Oregon Cattlemen’s Association

 Endangered Species Act

 

1.  Oregon Cattlemen support amending the Endangered Species Act.

·  It shouldn’t be harder to remove a species from the ESA list than it was to get a species listed.

 

·  Recovery of a listed species should not become a burden to society.  Federal taking opportunities must be eliminated.

 

2.  Scientific facts, gained through field work and measurements, statistical comparisons, and a logical discussion of the results must be inserted into the ESA process.

 

·  Popular journals, literature reviews, government reports,  planning documents, government surveys, and simulated models are not  scientific information.  These types of printed literature “talk about” scientific information, but do not produce science facts.

 

·  Professional science journals require that specific criteria be met when manuscripts are submitted for consideration as a printed article.  For ESA listings, facts about species (if known) should be documented from this type of literature.  It is the “best available science”. 

 

·  Biological opinions, written about ESA listed species, are not documented scientific facts.  They are agency opinions expressed from the personnel’s experience and education. 

 

3. GRAY WOLVES:  Wolves kill game animals upon which recreation hunting fees depend. 

 

·  Oregon  will need to expend more money to remove animals that threaten public safety. 

 

·  Wolf management will create significant additional costs for Oregon state government.  (Monitoring wolves and their prey, endless studies, and surveillance in other states is costing $400,000-$800,000 per year in Montana.  We could experience a similar impact in Oregon.) 

 

·  Most significantly, Defenders of Wildlife are unlikely to continue their program of compensating operators for livestock lost due to wolf predation.  Oregon and the federal government will bear this cost unless we are allowed local control of wolf populations. 

 

·  There has been a 35% downturn in Oregon’s net farm income, eighth worst in all fifty states.  Farm expenses are up 15%.  Oregon agriculture endures a $158 million loss in farm gate income to predators each year.

 

4.  SALMON, BULL TROUT, REDBAND TROUT:  A recent OMB report states that the federal government has spent $3.3 billion on salmon recovery.  During the last few years the numbers of returning salmon have skyrocketed.  OMB stated that the runs may be due to ocean conditions and that the population declines were not due to “habitat” conditions on land.

 

·  Scientific facts, gained through field work and measurements, statistical comparisons, and a logical discussion of the results must be inserted into the ESA process. 

 

·  We can no longer afford to have a law that is implemented on the “whims” of an opinion.  Facts about the ocean conditions and the role it plays in a salmon’s life cycle has been known for many years.  Bull trout life history studies have not received extensive work and until the “surveys” are replaced by data the listing should be declared invalid.

Clean Water Act

 

1.  Guidelines and rules for water quality assessments being implemented at the state level under the direction of the EPA lack statistically sound procedures.

 

·  EPA has approved of the use of a “tally mark” system vs a statistical comparison for 303(d) listings of impaired water bodies.  In a study published in 2003, it was found that the tally method had an average  false rate of 35%  compared to 5% false rate using statistical comparison on listing a stream as polluted.  In other words 1/3 of impaired water listing was incorrect.  (Gibbons, R. 2003. A statistical approach for performing water quality impairment assessments. JAWRA 39:841-849.)

 

·  Using statistical testing methods a person can state that they are 95% confident that stream water is not polluted.  The 303(d) listings and assessment is a statistical decision problem and is not just a tally marking task.  Without statistical testing, false decisions about compliance will be made either in declaring a stream is in violation when it is not, or in declaring a stream is not in violation when in fact it is.  (Robertson, D.M. 2003.  Influence of different temporal sampling strategies on estimating total phosphorus and suspended sediment concentrations and transport in small streams.  JAWRA.  39:5:1281:1308)

 

·  Failure to properly identify impaired streams (ie false positive) results in not only unwarranted planning costs but also the cost of forgone benefits to society.

 

·  It has been estimated that further implementation of the Clean Water Act through the total maximum daily load planning  on 25% of TMDLs will cost $50,000.00 to $200,000.00 per plan, 65% will cost $300,000.00 to $400,000.00 and 10% will run $600,000.00 to $1,000,000.00 per plan.  Costs are figured on how difficult the TMDLs are. (Smith, E., Y. Keying, C. Hughes and L. Shabman. 2001. Statistical assessment of violations of water quality standards under section 303(d) of the clean water act. Environmental science and Technology 35:606-612. )

 

2.  EPA has “married” the Clean Water Act to the US Fish and Wildlife Service through the Endangered Species Act.  National Marine Fisheries Service led us to the alter and blessed the union and now extraordinary amounts of money and time are spent negotiating between the 3 agencies. 

 

·  Clean water and the science used to examine water purity does not rely the same natural laws as fish science.  EPA treats the two as being the same.  The fish have taken precedence over all other beneficial uses and there is little factual scientific information to back the agency opinions up.

 

·  The agencies have mixed the CWA “point sources” with “non point sources” and the two are not the same.  One can be controlled by preventing an input at a specific site and source.  Non point sources are ones from vast acres of land and in many cases are “natural” in a watershed system.  Non point source “fixes” to curb pollution are likely ones that cannot be fixed and should not be prevented.

 

·  The cost to the livestock industry and agriculture communities is growing at a rate that is threatening livelihoods.  Federal grazing allotments are being lost due to agency “opinions” that livestock harm fish habitat if they are near any water sources.  Streams are being fenced (cost = $4000 per mile) and in some areas 100-300 ft. riparian buffers are being proposed ($1000 per acre). For a landowner the costs to exist and make a living are mounting rapidly. 

 

Back to WEST

Back to Home Page