Sent: Thursday, November 8, 2012 4:59 PM
Subject: WANTED: Examples of Economic Hardship Due to The Endangered Species Act (ESA) Critical Habitat
Please read the below call to action. PLC and NCBA need your examples of economic hardship suffered due to ESA Critical Habitat designations. You’re participation is crucial in preventing unnecessary and burdensome regulations on working landscapes.
Subject: Affiliate Call to Action: Send Examples of Economic Hardship Due to ESA Critical Habitat
TO:PLC and NCBA Affiliates
FROM:Dustin Van Liew and Theo Dowling, PLC/NCBA Staff
DATE:November 7, 2012
RE:Examples of Economic Hardship Due to ESA Critical Habitat – by Tuesday, November 13th
PLC and NCBA are looking for examples of economic and regulatory hardship to members brought on by the designation of critical habitat under the ESA. In light of the recent unprecedented ESA settlement between U.S. Fish and Wildlife Service and radical environmental groups, the federal government will be forced to make 1,201 decisions on proposed listing, listing and critical habitat designations for 1,053 species in the next 7 years. The USFWS’ FY 2013 budget request includes an increase in funding that could result in 88 more species being listed and critical habitat being designated in just this year alone. As USFWS struggles to meet the settlement deadline, little analysis—including economic impacts—is being done on large bundled decisions. For example, in Hawaii, cattlemen are currently being faced with at least five critical habitat designations that will directly impact them, and they are looking for specific examples to make the argument that the designations will have negative impacts on them (if they don’t come up with specific predictions of negative impacts, the agency won’t count any).
Furthermore, the agency has begun using broader strokes in designating critical habitat, defining “occupied” areas as areas that are used only intermittently by the species, or in some cases proposing CH in areas where the species is not even known to exist (such as with the jaguar of Arizona and New Mexico).
All the while, USFWS commonly underestimates the economic impacts of critical habitat designations. We have
insisted that all economic impacts be considered, using sound economic data, so as to allow for the exclusion of certain areas from CH designations. Gathering your examples of economic/regulatory hardships due to Critical Habitat will help us argue against sweeping CH designations in the aforementioned Hawaii case and in inevitable future cases. Examples could include not just financial impacts, but negative impacts such as additional compliance time, cost and paperwork for every-day practices.
Thank you in advance for taking a few moments to supply us with the backing we need to fight this damaging and misguided overreach. We’d appreciate your response by Tuesday, November 13th.
Manager of Legislative Affairs
Public Lands Council/ National
Cattlemen’s Beef Association
Administrative Assistant Oregon Cattlemen's Association
503-361-8941 ext 10
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