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April 5, 2004
Joan Jewett, Portland,
Oregon
503-231-6121
Phil Carroll, Portland, Oregon
503-231-6179
Douglas Zimmer, Lacey, Washington 360-753-4370
Meggan Laxalt, Boise, Idaho
208-378-5796
Tom Buckley, Spokane, Washington
509-893-8029
Diane Katzenberger, Denver, Colorado 303-236-7917x408
Draft
Economic Analysis of Critical Habitat Proposal for Bull Trout
In the Columbia and Klamath River Basins Released for Public
Comment
Most impacts are on Federal lands
The U.S. Fish and Wildlife Service today
released a draft analysis of the potential economic impacts of a proposal
to designate critical habitat for bull trout in the Columbia and Klamath
river basins.
Bull trout (Salvelinus confluentus)
are protected under the Endangered Species Act as a threatened species. In
2002, in accordance with a court settlement, the Service proposed to
designate critical habitat for the species.
The draft economic analysis, prepared by
Bioeconomics Incorporated of Missoula, Montana, estimates that protecting
bull trout and their habitat in the Columbia and Klamath basins could
potentially have economic impacts of $230 million to $300 million over the
next 10 years (about $23 million to $30 million per year), mostly on
Federal lands. The critical habitat proposal for the Columbia River Basin
includes parts of Oregon,
Washington, Idaho and Montana. The
proposal for bull trout in the
Klamath River Basin includes a
small part of the Klamath basin in Oregon.
Most
of the estimated cost already is occurring due to the listing of bull
trout and protective measures already in place for listed salmon and
steelhead. More than 60 percent of the area proposed for bull trout
critical habitat has previously been classified as salmon and steelhead
critical habitat, although much of that designation was recently withdrawn
for re-analysis by the National Marine Fisheries Service.
The draft economic analysis does not
separate costs associated with the designation of critical habitat from
those already incurred by the listing of bull trout in the Columbia and
Klamath basins in 1998.
The draft analysis will be available for
public comment until May 5, 2004.
The Service also is reopening the comment period on its proposal to
designate critical habitat for bull trout in the two river basins and will
accept comments until that date. Comments previously submitted need not be
resubmitted as they will be incorporated into the public record as part of
this comment period and will be fully considered in preparation of the
final rule.
series of public information meetings
also is planned. The schedule is:
Kalispell,
Montana: April 17, noon to 4
p.m., Montana Fish, Wildlife and Parks Office,
490 North Meridian Road
Bend,
Oregon:
April 20, 6
p.m. to 8 p.m., Bend Armory, 875 S.W. Simpson Avenue
LaGrande,
Oregon:
April 21, 6
p.m. to 8 p.m., National Guard Armory, 404 12th Street
Boise,
Idaho: April 14,
1 p.m. to 3 p.m. and 6 p.m. to 8 p.m., Boise Centre on the Grove, 850
Front Street
Salmon,
Idaho:
April 16,
9 a.m. to 1 p.m., Salmon
City Chambers, 200 Main Street
Lewiston,
Idaho: April 19,
4 p.m. to 8 p.m., Red Lion Hotel, 621 21st Street
Yakima,
Washington: April
21, 6 p.m. to 8 p.m., Oxford Suites Hotel, 1701 Yakima Avenue
“We
want to give the public time to review the draft economic analysis and the
critical habitat proposal and then provide us with comments,” said Dave
Allen, Regional Director of the Service’s Pacific Region. “Citizen
participation is crucial to the development of a final designation that
protects the species and is supported by the public.”
The Service has proposed to designate
18,471 miles of streams and 532,721 acres of lakes and reservoirs in
Oregon, Washington,
Idaho and Montana as critical habitat for the Columbia and Klamath basin
populations of bull trout. Under the court settlement, a final critical
habitat designation for those two basins must be made by September 21,
2004. The final designation could differ from the Service’s proposal.
Federal agencies are estimated to bear 75
percent of the costs associated with listing and the potential costs of
the proposed critical habitat designation, with private and other entities
(states, tribes) incurring 25 percent. Of the total 10-year costs, 70
percent are estimated to come from the expense of consulting with the
Service and the subsequent project modifications that may be required.
These modifications might include improved fish passage, reduced water
withdrawals, revised timber sales and highway projects, timing delays, dam
re-licensing, and foregone power generation. The remaining 30 percent of
the 10-year costs are estimated to be administrative expenses.
Consultations with the Service already
are required of Federal agencies as a result of the bull trout listing.
