Service Releases Study of Economic Costs for Revised California Red-legged Frog Critical Habitat

The U.S. Fish and Wildlife Service (Service) today re-opened the comment period on a proposal made last September to designate 1.8 million acres as critical habitat for the threatened California red-legged frog (Rana aurora draytonii). The new 30-day comment period coincides with the release of an estimate of possible economic impacts from designating critical habitat.


The economic analysis looks at the range of incremental costs linked to the critical habitat designation. The direct incremental impacts include up to $44.8 million through 2030 to protect the frogs and their habitat in new developments. Delays due to further consultations with the Service could cost up to $126 million through 2030, according to the analysis prepared for the Service under contract by Industrial Economics Inc. of Cambridge, MA. The study estimates that consultations will average nine months, although Service regulations require their completion in 135 days. The study notes that development is expected to occur on less than 1 per cent (7,099 acres) of the privately owned land (1.3 million acres) in the proposed critical habitat.


The economic analysis finds there would be no cost to ranchers from designating critical habitat because the proposal would maintain a so-called 4(d) rule for compatible ranching operations. The exclusion gives ranchers, on whose land many of the frogs occur, protection from violating the ESA if they continue routine ranching operations.

But the economic analysis also says that impacts to non-ranching agriculture could be greater if the critical habitat led to additional impacts from a 2006 settlement of a suit relating to pesticide consultations. The 2006 settlement applied specifically to the 2006 designated critical habitat and 564 other sections (mile squares) in California.

The economic analysis looks at a wide range of possible baseline costs for conserving the species, as required by Federal regulations, but which may not be considered in designating critical habitat. Baseline costs for protecting the species unrelated to the designation of critical habitat could be up to $1.83 billion. The analysis also projects possible consultation costs up to $425 million due to longer delays (two years) if the California Endangered Species Act (CEQA) is involved, although the frog is not protected under state law.

Release of the economic analysis provides a new opportunity for members of the public to comment on both the economic study and on all aspects of the proposed critical habitat rule.

The 2008 Service proposal calls for a 400 per cent increase in critical habitat from the 2006 rule, which designated 450,000 acres, but later was determined to be scientifically weak. The 2008 proposal was developed by Service biologists