STATEMENT OF ZEKE GRADER
THE PACIFIC COAST FEDERATION
OF FISHERMEN'S ASSOCIATIONS
TO THE SENATE ENVIRONMENT & PUBLIC WORKS
COMMITTEE, SUBCOMMITTEE ON FISHERIES, WILDLIFE AND WATER
9 May 2001
Washington, DC
The Endangered Species Conservation & Management
Act of 1995
Good Morning, Mister Chairman and Subcommittee members, my name is Zeke
Grader. I am the Executive Director for
the Pacific Coast Federation of Fishermen's Associations (PCFFA), representing
working men and women in the west coast commercial fishing fleet. We are a federation of many different
fishermen=s marketing associations, vessel owners
associations and fishermen=s cooperatives with member organizations as well as individual members in
ports from San Diego to Alaska.
The fishing men and women and their organizations that make-up our
federation are the economic mainstay of many coastal communities and
cities. PCFFA members represent at
least half a billion dollars in economic investments which generate tens of
thousands of family wage jobs -- not only in coastal communities, but far
inland as well. In other words, hard working men and women who help put
fresh, high-quality seafood on America's table, create a job base for coastal
communities, and help support a multitude of federal, state and local community
services through our taxes, all from the bounty of the seas.
The commercial fishing
industry represents a significant economic sector in this nation, accounting for well over $50 billion in
economic impacts and more than 700,000 jobs.
When combined with another $15 billion per year generated by the marine
recreational fishery, the whole offshore fishing industry now accounts for
about $65 billion per year to the U.S. economy.[1] In addition to commercial fishing, the recreational
sportfishing industry also contributes a mighty share to the U.S. economy. Fishing -- whether for sport or commercially
-- is big business, with a combined economic input to the national economy in
excess of $152 billion and supporting almost 2 million family wage jobs.[2]
Most of these jobs are to
one degree or another dependant upon strong protection of the biological
resources upon which they are based. In
other words, our industry would not exist -- nor would $152 billion dollars in
annual income and 2 million jobs in this economy that we generate -- without
strong environmental protections.
Our industry is a prime example of a basic economic principle:
The fundamental
source of all economic wealth is the natural environment. In the long-run environmental protection
does not destroy jobs -- it creates them and maintains them on a sustainable
basis for the future.
In other words, the
biological wealth of this country is its "natural capital." Like any economic capital, we can invest
it wisely and reap its benefits indefinitely, or we can allow it to dissipate
and waste it. Pushing species to the
brink of extinction -- and beyond -- not only wastes future economic
opportunities but helps destroy those industries we already have,
such as the Pacific salmon fishing industry.
The ESA is the law of final resort that prevents us as a society from
negligently wasting our irreplaceable "natural capital" -- and the
jobs that this "natural capital" represents, both in the present and
in our economy's future. Ultimately all
economic wealth comes from our natural environment. In the final analysis this is all humanity has, and all it has
ever had, from which to obtain its livelihood, and indeed its very existence.
The Endangered Species Act
(ESA) dispute is not really a clash between species vs. jobs, nor even between
public trust values vs. private
property rights -- fundamentally, the ESA dispute is a clash between
short-term profiteering vs. long-term and sustainable economic development. The ESA merely establishes limits beyond
which voracious human consumption should not go. That limit is the limit of "biological
sustainability." This is
also the basis of economic sustainability as well. As a society, we violate nature's biological
limitations at both our biological and our economic peril.
Each species pushed into
extinction is first and foremost a loss to the very fabric of our human food
chain. However it also represents a
lost future economic opportunity effecting our entire economy. The biological diversity of our natural
resources represents the foundation upon which many industries of the present
are maintained, but also upon which industries of the future will be built and
people of the future will be fed.
Wasting our "natural capital" dramatically impoverishes our
society by limiting our future industrial and economic growth.[3]
The commercial fishing
industry has seen the Endangered Species Act up close and in operation for many
years. Our industry is a highly
regulated industry. We are, for
instance, far more strictly regulated under the Endangered Species Act
(ESA) than the Northwest timber industry, and for many more species. While the timber industry has recently
suffered through curtailments caused by one or two ESA listings, the fishing
industry has long been dealing with the impacts of listings for chinook salmon
in both the Columbia and Sacramento Rivers, sockeye salmon in the Columbia, sea
turtles in the Gulf, marine mammal species protected under both the ESA
and the Marine Mammal Protection Act (MMPA), and various species of seabird
protected under both the ESA and the Migratory Bird Treaty Act (MBTA). On the west coast, we have also learned to
cope with ESA listings for coho and sockeye salmon and some runs of chinook as
well. The cumulative effects of this
multitude of listings is, frankly, far more restrictive than any past
restrictions caused merely by spotted owls or marbled murrelets.
There is, in fact no
industry more regulated under the ESA presently, nor more likely to be
regulated in the foreseeable future, than the commercial fishing industry. We
can therefore speak with some authority, as a regulated industry, on how well
the ESA works. Yet in spite of
short-term dislocations created by listings,
we view the protections offered by the ESA as vitally important in
protecting and preserving our industry, our jobs and our way of life for the
long term. It is species declines and the forces which cause those
declines which are the real enemy, not the ESA. The ESA is only the messenger.
It is, in fact, axiomatic
that a species only qualifies for listing under the Endangered Species Act
because it faces extinction. This point
seems to have been missed by many who are calling for the elimination or
curtailment of ESA protections. The
best way to prevent listings, then, is to prevent the species' decline in the
first place. Limiting or repealing the
ESA itself only throws out the primary tool to achieve recovery, in other words
shoots the messenger, but does nothing to reverse the underlying declines. In other words, the ESA is only the warning
bell and not the problem itself. Disconnecting
the warning bell is not a viable response to an emergency in the making.
72,000 SALMON JOBS AT RISK -- SALMON AS A
CASE
IN POINT FOR HOW THE ESA PROTECTS JOBS
Salmon, once the economic
mainstay of both the commercial and recreational fishing industry in the west
have been reduced by decades of short-sighted human actions to a mere shadow of
their former glory, largely as a result of a multitude of cumulative on-shore
causes. The great salmon runs of the
east coast are all but gone, more than 98% of those runs now extinct.[4]
Salmon in east coast restaurants are almost always inferior Norwegian salmon
raised artificially -- which exports to Norway thousands of jobs that should
have belonged to American fishermen.