The critical habitat designation would result in additional consultations
only in cases where unoccupied habitat is designated. About 14 percent of
the proposed critical habitat is either unoccupied or has unknown
occupancy.
Under the Endangered Species Act, an
economic analysis is required prior to the designation of critical
habitat. The Fish and Wildlife Service may exclude areas from a final
critical habitat designation if the benefits of excluding them are greater
than the benefits of including them, unless the exclusion would result in
the extinction of the protected species.
A notice of Availability of the draft
Economic Analysis was published in today’s Federal Register. The Notice
and the draft Economic Analysis are posted at
http://pacific.fws.gov/bulltrout/. You may mail or hand-deliver
written comments to John Young, Bull Trout Coordinator, U.S. Fish and
Wildlife Service, Ecological Services, 911 N.E. 11th Avenue,
Portland, Oregon 97232; fax them to 503-231-6243; or send them by e-mail
to:
R1BullTroutCH@r1.fws.gov. Please submit electronic comments in an
ASCII file format and avoid the use of special characters and encryption.
Please also include “Attn: RIN 1018-A152” and your name and return address
in your e-mail message. If you do not receive a confirmation from the
system that we have received your e-mail message, please contact John
Young at 503/231-6194. If our Internet connection is disrupted, please
submit your comments by mail or fax, and obtain hard copies of the
documents from the contact above.
The Service proposed critical habitat in
November 2002 for bull trout in the Columbia and Klamath basins in
accordance with a settlement agreement with the Alliance for the Wild
Rockies and Friends of the Wild Swan. The two environmental groups sued
the Service for not designating critical habitat after listing bull trout
in 1998 as threatened in the Columbia and Klamath basins and in 1999 as
threatened throughout its range in the lower 48 states. At the time the
Service was unable to complete critical habitat designations because of
budget constraints.
As part of the settlement agreement, the
Service also agreed to designate critical habitat for
The Coastal-Puget Sound (Washington), St.
Mary-Belly River (Montana) and Jarbidge (Nevada) distinct population
segments of bull trout. The Service will propose critical habitat for
those populations in June 2004. A draft recovery plan for all lower-48
populations of bull trout also is being developed.
Critical habitat designates areas that
contain habitat essential for the conservation of a threatened or
endangered species and which may require special management
considerations. These designations do not have to be occupied by the
species at the time of the designation. A designation does not set up a
preserve or refuge or signal any intent by the federal government to
acquire or control lands or waters. It does not close an area to human
access or use, such as fishing or boating.
A critical habitat designation requires
federal agencies to ensure that any activity they fund, carry out or
authorize is not likely to destroy or adversely modify a protected
species’ critical habitat. By consulting with the Service, an agency can
usually minimize or avoid any potential conflicts with listed species and
their critical habitat, and the proposed project may proceed.
The
U.S. Fish and Wildlife Service is the principal Federal agency responsible
for conserving, protecting and enhancing fish, wildlife and plants and
their habitats for the continuing benefit of the American people. The
Service manages the 95-million-acre National Wildlife Refuge System which
encompasses 544 national wildlife refuges, thousands of small wetlands and
other special management areas. It also operates 69 national fish
hatcheries, 64 fishery resource offices and 81 ecological services field
stations. The agency enforces Federal wildlife laws, administers the
Endangered Species Act, manages migratory bird populations, restores
nationally significant fisheries, conserves and restores wildlife habitat
such as wetlands, and helps foreign governments with their conservation
efforts. It also oversees the Federal Aid program that distributes
hundreds of millions of dollars in excise taxes on fishing and hunting
equipment to state fish and wildlife agencies.
Summary
Of the
Draft Economic Analysis of
Proposed Critical Habitat for Bull Trout
In the Clark Fork and Kootenai River Basins – Montana
The Fish and Wildlife
Service hired an independent private contractor, Bioeconomics Inc. of
Missoula
MT, to estimate the economic and other
impacts associated with designating certain areas as critical habitat for
bull trout. In preparing this economic analysis, Bioeconomics contacted a
wide range of public and private sources.
The Economic
Analysis is not intended to describe the cost of bull trout recovery;
rather, it summarizes the cost to agencies and the public in complying
with Endangered Species Act regulations due to combined effects of both
the existing bull trout threatened species listing (1998) and the proposed
designation of bull trout critical habitat (2004).
Range-Wide
Summary
Total rangewide cost
estimate is $230 to $300 million over 10 years ($23-30 million per year).
This includes the ongoing activities due to the 1998 listing action as
well as the current critical habitat proposal.
