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Critical Habitat Impact Questioned

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Sonora, CA — The Tuolumne County Board of Supervisors voted to send another letter to the federal government regarding the Sierra Nevada Yellow-Legged Frog and the Yosemite Toad. The letter will focus on the recently released economic impact of the proposed endangered species listings.

The U.S. Fish and Wildlife “Draft Economic Analysis on Proposed Critical Habitat for the Sierra Amphibians” calls for 1,831,820 acres to be designated as critical habitat with an estimated economic impact of $630,000 to $1.5 million over 17 years (2014 to 2030). The draft summary states, “With 97 percent of the proposed critical habitat designated on federal lands, the estimated costs of the designations are largely associated with federal agency consultations for actions on federal lands such as fish stocking, water operations, grazing, and recreation.”

In Tuolumne County 327,907.39 acres and 149.17 non federal acres are proposed to be designated as critical habitat for the two amphibians. Ninety-four percent of the land to be designated as critical habitat for the endangered species is designated as Wilderness.

A draft of the responding comment letter from the Board says, “The economic analysis only evaluated the impact on the agencies (mostly Federal) required to enforce the designation and ignores the actual economic impact to forest users and the community. This is a procedural flaw and should be rectified in this analysis and in future endangered species impact analyses.”

District 1 Supervisor Sherri Brennan recommended that the letter make it clear the acres they want to designate are much larger than the current sites occupied by the species. Brennan said the area is also larger than the potential habitat of the two species.

Brennan wanted the comment letter to state that the financial impact would not be just on grazing but on all permitted uses such as timber (small sales made above 6,000 feet) recreation, and grazing. As stated in the agenda draft of the letter, “This would be detrimental to historical activities and to the local economy.”

A letter from the supervisors to the US Fish and Wildlife Service was recommended by the Tuolumne County Natural Resources Committee to “counter any extreme actions which could result from making this endangered species designation.”

According to the US Fish and Wildlife Service there will be more public hearings before publishing a final rule. The Service will have an independent economic analysis of the proposed critical habitat before the rule is completed.

Public comments on the economic analysis are due to the USFWS by March 11, 2014. Comments may be submitted online at the Federal eRulemaking Portal here The Docket Number for the proposed listing rule is FWS-R8-ES-2012-0100 and for the proposed critical habitat rule and draft economic analysis is FWS-R8-ES-2012-0074.