The virtual extinction of the east coast=s once abundant salmon runs, which once extended well down into Georgia
in colonial times, and the elimination of an entire segment of the fishing
industry in the process, is one of our greatest American tragedies. The efforts now to bring those enormously
valuable biological resources back from the brink through their listing under
the ESA, and the modification of other industrial sectors to make that
possible, is well worth the effort.
The destruction of salmon
spawning and rearing habitat has also been ongoing and pervasive in the west
for many decades -- it is just a few decades behind the east coast but going
along the same path leading to extinction.
Every year fewer and fewer salmon survive the silting up of their spawning
grounds by inappropriate or poorly planned logging, grazing and road building
practices. Fewer still survive the
nightmare ride through hydropower turbines and slack-water reservoirs in the
more than 30 major federal and state Columbia River Basin hydropower dams. In
the eight federally operated Columbia and Snake River mainstem dams alone, each
dam's turbines and hot water reservoirs combined kill up to 15% of the
outmigrant fish making their long journey to the sea.[5] 3,000 miles of prime salmon spawning streams
in the Sacramento Basin have now been reduced to less than 300, and much of
what remains is biologically damaged or suffers from too little cold water
during critical spawning times.
The relatively few wild
salmon which remain alive after all these accumulated impacts are then subject
to otherwise natural ocean fluctuations (El Ninos) which, combined with all
the upstream human-caused assaults, can be the final blow to an already
highly stressed salmon ecosystem. Once
the numbers of salmon in a stream drop below a certain threshold, the remaining
fish cannot reliably find each other to mate.
Even though many fish remain, the run has then dropped into what is
called the Aextinction vortex@ and numbers drop precipitously from that
point onward -- only major intervention can then save them. This is precisely what seems to be happening
over much of the west coast and has happened long since for salmon over most of
the Atlantic seaboard.
Salmon are the most
sensitive to their environment in the egg stage and as juveniles when they are
still in freshwater streams just after spawning. Some species (such as coho salmon) spend a fairly long time in
freshwater streams since they must "overwinter" there for up to 18
months before migrating out to sea.
Even once they leave these freshwater streams, salmon must still spend
additional time in coastal wetland estuaries and marshes in order to gradually
adapt to life in salt water. They are
"anadromous" fish, which means they are hatched in freshwater, then
adapt to salt water, then return again to freshwater to spawn. In the ocean they are relatively large and
relatively safe, but in inland streams they are subjected to every
environmental problem created by mankind, in addition to natural predation and
other natural impacts. Salmon evolved
for drought, for El Ninos, to avoid
predators -- but have not evolved to prevent themselves from being sucked into
irrigation pumps, nor from being destroyed by hydropower turbines, nor stranded
without water in unscreened irrigation ditches. They also have not evolved to survive water pollution, oil spills
and the many other unfortunate environmental problems created by modern
civilization.
Roughly speaking, we have
lost about 80 percent of the productive capacity of salmon streams in the west
coast as a direct result of various causes of watershed destruction. According to a 1991 comprehensive scientific
study by the prestigious American Fisheries Society (AFS), at least 106
major populations of salmon and steelhead on the West Coast are already extinct. Other studies place the number at over
200 separate stock extinctions in the Columbia River Basin alone. The AFS report also identified 214
additional native naturally-spawning salmonid runs at risk of extinction in the
Northwest and Northern California: 101 at high risk of extinction, 58 at
moderate risk of extinction, and another 54 of special concern.[6] In a recent extensive GIS mapping study of
present salmon habitat occupied versus historical habitat, based on the AFS
data and updates, the data indicated the following distributions across the
landscape:
Status of Salmon Species in the Pacific
Northwest & California
Current Distribution as a Percentage of Historic Habitat
Species |
Extinct |
Endangered
|
Threatened |
Special
Concern |
Not
Known to be Declining |
Coho |
55% |
13% |
20% |
5% |
7% |
Spring/Summer
Chinook |
63% |
8% |
16% |
7% |
6% |
Fall
Chinook |
19% |
18% |
7% |
36% |
20% |
Chum
salmon |
37% |
16% |
14% |
11% |
22% |
Sockeye |
59% |
7% |
3% |
16% |
15% |
Pink
salmon |
21% |
5% |
<1% |
<1% |
73% |
Sea-run
Cutthroat |
6% |
4% |
61% |
29% |
0% |
Winter
Steelhead |
29% |
22% |
7% |
18% |
24% |
Summer
Steelhead |
45% |
5% |
5% |
27% |
18% |
According to GIS mapping, Pacific Northwest salmon are already extinct
in 38% of their historic range, between 50-100% of these species are at risk or
extinct in 56% of their historic range, and in only 6% of their historic
habitat range are fewer than 50% of these salmon species at risk or extinct.[7] The conclusions of this study (the best and
most complete science to date) are chilling --
9 out of 10 known species of Pacific salmon will be extinct in the lower
48 states in the near future unless land use patterns pressing those stocks
toward extinction are reversed.[8]
The productive capacity of
the salmon resource has always been enormous.
Even as recently as 1988, and in spite of already serious existing
depletions in the Columbia and elsewhere,
the Northwest salmon fishing industry (including both commercial and
recreational components) still supported an estimated 62,750 family wage jobs
in the Northwest and Northern California, and generated $1.25 billion in
economic personal income impacts to the region.[9] An additional estimated job loss from the
Columbia River declines alone had already occurred by the 1988 baseline year,
amounting to another $250 -- 505 million in annual economic losses as well as
the destruction of an additional 13,000 to 25,000 family wage jobs. These jobs had already been taken out of the
economy as a direct result of dam-related salmon declines in the Columbia basin
prior to 1988.[10]
Hydropower and irrigation
dams are probably the major leading factor in the collapse of the salmon
fishery on this coast. Historically
almost one-third of all west coast salmon were produced in the Columbia and
Snake river systems, making that river the richest salmon production system in
the world. Now, however, in the Columbia and Snake rivers the hydropower system
accounts for about 90% of all human-induced salmon mortality, as opposed to
only about 5% for all commercial, recreational and tribal fisheries combined.
Official figures from the Northwest Power Planning Council indicate that the
Columbia River dams kill the equivalent of between 5 million and 11 million
adult salmon every year, with several million more killed by a variety of dam
related habitat loss factors in the upper watersheds of the region.[11] Many millions more fish are killed in the
Central Valley Project and in the Klamath Basin by loss of in-stream flows.
Another problem is wetland
losses throughout the west coast.