ü
While this sounds like a
huge dollar figure, you must keep in mind that the bull trout range
encompasses watersheds in four northwest States. The critical habitat
proposal alone includes over 18,000 miles of stream and over 500,000 acres
of lakes.
ü
Most of the costs of
protecting bull trout are already embedded in agency actions and policies,
often mandated by laws such as the Clean Water Act, National Forest
Management Act, etc.
o
According to the report:
“There are so many protective standards for fisheries put in place for
timber harvest management on the National Forests in the Pacific Northwest
at this time that the additional requirements of bull trout formal
consultation are likely to be minor.
o
For example, timber sales
are already largely constrained by Total Maximum Daily Load (TMDL)
requirements and Inland Native Fish (INFISH) standards. Therefore, formal
critical habitat consultations to mitigate for bull trout may not yield
additional terms and conditions relating to sediment.
ü
Approximately 30% of the
total estimated cost is associated with administration of Section 7
consultations, the other 70% with project modifications to benefit bull
trout.
ü
Most of the estimated costs
of the actions described (75%) are expected to be borne by Federal
agencies, primarily the Forest Service and the Bureau of Reclamation.
ü
Approximately half the
identified project modification costs are associated with dams and
reservoirs; primarily related to water level regulation, FERC relicensing
conditions, and fish passage at a relatively small number of sites.
o
Annual foregone power
revenue losses to the Bonneville Power Administration, that are attributed
to system flow modifications at Hungry Horse and Libby Dams designed to
benefit bull trout and other resident fish species are considered to be
$2-4 million per year.
o
These losses do not consider
the potentially offsetting benefits of recreation and other beneficial
uses in Montana.
ü
Timber harvest modifications
(reduced sale volume, fishery evaluation and monitoring, road and culvert
Best Management Practices upgrades, etc.) account for about a quarter of
the total project modification costs. A critical habitat designation is
not expected to result in higher prices or a reduced supply of wood
products to consumers.
ü
Water diversion
modifications (such as fish screens) account for about one‑eighth of the
total project modification costs.
ü
Modifications to mining
projects (watershed assessment and monitoring) account for about
one-sixteenth of the total costs.
ü
30% of the total project
modification cost is associated with only 4% of the area – primarily in
the mid-Columbia in Washington and portions of Oregon where major fish
passage issues are likely to be addressed. Some of these involve
anadromous species as well as bull trout.
ü
Costs associated with
activities to benefit bull trout overlap broadly with activities to
benefit a variety of other aquatic species (salmon, steelhead, cutthroat
trout, sturgeon) and terrestrial species (grizzly bear, lynx, gray wolves)
and provide many benefits to other resources that are not quantified in
this report.
Clark Fork
Unit Summary
For Montana and
northern Idaho, the estimated annual cost of bull-trout related actions in
the Clark Fork River Basin is estimated to be between $1.3 million and
$2.1 million per year.
ü
These costs have been
incurred annually for the past five years (since bull trout were listed as
threatened in 1998) – nothing new here since all proposed critical habitat
is already occupied and ongoing Section 7 consultation is continuing.
ü
Bull trout formal
consultations in the Clark Fork Unit (39 conducted in 1998-2002) were the
highest of any unit analyzed. This is due primarily to the size of the
unit, the high number of streams and the high proportion of those streams
that contain bull trout, the relatively high percentage of Federal (USForest
Service) lands, and the absence of previously listed aquatic species
(salmon and steelhead) in those waters.
ü
The Clark Fork is the
largest critical habitat unit within the entire four-state region
designated (including most of western Montana and a portion of northern
Idaho). It includes 3,372 miles of streams (18% of the four-state total)
and 304,225 acres of lakes (57% of the four-state total) that were
proposed for designation as bull trout critical habitat.
ü
The estimate includes $0.8
million per year in Section 7 administrative costs. This is a relatively
high percentage of total costs (38%-62%), due mostly to the scope and
complexity of bull trout distribution and Federal lands in the watershed.
ü
The estimate includes
$0.5-$1.3 million dollars per year in project modification costs.
o
Timber sale modification
(reduced sale volume, fishery evaluation and monitoring, road and culvert
BMP upgrades, etc.) is expected to bear the largest share of future
project modification costs in this unit ($270,000 to $680,000 per year).
o
Costs associated with
irrigation diversion modifications in the Clark Fork
range from $0 to $280,000 per year. These costs represent potential
impacts to water users associated with reductions in available irrigation
water as a result of system modifications (reservoir pools, etc.), and are
not related to water rights.
o
Other forecast project
modification costs within the Clark Fork Basin are associated with:
§
Mining (up to $100,000
annually, principally involving watershed assessment and monitoring).
