After 8+ years of FWP management, border inspection stations continue to suffer from (a) lack of infrastructure; (b) insufficient season/days/hours of operation which results in reduced levels of protection for Montana waters; (c) staffing shortages and (d) lack of enforcement presence.

 

Solutions:

  • Via the state 2019 AIS budget, allocate funds directly to MDT for the operation of border inspection stations at ports of entry and weigh stations. This could also reduce staffing needs since only one inspector would be needed when MDT operators are already present at MDT sites.  One-time funding may be needed to reconfigure some MDT sites to accommodate non-commercial traffic and the wage scale may need to be increased to accommodate MDT’s union pay scale.[27]
  • Via the state 2019 AIS budget, allocated FWP funding to stated WIS with specific minimum season/hours of operation.

 

  • Issue: Lack of Independent Oversight to Address Program Deficiencies

To their credit, the FWP Watercraft Inspection Station Annual Report, 2018, page 4 states:

 

“One challenge that the AIS program continues to encounter is QA/QC [Quality Assurance/Quality Control] at inspection stations . . . “

 

We agree with this assessment.  In particular, the season of operation, hours of operation and quality control for the WIS across the State are all areas that require independent assessment.  The agency(ies) being assessed cannot pay for such oversight directly because this reduces the independence of the auditor(s).

 

Solution:  Via the State 2019 AIS budget, provide funding for EQC to hire independent contractor(s) to ground truth conditions and review existing protocols.  At a minimum, two reports should be made to EQC – one early in the season to remedy deficiencies, and the second at the end of the season to determine how/if the agencies remedied identified deficiencies.  In addition, data should be readily accessible to the public to ensure transparency.

 

 

 

 

 

Appendix A:  Sample WIS Database Screen Shots

 

This outboard motor watercraft was inspected at the Wibaux WIS on July 13, 2018.  The Wibaux inspection indicated that the boat had last launched in the state of Minnesota and was heading to Washington State. Though it was considered a ‘high-risk’ inspection, there is no indication that the watercraft’s anchor was inspected as required based upon high-risk inspection protocols.  A watercraft with the same seal number entered the station again on July 21, 2018.  However, other key information such as registration numbers did not match up, and during the second inspection on July 21, 2018, only the hull and engine were checked.

 

It is uncertain what transpired here, but it is possible that the incorrect seal numbers were entered into the database during one of the inspections, or data was incorrectly recorded across the board.  Regardless, a high-risk inspection should have been completed for one or both of these boats.

 

 

 

 

 

 

 

 

 

This outboard motor boat was sealed on July 14, 2018 and Wibaux inspectors correctly tagged the watercraft as requiring a high-risk inspection.  However, only the hull and engine were reported as being inspected, contrary to the protocols for a high-risk inspection. On July 15,2018, a boat with the same seal number entered the Anaconda station, and again, the information collected did not match the first inspection at Wibaux.  Given that the boat types were very different – one boat was motorized and the other was not – it is possible that inspectors entered the incorrect seal number.  Regardless, the inspectors failed to complete the high-risk inspection required on July 14th.

 

 

 

 

 

 

 

 

 

 

This outboard motor boat entered the Wibaux station on July 19, 2018, and then entered the Anaconda WIS on July 20. Note that the registration numbers, while both from Minnesota, do not match. Additionally, the July 19th inspection indicated that the boat last launched at Minnetonka Lake, a lake known to have invasive mussels. However, the boat did not receive a high-risk designation, and the anchor was not inspected.  At the Anaconda WIS the following day, no inspection information was recorded.  Failure to inspect the anchors of high-risk boats can lead to the inadvertent introduction of invasive mussels into Montana waters.

 

 

 

 

 

 

 

 

 

 

This watercraft came through the Wibaux station from Minnesota on its way to Flathead Lake on July 23, 2018. The high-risk inspection did not trigger an inspection of the anchor, nor does the data entry indicate that the boat was fully drained. The following day, the watercraft was inspected again at the Anaconda WIS, and inspectors recorded it as a wakeboard with no ballast tanks.  However, wakeboard boats generally possess at least one ballast tank.    If this watercraft was in fact a wakeboard boat, it appears that inspectors at both stations failed to inspect the tanks and check the ballast tank plugs beneath the boat.  This boat was not decontaminated based on UMPS III protocols.

 

 

 

 

 

 

 

 

 

 

This watercraft came through the Wibaux station on July 21, 2018 from Michigan headed to Flathead Lake.  The watercraft was given a high-risk designation. However, either an inspection was not undertaken, or such inspection failed to be recorded.  No seal was placed on the craft.  It is very common for standing water to be present in the bilge of PWC, yet it does not appear that the bilge was checked.   A seal number search indicated that the water craft did not receive another inspection before launching on Flathead Lake.