California has already lost 91% of its original wetlands, Oregon has
lost 38% and Washington has lost another 31% and the remaining percentages of
original wetlands have been severely compromised in their biological functions.[12] These wetlands are vital in protecting
overwintering salmon, helping them survive droughts and (for saltwater
wetlands) helping them adapt to ocean conditions. A main factor in the destruction of the coastal salmon stocks in
the Northwest has been the rampant destruction of the area's wetlands. Loss figures for the most valuable coastal
and estuarine wetlands are much greater than the overall state loss averages.
There has been a lot of
press recently about court ordered irrigation cutbacks in the Upper Klamath
Basin that have been imposed to protect salmon and other fish from extinction,
with the farmers blaming the Endangered Species Act for problems that are
clearly caused by a drought. In fact,
the Courts under the ESA have only been saying that, especially in a drought year,
natural public resources should have enough water to survive. In short, the the court said that the
irrigators cannot take all the water for themselves, drying up the rest of the
river system at the expense of everybody else.
In other words, the ESA
requires the protection of the very ecosystem which supports all of these
economies, and forbids wasting all of our natural resources (which are owned by
the public in general) simply to benefit a few farmers for a few years. It just makes no sense to keep irrigating
croplands as usual in the midst of what has become the Klamath Irrigation
Project=s worst drought in its entire 90 year
history, particularly when the result will inevitably be a dried up river, dead
lakes, the final extinction of several commercially valuable species and the
total destruction of a whole downriver fishing economy that also supports
thousands of coastal jobs B all this destruction just to keep feeding a bloated federal irrigation
project that produces federally subsidized surplus crops for which there is now
little or no market.
The relatively large salmon
harvest projected this year in Central California is an instructive exception
to these decline trends. The primary
cause of those increases has probably been water reforms in the Central Valley,
driven by the listing under the ESA several years ago of the devastated native
runs of Sacramento winter-run chinook salmon and the delta smelt. Although some of those reforms are now
embodied in the Central Valley Project Improvement Act, the ESA listing predates
the CVPIA by several years and forced these reforms to be made. Greater in-stream smolt survival coupled
with fortunate ocean conditions have thus given us a large harvestable run and
put a lot of California fishermen back to work while other areas along the west
coast where habitat loss and water diversions still continue are still in
decline.
In fact, the salmon
rebounds in recent years from the California Central Valley is an ESA success
story. ESA driven water reforms in
California were long overdue, are starting to have their effect, and are now
resulting in abundant and sustainable salmon harvests once again off the shores
of California. The ESA has thus
resulted in restoring jobs, communities and a tax base once again to schools
and public services in many coastal fishing-dependent rural ports. There is a long way to go, but none of this
could have been done had not the ESA forced society into a better balance in the protection of our fundamental Anatural capital,@ our priceless natural resources.
ESTIMATES OF SALMON JOB LOSSES DUE TO LACK
OF PROTECTION OF SALMON RESOURCES
California=s returning salmon harvests are certainly
encouraging, and show us what better resource protection can accomplish. However, with the one major exception
off California, and a few very minor
mostly sportfishing exceptions in Washington and Oregon, most of the entire
ocean going salmon fleet was closed down or severely restricted since 1994 because of these declines, particularly of coho
salmon which is now ESA listed. Even
with some harvests returning in central California, we estimate that coastwide
we have still lost 90% of our industry income from the commercial fishery
as compared to the 1976-1993 averages -- which translates to loss of 90% of the
jobs created by the commercial salmon industry as a whole. The recreational salmon fishing industry has
also suffered a similar decline of 70% in that same time period, with some
areas (such as central Oregon) also suffering years of nearly complete
closures. While there is some mismatch
of figures (due to different averaged years) these two figures combined will
give us a pretty good estimate of total salmon industry job losses since 1988. Doing the calculation we get job losses as follows:
15,250 x 90% = 13,725 jobs lost since 1988 in the commercial salmon
fishery
47,500 x 70% = 33,250 jobs lost since 1988 in the recreational salmon
fishery
======
46,975 jobs lost overall since 1988
In additional, habitat losses and hydropower mortality in the Columbia
and Snake rivers have also resulted in up to 25,000 lost jobs. Adding these lost jobs to the above figures
for losses in the Columbia River which occurred even before 1988 indicates a
total west coast job loss within the last two decades of approximately 72,000
family wage jobs.
In other words, roughly 47,000 jobs have been
lost in the west coast Pacific salmon fishing industry (including both
commercial and recreational) just since 1988, with a total of 72,000
fishing-generated family wage jobs lost -- including losses due to the current
operations of the Columbia and Snake river hydropower system -- over the past
three decades.
Overfishing is not a likely
cause of these declines. Had
overfishing been a major contributing factor in salmon declines (as some have
claimed) then past harvest closures should have resulted in substantial
rebuilding of populations. However,
there is no evidence that these closures resulted in substantial population
increases -- indicating that the limiting factors are in the watersheds, not in
ocean or in-river harvest levels.[13] There are also a number of other
indications leading to the same conclusion, including: (a) the most precipitous
declines have occurred primarily in the most inshore habitat sensitive species
(coho salmon) as opposed to chinook salmon which spend much less time in inland
watersheds and whose populations are still relatively robust; (b) precipitous
declines have also occurred in species for which there is no sport or commercial
harvest (searun cutthroat) but which originate in inland watersheds in
which there has been substantial human disturbance (primarily clearcut timber
harvesting and increased stream siltation from logging road washouts).
When seasons remain closed,
the enormous economic investment already put into the Pacific fishing fleet
goes to waste. Just in the Columbia
River gillnet fleet alone an estimated $110 - $129 million dollars in capital
assets is invested.[14] Yet the in-river gillnet fleet is only a
relative handful of small boats and its capital investment is certainly only a
very small fraction of the overall capital invested in the entire ocean salmon
fishing fleet. This figure does not
even include buyer and processor investment.
Additional salmon extinctions essentially mean the bankruptcy of whole
fishing-dependent coastal communities and the waste of a tremendous capital
investment built up over generations.[15]
Again these extinctions
represent lost jobs, lost family income and lost local tax revenues suffered by
fishing communities as a result of poor environmental protection of west
coast salmon. These losses are
being suffered by real people, many of them third or fourth generation
fishermen, who suddenly find they cannot feed their families, pay their home
and boat mortgages or help maintain their communities. Better protection of salmon and their
habitat (through the ESA and other strong environmental laws) will help restore
these 72,000 jobs to the region and rebuild these local economies.
