RE: Request for 90 Day Extension of Public Comment Period on Spotted Owl Critical Habitat to October 7 th 2012

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1 Congressman David Reichert 1730 Longworth House Office Building Washington, DC May 7 th, 2012 RE: Request for 90 Day Extension of Public Comment Period on Spotted Owl Critical Habitat to October 7 th 2012 Dear Congressman Reichert; On behalf of the National Forest Counties in Washington State we wish to take this opportunity to thank you for your continued help and support for the resource dependent counties, communities and school districts in our State. As you are aware, the U.S. Fish and Wildlife Service (USFWS) is preparing a revised designation of Critical Habitat for the northern Spotted Owl. The revised designation under consideration will double the current Critical Habitat area, include private lands and have an enormous impact on 17 counties: including the designation of over 4 ½ million acres in Washington State. In a memorandum to the Secretary of the Interior, Ken Salazar, (copy attached) President Barack Obama made clear his concerns about the economic impact of Critical Habitat on rural areas already hard hit with federal regulations. In the case of rural Washington, we have experienced over two decades of precipitous economic decline due to the rules and restrictions put in place under just the simple listing of the Spotted Owl, without any Critical Habitat designation. Our Counties have experienced enormous limitations on our ability to manage our Federal Forests. Since designation of Critical Habitat in 2007, emerging science, as well as the current proposed Critical Habitat Executive Summary, indicates that the Barred Owl poses as great a threat to the persistence of the Spotted Owl as modification of habitat. This, and other contributing factors that have led to the decline in the Spotted Owl population, need to be fully explored and accounted for in the current proposal. Minus an honest assessment, rural communities in Washington will incur additional economic losses, as well as loss of multiple uses on these lands, as restrictions to economic activities are further applied on the proposed more than 4 ½ million acres. Based on the President s memorandum and the short time frame involved to review the economic analysis by the USFW, we are asking that you request on our behalf, a ninety day extension for public input. We are in the process of preparing an in-depth review of the aggregated impacts of the Owl listing and Critical Habitat over the last 20 years. It is only with this information that the true cumulative and connected effects on the economic infrastructure and education opportunities in our State and region can be understood. Our review will not be limited to economic impacts only, but will also demonstrate the related deterioration of the region s physical and social infrastructure. Thank you for your consideration. Sincerely, Paul J. Pearce, WSAC President Skamania County Commissioner pearce@co.skamania.was.us Washington Counties Building 206 Tenth Ave SE Olympia, Washington Phone: Fax:

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5 Ken Salazar, Secretary of the Interior Department of the Interior 1849 C Street, N.W. Washington DC May 7 th, 2012 RE: Request for 90 Day Extension of Public Comment Period on Spotted Owl Critical Habitat to October 7 th 2012 Dear Secretary Salazar, As you are aware, the U.S. Fish and Wildlife Service (USFW) is preparing a revised designation of Critical Habitat for the northern Spotted Owl. The revised designation under consideration will double the current Critical Habitat area, have an enormous impact on 17 counties and will include over 4 ½ million acres in Washington. In President Barack Obama s February 28th memorandum to you, he made clear his concerns about the economic impact of Critical Habitat on rural areas already hard hit with rules, restrictions, and requirements. In the case of rural Washington, we have experienced over two decades of economic decline as rules and restrictions put in place under just the listing of the Spotted Owl, without Critical Habitat designation, have greatly limited our ability to manage our Federal Forests. Since the last designation of Critical Habitat in 2007, emerging science, as well as the current proposed Critical Habitat Executive Summary, indicates that the Barred Owl poses as great a threat to the persistence of the Spotted Owl as modification of habitat. The Barred Owl and other contributing factors that have led to the decline in the Spotted Owl population, needs to be fully explored and accounted for. Minus an honest assessment, rural communities in Washington will incur additional economic losses on the proposed more than 4 ½ million acres. On behalf of Washington s National Forest Counties; based on the President s memorandum, as well the short time frame involved to review the economic analysis by the USFW, we are requesting a ninety-day extension for public input. We are in the process of preparing an in-depth review of the aggregated impacts of the Owl listing and Critical Habitat over the last 20 years. It is only with this information that the true cumulative and connected effects on the economic infrastructure and education opportunities in our State and region can be understood. Our review will not be limited to economic impacts only, but will also demonstrate the related deterioration of the regions physical and social infrastructure. Thank you for your consideration. Sincerely, Paul J. Pearce, WSAC President Skamania County Commissioner pearce@co.skamania.was.us Cc; Governor Chris Gregoire Washington Senate and House Delegation Rachel Jacobson, Acting Assistant Secretary for Fish Wildlife and Parks Daniel M.Ashe Director, US Fish and Wildlife Service Paul Henson, State Supervisor, USFWS Washington Counties Building 206 Tenth Ave SE Olympia, Washington Phone: Fax:

6 Scope of Work to assess the Habitat Conservation Area review for the Northern Spotted Owl for the 61 County Owl Region Sierra Institute for Community and Environment will: 1) Review Industrial Economics previous work with a focus on 2008 HCA/designation of critical habitat project and associated court interpretations and suggested modification of the work. This will include review of Executive Order and exploration of how they take it a step further. 2) Review and discuss distinction of institutional analysis of critical habitat review and attendant socioeconomic impacts. There is value in advancing understanding an assessment of institutional ruling and impact on agencies and impact on communities and counties. Similarly, there is need for advancing understanding the implications of an analysis that appears to primarily focus on institutional implications and only secondarily and qualitatively focus on counties (and not communities). 3) Communicate directly with Industrial Economics to advance understanding of their work and assure they understand impact of focus of their work and the distinction described in 2 above. 4) Phase I: Develop descriptive statistics for the 61 owl counties focusing on changes from 1990 to Descriptive statistics will include examination of (but not be limited to the following): county and community populations student population county and school budgets SRS funding by county percent of budgets represented by SRS (and perhaps closer subanalysis of of communities with greater than 5% (or similar percentage) of their budgets comprised of Secure Rural School funding) SIC employment by sectors business diversity by employment changes over time of employment by key sectors employment/unemployment rates impoverishment represented by free and reduced lunch participation rates, poverty, and families receiving public assistance disaggregating county level data where possible to examine community impacts health indicators by county economic vitality through per capita or median income adjusted for inflation transfer income totals by county community capacity The bulk of the information will be collected through secondary data, with reliance of U.S. Census Data, state development departments, and county-level data collected by the states and 3

7 counties, among others. Some information, such as community capacity, will be collected using key informant interviews. There is inadequate time in phase I to do this in substantive detail, but some county and school officials, and other key informants such as economic developers will be interviewed. Phase II will focus on additional data analysis and more comparative analysis of 1990 to changes, including more detailed community capacity assessment, and analysis of communities assessed in Sierra Institute s work evaluating the effects of the Northwest Economic Adjustment Initiative and Secure Rural School and Community Self Determination Act. Time and budget permitting, Sierra Institute will conduct some limited case analyses. These will be based on previous Sierra Institute case studies in the region. 4