 

 

 

 

 

This inboard jet boat from Minnesota entered the Wibaux WIS on July 25, 2018. The high-risk inspection indicated that only the hull was checked on the boat.  Moreover, given the presences of invasive mussels in Minnesota, the boater should have been required to specifically state where the boat was launched in the last 30 days.  This boat should have received a full HEAD inspection and this data raises questions regarding the state’s 2018 decontamination protocols.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

This outboard jet motor boat came through the Wibaux WIS on July 18, 2018.  Though the boat was tagged as high-risk, only the hull of the watercraft was inspected. It appears that the same day, this watercraft entered the Nashua WIS.  Nashua recorded a different watercraft type, different boat and trailer states, and it appears no inspection was undertaken.  Also, it appears that Nashua inspectors believed or were instructed that sealed boats were simply to be passed through the station.  A certain amount of redundancy is useful and can be used to spot check the work from other stations.  Inspectors at Nashua should have reviewed the Wibaux inspection and realized that a full inspection had not been completed and was required.  Given the low amount of boat traffic at locations like Wibaux and Nashua this spot checking is both feasible and warranted, and such diligence should be expected of inspectors.  Similarly, management staff should be reviewing this data to correct such deficiencies as they occur, rather than waiting until the end of the field season.

 

 

 

 

 

 

The three screen shots below show a series of inspections with different bodies of water listed as last visited, different registration numbers, and the initial high-risk inspection at Wibaux only indicates that the hull and engine were checked, contrary to high-risk inspection protocols.  Though this boater stated the next destination as Washington state, determining where a boat was last launched is of critical importance and these inconsistencies should have triggered a more robust response.  The good news is that Ravalli inspectors finally conducted a HEAD inspection – at the third WIS the boat entered in the State of Montana.

The three inspections below show a watercraft coming from North Dakota heading to Flathead Lake.  At least two different types of watercraft were reported for the same boat.  At Anaconda, inspectors classified the boat as a wakeboard boat with no ballast tanks, which is unlikely.

Again, the lack of actual decontamination for such boats raises questions about the program’s effectiveness in 2018 (see Decontamination Section of this report).

 

 

 

 

 

 

 

This personal watercraft was headed to Whitefish Lake from Michigan. The high-risk inspection indicates that only the hull of the PWC was inspected, though the bilge in this watercraft is the area most likely to transport AIS.  Again, the registration and trailer numbers do not match, and when the PWC went through the Anaconda WIS, no inspection procedures were recorded.  Inspectors should reinspect such high-risk boats and be trained to catch and fix errors from other stations.

 

 

 

 

 

 

 

 

 

 

 

This outboard motor boat entered the Wibaux station on July 21, 2018 and then entered the Ravalli WIS on August 3, 2018. The registration and seal number match, but the last waterbody visited and seal color do not match.  Both inspections were recorded as high-risk, yet only the Ravalli WIS indicated that the anchor was checked.

 

 

 

 

 

 

 

 

This outboard motor boat coming from Minnesota was headed to Flathead Lake.  The first inspection at Wibaux on July 23, 2018, indicates that only the hull and engine were checked (no anchor or drain).  Fortunately, the next day in Anaconda, the boat was intercepted, and a full decontamination and standing water decontamination were performed.  This is an example of how the redundancy in the system can catch errors and ensure that potentially mussel-fouled boats do not enter Montana waters.

Interestingly, the data records do not indicate the presence of standing water, but we applaud the fact that inspectors erred on the side of safety and took additional precautionary steps to ensure the boat was clean prior to leaving the WIS.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Photo Credits:

 

Front Cover:  https://www.google.com/search?rlz=1C1CHBF_enUS811US811&q=free+aquatic+invasive+species+photos&tbm=isch&source=univ&sa=X&ved=2ahUKEwjzzsz_98DhAhVRvKwKHVX2CxUQsAR6BAgJEAE&biw=1238&bih=593

[1]    FWP categories these stations with different names, but for the purpose of this report it was easier to describe the function of the stations rather than categorizing them as a type I or II.

 

[2]    The data presented in the remainder of this section is a rough approximation.  The FWP WIS database does not permit non-FWP employees to conduct database searches for each station.  Therefore, manual counting was required to obtain much of this data, and it is possible that a small number of data points may have been missed in tabulating these calculations.

 

[3]    Optimally, stations would open on or about March 1st each year, with flexibility to account for weather patterns and road conditions.  Many residents return to Montana early in March with watercraft that have been launched in the southwest, and boats in transit from the mid-west may enter the state well in advance of the opening dates for Nashua and Wibaux, see Table 1 above.

 

[4]    This can be accomplished in part by after-hours studies.

