2013-02-05_REVISION - M1985043

• Permit No: M1985043
• IBM Index Class Name: REVISION
• Doc Date: 2/5/2013
• Doc Name: FEDERAL REGISTER - HIGHLIGHTED
• From: OPERATOR
• To: DRMS
• Email Name: TC1
• Media Type: D
• Archive: No

Federal Register/Vol. 69, No. 168/Tuesday, August 31, 2004/Rules and Regulations 53201
related to the owl, but rather was
shutdown due to financial
mismanagement.
Our Response: Based on available
information, the injunction on timber
harvest on Navajo lands was one of the
factors contributing to the demise of
NFPI in 1994. However, there were
likely other factors contributing to the
shutdown of the mill operations. This
final economic analysis was not altered
in its assumption that the lack of
availability of timber from Navajo lands
was a factor in the shutdown of the mill
based on this comment letter. However,
in response to this comment, the
economic analysis has been revised to
attribute the NFPI shutdown to a variety
of factors, including the cessation of
timber harvest on Navajo lands.
(86) Comment: One commenter notes
that the termination of logging activities
and the subsequent fuel load build -up
over time has produced the potential for
wildfires that could devastate the entire
Lincoln National Forest. This
commenter provides supporting
information including estimates of lost
timber value, costs of fire management
activities, data on average number of
acres destroyed per fire from 1960-
2002, and fire suppression costs.
Our Response: The issue of impacts to
fire management activities is discussed
in Section 5 of the economic analysis.
The data provided by the commenter on
the average number of acres destroyed
per fire is consistent with the data
presented in Exhibit 5 -1 and discussed
in Section 5.1.1, Wildfire in the
Southwest. The data estimating costs of
fire management activities and lost
timber value have been noted. As
discussed in Section 5.2.3, Project
Modifications Associated with Fire
Suppression Activities, if a wildfire
occurs, consultation takes place after the
fact; therefore, fire suppression
activities are not affected by owl
conservation, as indicated in Exhibit 5-
4. The potential for increased wildfire
risk resulting from owl conservation
efforts is discussed in Section 5 of the
economic analysis. However, models for
quantifying the impacts of increased
wildfire risk are not available at a scale
that would allow us to address the
impact of owl conservation efforts.
Therefore, these impacts are not
quantified in the report.
(87) Comment: One commenter notes
that owl protections prevent effective
forest and watershed treatment which
results in unnecessary fire fighting costs
and destruction of water delivery, water
quality impacts and infrastructure
destroyed or damaged. The commenter
believes the loss of environmental
services should have been included in
the analysis.
Our Response: The impacts of owl
conservation activities on forest
management and treatment are
considered in Section 5 of the report.
The resulting impacts are summarized
in Exhibit 5 -4. As illustrated in this
exhibit, fire suppression activities are
not expected to be modified as a result
of owl conservation activities. As
discussed in this section, the analysis
found that restrictions on thinning and
vegetation removal in PACs could have
some economic impact.
(88) Comment: Several commenters
state that regional economic impacts in
areas where livestock grazing may be
affected should be considered.
Commenters note that there are indirect
and induced effects on the regional
economy that result from lost output in
the range livestock or ranching sector.
Commenters state that the economic
analysis does not show actual economic
burden to ranchers and county budgets.
One commenter states that critical
habitat will cause a reduction in cattle
numbers and be detrimental to the New
Mexico economy. This commenter
provides information on reduced cattle
numbers in Catron County, New
Mexico, and the potential impacts of
reductions in cattle in that County.
Our Response: As stated in Section 4
of the analysis, the estimated annual
reduction in grazing anticipated to
result from owl conservation measures
represents approximately 0.14 percent
of the annual AUMs grazed in affected
states. This estimate includes impacts
that are likely to result from numerous
causes unrelated to the Act, but which
could not be separated due to their
temporal and spatial correlation with
owl- related activities. To assume that a
reduction in AUMs in owl critical
habitat areas will result in an
accompanying decrease in livestock
production region -wide requires the
assumption that no substitutions in
forage will be made to adjust for the
reductions in AUMs authorized in owl
critical habitat areas. This is unlikely,
given the well - documented behavior of
ranchers wishing to maintain existing
herds. For example, Rimbey et al. (2003)
states that when faced with changes to
public forage availability, ranchers
"would do everything they could do to
maintain their existing herd. Depending
upon when the reductions occurred
during the year, the ranchers identified
alternatives for maintaining herd size
and remaining in business: purchase (or
not sell) additional hay (to replace
forage in winter, early spring or late
fall), and look for private pasture and
rangeland leases (summer forage)
( Rimbey et al. 2003). The last alternative
mentioned by ranchers was the
reduction in the number of cattle they
would run on their ranches" (Rowe et
al. 2001; Torell et al. 2001). Thus, given
observed rancher behavior, it is unlikely
that a reduction in permitted or
authorized AUMs of Federal allotments
in owl critical habitat areas would
necessarily lead to a reduction in herd
size, as long as replacement forage is
available.
However, given the localized nature
of ranching and the increasing number
of restrictions on ranching behavior
overall, it is possible that additional
reductions that may be associated with
owl conservation could occur in areas
where substitute forage areas are not
available, or where supplemental forage
is prohibitively expensive. The
economic analysis captures the value of
those losses to rancher wealth by
assuming that ranchers lose the value of
AUMs reduced on Federal lands (i.e.,
effectively assuming that no
replacement forage is available). While
assuming a region -wide reduction in
AUMs equal to that estimated in the
analysis is clearly conservative (i.e.
more likely to overstate costs than
understate costs), it may provide
additional context for the reader who
wishes to understand the potential
impacts to the regional economy. As a
result, a regional economic impact
analysis using the IMPLAN model has
been added to Section 4.3 and Section
4.5 of the analysis.
(89) Comment: One commenter states
that permit value is not a widely used
method to estimate impacts to the
ranching industry. This commenter
states that permit value is essentially a
measure of rancher wealth based on the
number of federally permitted AVMs he
is allowed to graze, the value of the
Federal grazing fee, and the private
property and property rights owned by
the permittee. This commenter also
states that permit value is not
recognized by the FS and only becomes
a monetary transaction when the
rancher sells or tries to sell his private
property along with the associated
grazing privileges.
Our Response: We agree with the
commenter's definition of permit value
as a measure of rancher wealth. Indeed,
Section 4 of the economic analysis
focuses on the estimation of potential
lost rancher wealth that may be
associated with a reduction in Federal
AUMs grazed due to owl conservation
efforts. This lost rancher wealth is
measured in terms of lost permit value.
Numerous published articles have
focused on the derivation of permit
value for Federal grazing permits. For