WHY THE FISHING INDUSTRY NEEDS THE ENDANGERED
SPECIES ACT -- $152 BILLION/YEAR
AND 2.0 MILLION JOBS AT RISK
Most fish species spend
only part of their lives in mid‑ocean.
During their juvenile stage, most
live and thrive in the nearshore environment of streams, rivers and
estuaries. Some, like salmon,
reproduce and grow far inland in fresh water streams hundreds of miles
from the ocean. However, salmon are
just one example of commercially valuable species that are also dependent on
inshore or nearshore habitat quality.
All around the country, our
industry is utterly dependent on species which themselves require healthy
watersheds and estuaries for the most critical parts of their life cycle. Nearshore waters, including rivers, streams
and coastal wetlands, are essential nursery areas for fully 75% of the entire
US commercial fish and shellfish landings. These sensitive ecosystems are
valuable national assets which contribute about $46 billion per year to the US
economy in biological value (including natural flood control and filtration of
pollutants), as well as providing its healthiest food sources. Salmon are only one part of this whole
economic picture, and only one of many commercially valuable species which need
protection. The bottom line protection
of all these species is the Endangered Species Act.
All the nation's $152
billion fisheries have been put at risk as a result of the continuing
destruction of fish habitat in the nation's rivers, estuaries and coastal
ecosystems. This destruction has
already led to billions of dollars in lost revenue to the nation every year,
lost jobs, lost food production, and lost recreational opportunities. The collapse of the salmon fishery is only a
small part of this overall habitat loss problem.
Nor is coastal
habitat loss the only problem.
Our entire inland freshwater fish resource is also in serious
trouble. According to studies
by the prestigious American Fisheries Society, roughly one-third of 790
known species of freshwater fish in the U.S. are in danger of extinction or of
special concern. In
the case of a whole family of
nonanadromous (i.e., resident) salmonids, more than 50% of all known U.S.
species in that family are close to extinction. Within the largest known family of fish (the Cyprinidae),
which include 29.2% of all known fish species in the U.S., the number of
species classifiable as endangered (7.2%), threatened (9.4%), of special
concern (10.8%) or already extinct (3.3%) totals 30.7% of this entire large
family of fish species. Of the 18
states with greater than 10 imperiled fish species, 10 are located in the South
and 5 in the West. The 11 states with
the highest number of imperiled fish species are (in descending order) Nevada
(43), California (42), Tennessee (40), Alabama (30), Oregon (25), Texas (23),
Arizona (22), Virginia and North Carolina (21 each), and Georgia and New Mexico
(20 each).[16]
This country is in the midst of an ecological disaster
which is causing tremendous economic losses throughout the nation in this and
many other resource dependent industries.
The large number of the nation=s fish and wildlife which qualify for listing
under the ESA is just the symptom of this overall ecological disaster.
The Congress and the
Administration need to make a serious commitment to the protection of those
habitats and ecosystems that determine the future productivity of fish and
shellfish resources in the U.S. If this
commitment is made, at least a doubling of anadromous fish and other near shore
dependent marine fish and shellfish populations of the "lower 48"
states can be expected. This could
produce an additional $27 billion in annual economic output (above and beyond
the current level of $152 billion) and more than 450,000 new family wage jobs. [17]
Environmental regulations
exist because after decades of neglect and pollution, policy makers finally
realized that a healthy environment is the ultimate source of the nation's
economic wealth, its food and the well-being of its citizens. When all other efforts to save these
valuable biological resources fail, however, the final safety net is the Endangered
Species Act (ESA). In spite of the
problems the ESA has created for individual fishermen, it is also the last hope
for the restoration of whole industries (such as salmon fishing) in many areas. Without a strong ESA, the only available
remedy for species recovery is closing down the fishery, even though the real
problems lie elsewhere and are caused by rampant destruction of habitat.[18]
This is exactly what has
happened to the salmon industry to date ‑‑ as onshore habitat
declined, as fewer and fewer fish survived to even reach the ocean, it has been
the fishermen who have been cut back over and over again, and who have almost
singlehandedly paid the price of inland environmental destruction on a massive
scale. This is because under the
Magnuson Act fishery managers can only manage fishermen ‑‑ they
have no legal jurisdiction over actions onshore which destroy the biological
foundations of the fishery itself.[19] Only the ESA gives them the authority to
modify or curtail such actions.
Thus without a strong ESA,
there will never be salmon recovery in the Northwest, and the approximately
72,000 lost salmon jobs -- which the salmon resource could still generate in
this region with proper protection of the resource -- would be gone forever. In
short, salmon mean business, and it pays to protect them. Without the ESA to drive recovery, however,
you can kiss the entire Northwest salmon industry -- and many other components
of the entire nation's $152 billion/year fishing industry -- goodbye!
The fishing industry
represents a significant economic contributor to America=s economy which is dependent upon a healthy
environment. The ESA is not the enemy,
it is only the messenger. Listing a
species is like dialing the 911 number when you need an ambulance. It should be used rarely, but when it is
needed it is real handy to have an emergency number to call. Often this can mean the difference between
life and death.
THE "ENVIRONMENT VS. JOBS" ISSUE IS
A FALSE DICHOTOMY --
THE ESA DOES NOT CAUSE SUBSTANTIAL ECONOMIC
DISRUPTION
There is absolutely no
evidence that the ESA seriously impacts state or regional economies, and every
reason to think that it does not. For
instance, a study by the MIT Project on Environmental Politics and Policy,
which looked at the statistical relationship between the number of species
listed in each state as compared to that state's economic performance (over the period of 1975-1990) concluded:
"The
data clearly shows that the Endangered Species Act has had no measurable
economic impact on state economic performance.
Controlling for differences in state area, and extractive industry
dependence the study finds that states with the highest numbers of listed
species also enjoyed the highest economic growth rates and the largest
increases in economic growth rates....
The one and a half decades of state data examined in this paper strongly
contradict the assertion that the Endangered Species Act has had harmful
effects on state economies. Protections
offered to threatened animals and plants do not impose a measurable economic
burden on development activity at the state level. In fact the evidence points to the converse...."