 

[5]    FWP operates approximately 50% of the Class I inspection stations.  The remainder of stations are operated by a variety of parnters, with CSKT, Blackfet and Glacier National Park operating the majority of these stations.   The Class I station at Tiber is not included in this analysis as no inspections are offered at this station.

[6]    For example, on May 6, 2015, 28 days after the station opened, the first mussel-fouled watercraft of the season was detected at the WIS in Browning, Montana.  On August 17, 2015 a third mussel-fouled boat was detected at the Browning WIS at 7:15 pm.  Such detections demonstrate the need for extended hours of operation and early season opening dates.

 

[7]    Class I stations include perimeter and Continential Divide WIS.

 

[8]     The CSKT station at Ravalli opened in March 15th, but this WIS was not a FWP managed station.  Similarly, the Blackfeet station in Browning opened April 3, 2019.  It should be noted the FWP does provide funding for these stations, but the tribes operate and manage these stations.  In addition, it should be noted the FWP did open the Kalispell regional office for inspections 7-days a week starting March 13, 2019.  The hours of operation at the regional office were not posted as of 3/31/19.

 

[9]      Closing and opening times are based on the data provided online in the FWP WIS map.

 

[10]    Average hours of operation are based upon the FWP report released in February 2018.  Inconsistencies between stated hours of operation and average hours of operation are unclear.

[11]    Stations should optimally operate 24 hours a day, which will require lighting, adequate security, etc..  It is possible that an automated system, along with an enforcement presence, could be used to reduce total program costs.  At a minimum, staffed border inspection stations should operate from sunrise to sunset each day.

 

[12]    The stations lacking opening/closing data represent data missing  on the FWP map as of December 2018, http://cleandraindry.mt.gov/Watercraft-Inspections.

 

[13]    Discrepancies exist for some station operations.  The posted hours for this WIS indicates it was operational 14 hours each day, but the FWP average reported the station operating 15 hours a day.

 

[14]    Data from the CSKT station at Ravalli, which is open 24 hours per day during the height of the field season, shows that watercraft routinely travel after 9:00.  And although boating traffic does decline as night falls, high risk boats have been intercepted at the Ravalli station well after 10:00 pm.

 

[15]    For non-perimeter stations it is important to conduct several after-hour surveys to determine the optimal hours of operation of each WIS.  For Browning, after hours studies showed no boating traffic moving through the highway 2 corridor from 11:00 pm to 5:00 am.  Patterns will differ at various stations, and studies should be done annually to assess any changes in boating patterns so hours of operation can be adjusted accordingly.  At a minimum, studies can be undertaken during the height of the field season by selected a random 7-day period.

 

[16]    The agency currently has no basis for this argument since after hour studies have not been conducted at these FWP perimeter stations.

 

[17]    For example, though unlikely, it is possible that on occasion no watercraft entered the station for several hours in a given day in July.

[18]    For example, at the Eureka WIS, the first inspection on July 1, 2018 did not occur until 11:19 a.m. A total of six boats came through the station after this first inspection.  Given the number of boats entering the station after 11:19 am, it is likely more watercraft would have been inspected had the station been open earlier.  On July 11, 2018, only 6 watercraft were inspected at the Eureka WIS. The first three inspections occurred between 10:16 and 11:13 am; the last three were between 2:24 and 3:29 pm. This may indicate that the station was closed for much of the day.

 

[19]    It is our understanding that the FWP bureaucracy has pushed back against a higher pay scale at remote locations, due in part to issues regarding the state pay band for inspectors and concerns raised from Helena FWP staff claiming such selective pay increases are unfair given their modest salaries.  A possible solution may be to increase the hourly rate in remote locations and allow Helena staff to be reassigned to these stations.

 

[20]    Using the 16-hour minimum would likely capture approximately 90% of the boating traffic at most WIS.  If the legislature and citizens seek to reach 100%, hours of operation would likely need to increase to 24 hours per day at most WIS.

 

[21]    Since the term “originates” is not defined, for the purposes of this report we will assume that this refers to any watercraft that has travelled outside the pacific northwest, not just boats registered in another state.

[22]   Based on tracing seal numbers, it appears that only 23 of the high-risk motorized watercraft were inspected at another WIS in Montana.

 

[23]    Montana data in this section derived from the Watercraft Inspection Station Annual Report, 2018.

[24]    In this context, fouled boats represent boats fouled with mussels, mud, plants, etc.

[25]    http://catalog.lehigh.edu/undergraduatestudies/guidetoacademicrulesandregulations/definitionsofgrades/

[26]      According to the Watercraft Inspection Station Annual Report, 2018, FWP has operated WIS since 2004, which means that agency has 15 years of experience operating stations.

 

[27]    The pay scale offered by FWP at border stations, in part, constrains the available pool of WIS inspectors.  The increased pay scale would be beneficial in attracting a larger number of applicants.