RCRC submitted comments to the U.S. Fish and Wildlife Service last week on the Economic Analysis of Critical Habitat Designation of the Sierra Nevada yellow-legged frog, the mountain yellow-legged frog, and the Yosemite toad.  RCRC has previously submitted comments on the listing and habitat designation of the three amphibians.  Sixteen of the seventeen counties listed for critical habitat designation are RCRC Member counties. 

The Economic Analysis reviews the cost of the time other federal agencies must take to consult with the wildlife agencies before authorizing activities within critical habitat, and ignores the underlying costs of listing a species under the ESA.  RCRC noted, among other things, that the utilization of the current federal methodology for economic analysis of critical habitat designation denies the Secretary the data needed to determine the real economic impact of critical habitat designation on the citizens and the economy of the seventeen affected counties. 

RCRC’s comment letter can be accessed here.

For additional information, please contact RCRC Legislative Advocate Kathy Mannion at 916.447.4806 or kmannion@rcrcnet.org.