The author of that study also noted that actual ESA listings are
themselves only affecting a very small number of development projects
undertaken and that, in economic context, these impacts are very small indeed
in comparison to other much more major factors:
"In
fact, for every tale about a project, business, or property owner allegedly
harmed by the efforts to protect some plant or animal species there are over
one thousand stories of virtual 'non-interference.' In reviewing the record of 18,211 endangered species
consultations by the Fish and Wildlife Service/National Marine Fisheries
covering the period 1987-1991 the General Accounting Office found that only 11%
(2050) resulted in the issuance of formal biological opinions. The other 89% were handled informally --
that is to say the projects proceeded on schedule and without interference. Of the 2050 formal opinions issued a mere
181 -- less than 10% -- concluded that the proposed projects were likely to
pose a threat to an endangered plant or animal. And most of these 181 projects were completed, albeit with some modification in design or
construction. In short, more than 99%
of the projects reviewed under the Endangered Species Act eventually proceeded
unhindered or with marginal additional time and economic costs. Given the political and economic screening
that occurs in listings cases it is not surprising that no measurable negative economic
effects are detectable....
Furthermore local economic effects must be
considered in context. Hundreds of
state and federal policies have far more injurious impacts on local economies
than wildlife protection. For example,
the recent series of military base closings have had economic effects hundreds
of times greater than all the listings during the 20-year life of the
Endangered Species Act. Even greater
economic and social harm resulted from the ill-conceived deregulation of the
savings and loan industry during the 1980's.
The number of jobs lost to leveraged buy-outs in the 1980's exceeds by
many times the wildest estimates of jobs lost to endangered species; and no
social good was accomplished in any of these cases." [20]
In the case of the fishing
industry, as well as many other environment-dependent industries, judicious
application of the ESA to protect the biological resources we depend upon can
add a substantial number of jobs to the regional economy. At least 72,000 additional salmon-generated
family wage jobs can be restored to the west coast by taking steps under the
ESA to restore and recover the great salmon runs which once made this region
the envy of the world. Without the ESA
to drive recovery, however, this economic revitalization would likely never
happen.
PROBLEMS WITH THE ESA AND THEIR SOLUTIONS
I think all sides of the
debate will admit that the Endangered Species Act is not a perfect law. As a regulated industry ourselves, we
certainly know firsthand some of the problems that the current act has created,
and are seeking to make the act work better and more efficiently. However, what should not be in question is
the need for the act itself. The
problems with the act are not that it is too strong, but that it is too
bureaucratic and too poorly funded to accomplish its purposes efficiently and
with the least amount of economic pain.
As a regulated industry
organization which also strongly believes in the importance of the goals of the
act, we also believe the ESA needs improvement in a number of ways, including
the following:
(1) The ESA Should
Promote Species Recovery, Not Mere Maintenance on Indefinite Life Support
-- The principal flaw of the ESA is that it establishes a goal far short of
actual recovery of species. The stated
goal of the ESA is to prevent extinction and to establish plans for the
"conservation and survival" of listed species. This minimal level of
conservation does not result, in many cases, in ultimate population
recovery. Under the current
conservation standards, more and more species are thus pushed toward, and
indefinitely maintained, just short of the line of extinction. Massive last ditch rescue efforts begun when
a species is already hovering over the abyss of extinction is a much
more expensive proposition than to simply keep the species well-distributed in
several self-reproducing and interbreeding populations from which the species
will perpetuate itself naturally and at no cost to humans. Prevention is always cheaper than cure.
(2) There Should Be Recovery Plan Deadlines --
Recovery plans do not exist for most listed species, even many years
later. How can any species be recovered
enough to delist them without a plan?
This is a recipe for keeping species on the ESA list forever, just
perpetuating regulatory uncertainty. Regulatory uncertainty is in many
instances the cause of more economic dislocation than the species conservation
measures themselves would be once implemented.
At present there are no
statutory deadlines for the adoption of recovery plans, thus perpetuating
that uncertainty. For an industry such as ours or the timber industry or for
farmers, this uncertainty makes it very difficult to develop long range
business plans or to obtain business financing. The law should therefore require the Secretary to prepare within
18 months of listing a final recovery plan that incorporates the Recovery
Target document and all implementation plans, and which also contains
enforceable deadlines for all action items.
The first step toward a
recovery plan is the identification of and designation of >critical habitat.= This
designation puts landowners on clear notice as to what will likely be required
of them as a contribution toward recovery, and helps identify and ultimately to
resolve ESA disputes. Designation of
critical habitat is a vital step in the ESA recovery process that needs to be
retained, as well as fully funded.
The law should also require
the Secretary to ensure to the maximum extent practicable that the combined set
of recovery implementation plans will, when implemented, achieve recovery of
the species within a reasonable time frame.
The recovery plan should identify and prioritize actions that would have
the greatest potential for achieving recovery of listed species.
Recovery plans should
also emphasize implementing conservation measures which provide the greatest
benefit with the least economic impact first, as well as include nonregulatory
incentive-based efforts where appropriate.
Again these are all principles that, as a regulated industry, we
strongly support so long as the goal of ultimate and timely recovery is kept
central to recovery efforts.
(3) Assuring Cost Effectiveness and Minimizing
Conflicts with Private Landowners -- Most of the conflicts between private
landowners and the government with respect to species protection are more
perceived than real. Nevertheless,
there is a need to minimize those conflicts to the extent possible as well as
providing for conservation measures which achieve the recovery goal as cost
effectively as possible. Some of the
measures that should be incorporated into the law to achieve these goals
include the following:
The law should direct the Secretary to
emphasize the role of federal actions and public lands in achieving recovery. The law should be clearer in specifying that
federal agencies have a responsibility to use their existing programs to foster
the implementation of recovery plans to the degree they can.
If critical habitat occurs on privately held
lands, the law should direct the Secretary to identify land for acquisition in
the recovery plan (including any land interests less than fee title, such as
conservation easements) pursuant to section 5 of the Act, from willing sellers,
and should set priorities for acquisition.
This process should be well funded and the administrative procedures for financing these acquisitions
should be simplified. Many landowners
would be more than willing to help with recovery efforts if such financial
incentives were more readily available.
The law should also direct the recovery team and the Secretary, in preparing the
list of recovery actions, to consider
the cost effectiveness of conservation actions in order to identify ways of
reducing costs of recovery without sacrificing species preservation or recovery
goals.
Landowners should be encouraged to provide
habitat protection through a variety of incentive and financing programs,
including the following:
(a)
Establish a revolving loan fund for state and local government entities to
encourage such entities to develop regional, multi-species Habitat Conservation
Plans (HCP's).
(b) Enable landowners with proposed
activities consistent with an approved regional HCP to obtain expedited
approvals of those activities.