§
FERC hydro re-licensing of
private dams – mostly associated with Thompson Falls ($50,000 to $91,000
annually).
§
Federal Highway bridges and
road modification (up to $45,000 per year, primarily due to timing
constraints on in-stream work).
ü
Relative to other units, the
Clark Fork ranks high in agency costs for project modifications for the
U.S. Forest Service (#1 at $0.4 to 1.1 million per year), the Federal
Highway Administration (#1 at $45,000 per year), the Federal Energy
Regulatory Commission (#7 at $50,000 to $91,000 per year) and costs to
agencies such as the BIA, National Park Service, and Fish and Wildlife
Service. As previously described, this is due mostly to the scope and
complexity of bull trout distribution and Federal lands in the watershed.
ü
Bull trout-related
modifications on operation of the Federal Columbia Power System have
resulted in changes in operations at Hungry Horse Dam and Albeni Falls
Dam. While these are considered costs, most of the operational changes
due to bull trout have provided economic and recreational benefits in the
waters where they occur. Bull trout-related fishery studies in this
portion of the FCRPS are expected to cost $97,000 annually.
ü
Although the
Clark Fork
ranks fifth among the 25 units in total cost, it is among the five least
costly units in terms of cost per stream mile, due to the extensive amount
of area and stream network involved.
ü
Direct benefits due to bull
trout recovery are not described in the report, but are already being
realized in Swan
Lake - and with the reopening of Hungry
Horse Reservoir to recreational angling, they are on the increase. Such
benefits will be disproportionately high in western Montana compared to
other portions of the bull trout range due to the attractiveness of the
fishery because of the large size of the adfluvial fish. There is also a
lack of alternative fisheries for salmon or steelhead in this region.
Kootenai
Unit Summary
For Montana and
northern Idaho, the estimated annual cost of bull-trout related actions in
the Kootenai River Basin is estimated to be between $337,000 and $411,000
per year.
ü
These costs have been
incurred annually for the past five years (since
bull trout were listed as threatened in 1998) – nothing new here
since
all proposed critical habitat is already occupied and ongoing
Section
7 consultation is continuing.
ü
Bull trout formal
consultations in the Kootenai Unit (14 conducted in 1998-2002) were among
the highest number of any unit analyzed. This is primarily due to the
high number of streams and the high proportion of those streams that
contain bull trout, and the relatively high percentage of Federal (USFS)
lands. With the exception of the Kootenai River White Sturgeon, there is
also an absence of previously listed aquatic species (salmon and
steelhead) in those waters.
ü
The Kootenai (including most
of northwest Montana and a portion of the northernmost Idaho panhandle) is
among the smaller critical habitat units within the entire four-state
region. It includes 368 miles of streams and 30,094 acres of lakes that
were proposed for designation as bull trout critical habitat.
ü
The estimate includes
$290,000 per year in Section 7 administrative costs. This is a relatively
high percentage of total costs (71%-86%), due mostly to the scope and
complexity of bull trout distribution and Federal lands in the watershed.
ü
Timber sale modification
(reduced sale volume, fishery evaluation and monitoring, road and culvert
BMP upgrades, etc.) is expected to bear the largest share of future
project modification costs in this unit ($27,000 to $69,000 per year).
ü
Costs associated with
irrigation diversion modifications in the Kootenai range from $0 to
$28,000 per year. These costs represent potential impacts to water users
associated with reductions in available irrigation water as a result of
system modifications (reservoir pools, etc.), and are not related to water
rights.
ü
Other forecast project
modification costs within the Kootenai Basin, such as those associated
with mining, federal highway bridges and road modification, etc., total
less than $5,000 per year.
ü
Bull trout-related
modifications on operation of the Federal Columbia Power System have
resulted in changes in operations at Libby Dam. While these are
considered costs, most of the operational changes due to bull trout have
provided economic and recreational benefits in the waters where they
occur.
ü
The Kootenai ranks in the
bottom one-third of the twenty-five units in total cost due to bull
trout. It is near the middle of the range in terms of cost per stream
mile.
ü
Direct benefits due to bull
trout recovery are not described in the report, but with the reopening of
Lake
Koocanusa to recreational angling they are
on the increase. Such benefits will be disproportionately high in western
Montana compared to other portions of the bull trout range due to the
attractiveness of the fishery because of the large size of the adfluvial
fish. There is also a lack of alternative fisheries for salmon or
steelhead in this region.
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