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nothing to take into account the delay or elimination of projects or activities that may harm critical habitat and the impact on local economies. It is an economic approach that totally ignores human cost.


Te local economic impact study showed a far greater negative impact


on Arkansas then the Service’s study. Te Service’s method did not calcu- late any real potential costs in litigation, private land owner/business impacts or increased cost in infrastructure projects. Tese two species are among 42 Arkansas species that were listed as


Montgomery County Judge Alvin Black (left) tells members of the Arkansas Legislature, “Do what you can to make sure our fragile economy in Montgomery County and the surrounding region is not destroyed by overly protecting a mus- sel.” Benton County Judge Bob Clinard also testified against the designation.


Te effort suggested a 38-percent decrease in the proposed designation of critical habitat area. As stated above the Service uses a method of economic analysis that only estimates the limited cost those governmental agencies will bear if these CH designations cause some additional work (consultation) for the Service/Corp of Engineers/U.S. Forest Service and other federal agencies. Te total estimated economic impact using this “incremental” analysis ap- proach is $4.4 million over a 20-year period or $290,000 per year. Tis impact is for the entire designation in all effected states. It does


threatened or endangered under an agreement under the Endangered Species Act. Te potential of more critical habitat designation in the state is imminent, and if not challenged, the proposed listing could af- fect the state’s entire watershed by the time the listings are finished. Te AAC and 13 other organizations collectively submitted com- ments to the Service that included independent environmental studies conducted by GBMc & Associates, an environmental services company, and Histecon Associates, Inc., in Little Rock, conducted the economic impact studies while the firm Gill Ragon Owen P.A. submitted the final comments for submission to the USFWS. Members of this effort for responsible critical habitat designation in


Arkansas include: Association of Arkansas Counties; Arkansas State Chamber of Com-


merce / Associated Industries of Arkansas; Arkansas Environmental Federation; Arkansas Forestry Association; Arkansas Farm Bureau; Arkansas Poultry Federation; Arkansas Independent Producers and Royalty Owners; Camp Ozark; Energy and Environmental Alliance of Arkansas; Arkansas Cattlemen’s Association; Arkansas Timber Producers Association; Agriculture Council of Arkansas; and Arkansas Association of Conservation Districts.


COUNTY LINES, FALL 2013


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