(c) Authorize the Secretary to enter into
cooperative management agreements with private landowners, providing financial
incentives for conservation measures above and beyond those required by the ESA. Conservation activities to be funded under
this provision would include those called for by an approved recovery plan, but
could also be more pro-active in their approach, rather than reactive as so
often the case once a species has been listed.
The Habitat Conservation Plan (HCP) procedure
is a good tool for landowners to restore some certainty into the process as
well as to provide for long-term protection measures. However, the current HCP process is deeply flawed and
includes too little public notice and comment.
Furthermore, HCP's can be inconsistent and even work at cross purposes
with approved recovery efforts elsewhere.
HCP=s are not even required, under present law,
to actually contribute toward the recovery of the species, thus shifting the
burden onto the backs of other landowners who get their HCP later or not at
all. The law should clearly require
HCP's to be both consistent with and contribute toward species
recovery as embodied in approved recovery plans and goals.
Both HCP's and recovery
plans may have to occasionally be updated and revised in light of new
scientific information or the results of plan monitoring. Current law is vague
on how to go about amending an HCP in light of new data -- including data that
indicate that the HCP itself is failing.
There should be a periodic review process, either automatically every 5
years or when triggered by new data indicating potential for further declines. During that review process, existing
recovery plans should be kept in full force, but the Secretary should propose
modifications to the plan to conform with any new standards. These proposed modifications should be
widely published for public comment and adopted into the recovery plan only
when they will promote equal or greater protection and faster recovery in a
more cost effective manner.
(4) Protection Should
Be Aimed at Endangered Ecosystems, Not Just Individual Species, So That the
Need for Future Listings Can Be Greatly Reduced B A species-by-species approach does not
generally work. Multi-species plans for
the protection of endangered ecosystems need to be developed so that those
species which are part of such ecosystems do not begin the slide toward
extinction to begin with. The ESA
needs to become an "endangered ecosystem" act as well. Protection measures should be wholesale, not
retail, in order to be cost effective.
(5) Funding for
Scientific Surveys and Recovery Efforts Should Be Greatly Improved B Generally the listing process is a good one,
and it needs to be maintained as fundamentally a scientific decision making
process, not a political or economic one.
Far from being missing from the ESA, economic factors come into play at
almost every other decision making process, only the listing/delisting process
supposedly being truly free of such considerations. This makes sense: either a species is, or is not, headed for
extinction. How we get to recovery,
however, has a clear economic and social dimension, but the scientific fact of
population dynamics is an issue that can only be decided on a scientific basis.
Nevertheless, the process
would be better informed if there were more scientific data available earlier
in the process on the particular species under consideration. This requires better funding for such things
a upfront biological surveys, species status reviews and peer reviews. In other words, if Congress wants a better
job done, it must properly fund the ESA and allow the agencies to do a better
job.
Likewise there needs to be
ongoing funding not only for the recovery plan implementation process itself,
but for better scientific monitoring so that it is possible to tell whether
recovery efforts are in fact succeeding.
Adaptive Management (i.e., learning from past mistakes) is simply not
possible without adequately funded and ongoing scientific monitoring.
(6) Alternative Dispute Resolution for
Property Owners -- In our
experience, and in spite of anecdotal media portrayals otherwise, there are
really relatively few cases in which there are serious conflicts between the
needs of ESA species and the rights of landowners. However, there are rare instances in which property owners were
unfairly treated or in which government agencies made inappropriate decisions. This is inevitable in any large
administrative process, and generally to sorts of disputes that courts are
intended to resolve.
However, there should be a
speedy and cost effective way to put these problems to rights. Some internal dispute resolution mechanism
would be very helpful for landowners to minimize unnecessary conflicts and
resolve disputes. Some of these
mechanisms already exist but are rarely used.
There is, for instance, an existing Alternative Dispute Resolution
process within the U.S. Court of Claims which allows aggrieved landowners to
present their case to a Claims Court judge without needing a lawyer and without
a lot of paperwork. This process does
not even require a trip to Washington, DC -- it can be done by fax and phone. At a minimum, the ESA process ought to
formally include this type of mechanism as a "safety value" to
prevent problems from escalating out of control.
(7) All Known
Information about the Existence and Range of Threatened or Endangered Species
Should Be Available to the Public from a Centralized Data Source --
The process of making a listing decision is (or should be) purely a scientific
judgment call, based on the best scientific and commercial information
available. Though landowners frequently
complain about the science, we believe the trustee agencies generally do a good
job of gathering and using the best science.
Generally we find that when landowners complain about >junk science= what they are really saying is that the scientists either do not agree
with their own biased viewpoints, or that the landowner does not fully
understand the science behind the decision.
Also, for many rare species even the best available scientific data can
be very spotty and full of data gaps, simply because the species has not been
well studied. It is generally only after
a listing, and all the extra attention (and potential funding) that such a
listing brings with it, that substantial scientific resources are brought to
bear trying to study many of these species.
However, we do not feel
that the trustee agencies generally do as good a job of making the scientific
data base used in the decision making process as fully available to the public
as it should be. In the past this was
because the tools for wide dissemination of voluminous scientific reports and
species surveys was seriously deficient and expensive. In today=s increasingly digital world, there is no excuse for this. Today, voluminous scientific documents can
readily digitally scanned and converted to CD-ROM format and reproduced from
that format for a few dollars a copy.
The data bases can also be made available for easy public consumption on
the Internet. All these techniques are
being increasingly used by federal agencies, and this trend should be
encouraged and funded. The more data is
freely and cheaply available to members of the public the more transparent the
process will become and the more trust in the process itself the public will
have, even if some disagree with the policy outcomes.
Information depositories
should be created (perhaps made available through the National Biological
Service and administered through state agencies) so that prospective purchasers
of property would be able to ascertain quickly and inexpensively whether or not
ESA listed species are known to exist on the property they are considering
purchasing. Similar state-based
information services are already available in states like California, through
the local permit process. In theory, it
would be possible to have all this information in readily searchable form with
a quick computer inquiry for a very minimal fee. Some of this is being implemented now, as for instance the Ceres
information system maintained by the State of California, or the Streamnet
system run by the State of Oregon, both of which include extensive GIS
databases available on the Internet.
