On March 8, the United States Fish and Wildlife Service (USFWS) posted its proposed revisions to the designated critical habitat for the northern spotted owl. In this latest revision, USFWS proposes to increase the area designated as “critical habitat’ in three states—Washington, Oregon and California. Under the proposed rule, the number of acres will increase by a whopping 163 percent, from 5,312,327 acres to 13,962,449 acres.
The magnitude of the increase is not the only surprise in this proposed revision, however. This proposal includes privately owned land for the first time. This means private citizens will suffer a significant negative economic impact if this proposal is adopted as written.
The 2012 proposed rule represents an apparent reversal on the part of USFWS from its 1992 and 2008 proposal, which clearly stated: “The 2008 final recovery plan concludes that the habitat needs for recovery of the northern spotted owl in the United States can be achieved by managing for appropriate habitat on Federal lands within the range of the species, with voluntary recovery [emphasis added] measures on intervening non-Federal lands.” In the 1992 and 2008 plans, only federal land was included. By contrast, the 2012 proposed plan would include private and state-owned land. The proposal designates 671,036 state-owned acres and 1,267,704 privately owned acres as critical habitat. These totals make up 4.8% and 9.1% of the total proposed critical habitat acres respectively (see Table). This number also includes 557,097 acres not currently enrolled in formal conservation agreements, 407,171 acres in California and 149,926 in Washington.
Under the authority of the Endangered Species Act of 1973, the USFWS is required to reconsider the areas set aside as critical habitat based on a continued analysis of relevant considerations both scientific and economic. As required by law, USFWS will accept comments on the Revised Critical Habitat for the Northern Spotted Owl through June 6, 2012. Based on the comments, the USFWS will determine the number of private and state-owned acres that will be in the final rule; the USFWS acknowledges that this number could range from zero acres to the numbers shown in the above Table. Essentially, it has left open the possibility that some or all of the private acres could be excluded from the final rule.
In an effort to minimize the number of acres of private lands affected by this rule, it is essential that we in forest-related industries share with the USFWS what we know about the very real impact the proposed rule would have on private forest owners in the Pacific Northwest.
As part of this effort, I would like to submit the following comments based on relevant economic considerations.
Forest2Market recently conducted an analysis of the economic contribution of forestry-related industries to Washington State’s economy. The analysis quantified jobs, wages, the cumulative annual sales revenue realized by Washington-based enterprises, and the taxes paid to state and county governments.
Here are some of the highlights of that study:
Forestry-related industries also pay taxes and fees in the amount of $191 million annually. For every 1,000 acres, taxes and fees average nearly $28,000 annually.
These statistics show that the forest products industry in general and privately owned forests specifically are an important engine of economic activity. According to the proposed rule, in Washington State alone, 149,926 privately owned forest acres are targeted for designation. Based on the above economic statistics, the removal of these acres from productivity will translate to:
In my opinion, this is a very high price to pay for the protection of a single species in a single state. If private land not under conservation agreement is included in the final plan, as many as 2,250 American citizens in Washington State could lose their jobs. These jobs are predominately created by small enterprises in rural communities, where few if any alternative employment opportunities exist. According to the United States Census Bureau, these communities already have poverty rates higher than the national average. Further encumbrances on the harvest of renewable forest resources will affect most directly the communities where unemployment is the principal cause of poverty.
While I won’t argue the merits of the Endangered Species act of 1973, I do take exception to the fact that as a society we have made provisions for endangered species but no provision to share the cost of doing so. The $94.6 million in lost wages, which will be felt most dramatically in rural counties in Washington State, will not be shared by the federal government or the 313,256,970 citizens of the United States in whose name this regulatory action is being taken. Rather it will be paid for by a relatively few private citizens who are unlucky enough to own forestland in critical spotted owl habitat zones.
Several hundred American citizens will suddenly own land that has no value. From the landholder's perspective, this constitutes a perverse kind of eminent domain; they will still own their land and bear all the risk and liability related to it, but for all intents and purposes that land will be worthless as a source of income.
If as a society, we believe attempting to secure the recovery of the spotted owl is the right thing to do, we should not expect just one group of Americans—those who own land in critical habitat zones—to bear the full costs of owl conservation. We should all pay our share of the costs. Each of the 313,256,970 citizens of the US should split the cost of this land, relinquishing $94.6 million or $0.30 per person to the USFWS every year for the next four years. Otherwise the 3,000 Americans who own this land will pay an average of $31,533 a year until the habitat boundaries are modified, the owl population recovers, or (not to be a pessimist) the northern spotted owl is extinct like thousands and thousands of species that could not adapt to changes in their habitat before them.
To learn more or provide comments to the USFWS, visit the Federal Register website.
Absolutely Excellent…It appears, in our effort to save an endangered species, we are making another endangered—that being homo sapiens, variety - forestland owner.
Keep up the good work -
I agree. If, as a society, we decided to save the Northern Spotted Owl (or any other species) then the cost should be shared by all, not just a few individual landowners in Washington.
[...] out, timber leaders had even more reason to oppose the habitat designation. Forest2Market recently analyzed the impact that the Fish and Wildlife’s proposed habitat would have on the ground if approved. [...]
Why not round them up and raise them in captivity? As was done successfully with the California Condor-which also could not thrive in captivity.