Testimony of RDC Executive Director, Jason Brune to House Resources
Feburary 24, 2010
Chairman Neuman, Chairman Johnson, and Members of the Committee. For the record, my name is Jason Brune and I am the executive director of the Resource Development Council. I appreciate the opportunity to testify today in support of HJR 40.
RDC members include all of the major, and many of the minor, parties who will be adversely impacted by the proposed designation of over 3,000 square miles of critical habitat in Cook Inlet. From local communities, to oil and gas, mining, tourism, and fisheries members, all stand to be negatively affected by this proposal. Meanwhile, this designation will result in no added benefit to the belugas.
RDC members who live, recreate, and work in and around Cook Inlet are committed to the recovery of the beluga whale. It is important to remember that NMFS’ biologists have acknowledged the sole cause for the population decline of Cook Inlet beluga whales was the subsistence harvest that transpired in the 1990s. The multitude of activities in Cook Inlet that will absolutely be impacted by this critical habitat proposal were not the cause of the decline, nor are they an ongoing threat to the whale’s recovery.
Since statehood, economic and community development activities have occurred in Cook Inlet. Indeed, these activities have long co-existed with the belugas. Responsible community and economic development have in no way adversely impacted these whales or impeded their recovery. Unfortunately, this designation, if finalized will lead to additional requirements, costly delays, and lengthy 3rd party litigation. There is no other way to put it.
The ESA requires economic effects to be taken into account when designating critical habitat. In fact, areas may be excluded from critical habitat if it is determined that the benefit of such exclusion outweighs the benefit of specifying such areas as critical habitat.
The economic analysis that has been completed as part of this proposal is grossly inadequate. In fact, only direct consultation costs are acknowledged as “costs” in this analysis. Nothing further is considered. The ageny’s estimates are less than $600,000 over the next decade. Frankly, this is naïve and way understated.
Because of this, RDC has hired a contractor, Resource Dimensions, to undertake an independent economic analysis to attempt to more accurately identify the costs of this proposal. These economists have been conducting in person and telephone interviews with many of the potentially affected entities. We are working very closely with the State of Alaska Department of Fish and Game as well as the Office of Economic Development on the development of this analysis and we will be providing the results of this analysis to the agency. We hope NMFS will use these results as a boilerplate to conduct a more robust economic analysis and to that end, I wholeheartedly endorse the second action item of this resolution which calls for a more robust economic analysis..
In conclusion, the benefits of designating critical habitat in most, if not all of the areas that have been proposed is outweighed by the economic impacts it will have. In addition, critical habitat will provide no added benefit to the Cook Inlet belugas and therefore, I enthusiastically endorse HJR40.