Most land use conflicts
result when landowners have invested substantial money and resources in a
development project and feel that they have no choice except to proceed in
order to recoup their investment. If a
prospective landowner know before close of escrow whether or not there
might be conflicts between development plans and fish and wildlife protection
obligations, he or she could plan accordingly, propose mitigation measures with
acceptance a condition of close of escrow, and in general take a number of proactive steps to minimize or eliminate any
potential future conflicts. The more savvy
real estate developers are doing that now.
Biological impact reviews of development plans by state fish and
wildlife or local agencies is also now routinely done in many states as part of
the permit process, and this additional data base would fit neatly into that
process.
(8) Citizen
Enforcement Is Crucial B The Federal government cannot be, nor should it be, everywhere all the
time. The role and value of citizen
enforcement of such statutes as the ESA and the Clean Water Act are well
established. We strongly object to
recent attempts by the Bush Administration to eliminate well established court
avenues for resolving ESA disputes or to make government compliance with such
court orders essentially voluntary.
This is a recipe for lawless disregard by our own government for its own
laws. The end result will be far more
litigation, and not less, including against the very agencies who become
scofflaws as a result of such a policy.
(9) From Beginning to
End, the Whole ESA Process Has to be Better Funded by Congress B The total funding for all ESA research and
recovery efforts now amounts to approximately 50 cents per US citizen per
year. Given the level of problems
the ESA needs to address, and given the potential economic return on this
investment, and especially given the economic dislocation that could
potentially result for more of the >train wreck=
policies of the past, Congress=s current levels of funding for species identification and recovery
borders on the ridiculous. 50 cents per
year is too little to invest in our biological future.
**********************
In summary, I ask you to
remember that fishing is America's oldest industry as well as one of its most
economically important resources.
Protecting fish means protecting jobs, protecting food production,
protecting commerce and protecting recreational opportunities. Without a fully funded and operational
ESA, it would be commercial and sport fishermen who will find themselves
endangered. Where the fish go, so
go the billions of dollars they produce and the jobs and communities they
support. Thank you for this opportunity
to testify.
esa-5-01zg.wpd
[1] Economic figures from Our Living Oceans, Report on
the Status of U.S. Living Marine Resources, 1992. NOAA Tech. Mem., NMFS-F/SPO-2. National Marine Fisheries Service,
NOAA, U.S. Dept. of Commerce, Washington, DC.
See also Analysis of the potential economic benefits from rebuilding
U.S. fisheries (1992). National
Marine Fisheries Service, NOAA.
[2] From Fisheries, Wetlands and Jobs: The Value of
Wetlands to America's Fisheries, a report by William M. Kier Associates
(March, 1998) for the Campaign to Save California Wetlands, available on the
Internet at: http://www.cwn.org/docs/reports/kier/kiertitle.htm. See also Maharj and Carpenter (1997), The
1996 Economic Impact of Sport Fishing in the United States, by the American
Sportfishing Institute, Washington, DC.
[3] The $152 billion/year fishing industry is but one
example of this principle. Fully 40% of
the known medically valuable pharmaceuticals, for instance, are derived from
natural sources. This represents an
industrial economy also in the hundreds of billions of dollars worldwide, as
well as many millions of lives saved.
Yet only about 1% of all the plant species now known have been
adequately surveyed for their pharmaceutical value, and only a small fraction
of all plant species have even been cataloged categorized. Many will likely become extinct before
that can be accomplished. The
booming biotechnology industry is also another example. Their stock in trade is genes. These genes, however, can only come from
known natural sources -- even the simplest gene is millions of times too
complex to synthesize in the laboratory by any known technology. Unknown plant species may contain genes for
disease resistance worth billions to a failing crop industry, or worth billions
more for any of a number of other unknown and as yet undiscovered industrial
processes. Once extinct, however, the
potential uses of the organism will never be known. Every species driven to extinction gives us fewer economic
options.
[4] The
last remaining wild salmon runs in the eastern coast of the U.S. are in a
handful of rivers New England. These
have recently been listed for protection under the ESA. There are in fact more dams in New
England than there are individual adult wild salmon returning to your rivers
-- about 2,500 wild salmon still return to New England, while there are about
3,000 medium and small dams in the same area, many of them obsolete. However, as we have recently seen by the example of
the removal of Maine=s Edwards Dam, once these dams are removed, the fish
runs can be restored. PCFFA has
recently spearheaded the removal of several dams in the California Central
Valley with the same result B provide them
decent habitat and the salmon will return.
[5] Both
the impacts from upper watershed activities ( improper logging, overgrazing,
road washouts, etc.) and the impacts from the hydropower turbines are largely avoidable.
Many of these practices are obsolete and unnecessary, and profits in these
industries will not greatly suffer from curtailing or mitigating these problems. The externalized damage caused by these poor
management practices is, in many cases, more of a harm to society (and to the
very industry itself) than any conceivable short-term benefits. As an industry ourselves, we are very
sympathetic to the current plight of timber works (many of whom are also
fishermen) -- however, it is clear that short-sighted logging, grazing and
hydropower practices conducted without any regard to stream protection
has been disastrous for our industry and for the economies of many coastal
communities. Most of the federal
hydropower dams were built without downstream salmon passage, and some (such as
the Grand Coulee Dam) without any upstream passage whatsoever. Salmon are now totally extinct above Grand
Coulee Dam, and this extinction was designed into the system. The fishing industry is federally regulated
on the basis of biological sustainability (Magnuson Act). It is time that these other industries were
as well. The current dislocations in
these industries are fundamentally caused by past unrestricted overuse of their
resource which now has to be balanced out and made more sustainable. The historical rate of timber harvesting
over the last few decades has been many times what is biologically sustainable
without doing major environmental damage to other industries. The fundamental problem with the timber
supply is that after decades of overcutting old growth timber, the timber
industry is simply out of big trees.
[6] Nehlsen,
et. al., 1991. "Pacific Salmon at
the Crossroads: Stocks at Risk from California, Oregon, Idaho, and California,"
Fisheries 16:2(4-21).
[7] From
GIS survey maps prepared by scientists on contract to The Wilderness Society,
and published in The Wilderness Society's report The Living Landscape:
Pacific Salmon and Federal Lands (Volume 2). Published by the Bolle Center for Forest Ecosystem Management
(October 1993). The report and data
were peer reviewed.
[8] The one
exception was pink salmon, which now only occurs in the extreme upper portion
of the Puget Sound area in limited populations. These are also (incidentally) the areas least affected by
development since much of that area is in Olympic National Park -- emphasizing
the direct correlation between salmon production and intact watershed
ecosystems.
