A buddy of mine got a lawyer to help us with this about 13 years ago. I don't know if things have changed, we never got a clear cut answer other than "Don't retain any salmon and you'll probably be OK" We ended up saying screw it and bought charter permits. Have sold them since. The way the charter permit system is set up you have to fish 4 to 6 guys a day, all season, to make it pay, which doesn't leave a lot of room for fly guides. Western Washington WDFW does not seem to understand non-harvest oriented guiding, or fishing for that matter.