[9] Figures
taken from The Economic Imperative of Protecting Riverine Habitat in the
Pacific Northwest (Report 5, January 1992) published by the Pacific Rivers
Council, based on official federal statistics from the Pacific Fishery
Management Council. The fishery related
job breakdown by state, according to that report, was:
State |
Commercial |
Recreational |
Total |
Oregon |
4,450 |
9,500 |
13,950 |
Washington |
6,800 |
14,250 |
21,050 |
N.
California |
4,000 |
19,000 |
23,000 |
Idaho |
Negligible |
4,750 |
4,750 |
Pacific
Northwest Total |
15,250 |
47,500 |
62,750 |
Commercial
fishery jobs are heavily concentrated in coastal areas. Recreational fishery jobs, while a larger
number, are more diverse and are distributed more diffusely throughout inland communities.
[10] From a
report titled The Costs of Doing Nothing: The Economic Burden of Salmon
Declines in the Columbia River Basin.
Institute for Fisheries Resources (October, 1996), based on figures from
peer reviewed reports by the Northwest Power Planning Council. Completion of the last main-stem federal
hydropower dams was in the late '70's, and none were built with adequate fish
passage. That study concluded that
salmon losses in the Columbia Basin to date have amounted to the removal from
the regional economy of between 13,000 and 25,000 jobs annually at a cost to
the economy of between $250 to 505 million dollars annually, which translates
to the loss of natural capital assets conservatively estimated as up to $13
billion.
[11] Northwest
Power Planning Council publication Strategy for Salmon, Vol 2, page 17
and Appendices D & E.
[12] Facts on wetland
losses by state from a report by the US Dept. of Interior entitled Wetland
Losses in the United States 1780's to 1980's by Thomas Dahl. California has lost a higher percentage of
its wetlands than any other state. If
only coastal or estuarine wetlands is included in these figures, each state's
wetlands losses would be much greater.
[13] Dr. Chris
Frissell, who did much of the GIS mapping for The Wilderness Society report
cited above, took an independent look at whether harvest reductions were a
significant factor in population dynamics for coho salmon. If overfishing were a significant cause of
population declines, then harvest reductions should be effective in rebuilding
depleted stocks. He concluded in his
analysis as follows:
"Overfishing is often cited as a
principle factor causing decline of salmon runs. However, there are few historical or recent records to indicate
that curtailment of fishing has lead to increased spawning abundance of coho
salmon. For example, curtailment of fishing seasons has been thought to have
reduced harvest-related mortality rates on Oregon coastal coho substantially
during the past decade. However, there
has been no evidence of increased spawner escapement during this period,
suggesting that fishing curtailment is at best merely keeping pace with rapid
habitat deterioration and declining productivity of coho populations."
(Pacific
Rivers Council petition for the coastwide listing of coho salmon, dated
10/19/93).
[14] Figures from Dr.
Hans Radtke, Ph.D., fisheries resource economist.
[15] There is also
a cascading effect of these salmon declines which impact Alaska=s economy as well.
Fishing is the leading industry in Alaska, greatly exceeding timber
production as a source of economic support for its communities. Much of that fishing industry is now
threatened because of international disputes with Canada over the collapse of
the Pacific Salmon Treaty (PST). That
treaty collapsed a few years ago primarily because of salmon losses in the
lower 48 states (particularly the losses from the Columbia). Oregon and Washington salmon tend to migrate
north toward colder water. Under the
PST as presently written, Canadian-origin fish caught in Alaskan waters are
supposed to be replaced by U.S.-origin fish swimming north into Canadian waters
from the lower 48. However due to widespread salmon declines in the
lower 48 states those replacement fish are much fewer in number than the fish
Canada is losing to the Alaskan fleet.
Thus the Canadians have demanded cutbacks in the Alaskan catch to
balance out their own losses. The
Canadians are quite capable of enforcing these cutbacks through mandatory
transit fees (already imposed for a short time last year) or even gunboat
boardings on the high seas (as in the east coast=s ATurbot War@
between Canada and the European Union just a few years ago). To date the only thing that has driven
salmon recovery efforts in the lower 48 is the threat or reality of ESA
listings. Without a strong
ESA-driven recovery of these depleted lower 48 stocks there is no hope of
Alaska long avoiding another Afish war@ with Canada with no end in sight. Were the ESA
itself to disappear, this international problem would still force shutdowns of
much of the salmon harvest in Alaska within the next few years. These shutdowns would be required not by the
laws of Congress but by the laws of nature.
[16] American
Fisheries Society, AStatus of Freshwater Fishes of the United States:
Overview of an Imperiled Fauna.@ Fisheries, Vol. 19, No. 1 (January,
1994).
[17] Figures from Marine
Fishery Habitat Protection - A Report to the US Congress and the Secretary of
Commerce (March 1, 1994), copublished by the Institute for Fisheries
Resources, East Coast Fisheries Foundation and PCFFA, with extensive
citations. Copy available from PCFFA
upon request.
[18] Nowhere in the nation is the link between inland
environmental protection and fish production more obvious than in the Gulf
states, where National Marine Fisheries Service scientists estimate that 98%
of the Gulf commercial seafood harvest comes from inshore, wetlands dependent
fish and shellfish. Louisiana's
marshes alone produce an annual commercial fish and shellfish harvest of 1.2
billion pounds worth $244 million in 1991.
Gulf shrimp clearly head the list of the region's wetlands dependent
species. Without strong wetlands
protection this extremely valuable commercial fishing industry resource would
eventually no longer exist in those states.
The shrimp industry is learning to cope with TED=s and other devices to minimize unwanted bycatch
problems. A far greater threat to that
industry comes from estuary and wetlands habitat loss. The ESA is a tool which (in the last resort)
can be used to halt and reverse these losses and protect that industry.
[19] Only
recently has this begun to change, with the >Essential
Fish Habitat= provisions of the Magnuson-Stevens Sustainable
Fisheries Act, but this authority is still only a weak consultation process
that allows fisheries management councils merely to comment on proposed federal
actions that would destroy fisheries habitat, not to stop them. There is no enforcement authority in these
provisions.
[20] Stephen
M. Moyer (March 1995). Endangered
Species Listings and State Economic Performance. Massachusetts Institute of Technology, Project on Environmental
Politics and Policy. Facts on actions
cited from US General Accounting Office (1992) Endangered Species Act: Types
and Numbers of Implementing Actions (GAO/RECD-92-131BR).