Marcia Armstrong, Supervisor, District 5 Siskiyou County
**************
ECONOMIC IMPACTS:
Economic considerations play a significant role in requirements of the Porter
Cologne Water Quality Act for: (1) water quality control programs for
agriculture; (2) establishing reasonable water quality objectives; and (3) in
requirements that must be met for pollution prevention measures. These include
Chapter I, 13000, 13141, Article 3, 13241 and Article 4, 13263.3. The Economic
Analysis provided in the Draft Staff Report was completely inadequate to
comply with requirements. I request that a thorough economic analysis,
reflective of the full breadth and depth of economic impacts, particularly as
applies to agriculture in Siskiyou County, be prepared.
I submit the following information to be taken into consideration in such an
analysis:
Siskiyou County is not affluent. Standards of reasonableness should reflect
this context. The unemployment rate in our County is as high as 11.3%,
compared to 6.6% for the state. The household median income for the county is
$29,530, compared to $47,493 for the state.
Agriculture drives the economy of Siskiyou County with gross ag receipts in
2004 totaling $130,390,000. Tourism contributes about $53.5 million and timber
$51.5 million. Scott Valley is a primary agricultural area. Based on the
number of acres farmed and crop types, a rough estimate of one third of the
total farm sales in Siskiyou County, or $43,463,000, are from Scott Valley.
According to the 2004 Annual Crop Report for Siskiyou County, our primary crop
is alfalfa at 275,000 tons worth $28,875,000. Irrigated, dryland and rangeland
pastures combined produced forage worth $13,135,000. In 2004, the total value
of all field crops, including grains, totaled $56,300,000.
Livestock inventories for 2004 included an estimated 20,000 calves; 10,000
cows; 20,500 steers and heifers, and 1,300 bulls. These were valued in 2004 at
$32,196,000. Milk and wool production were valued at an additional $4,896,000.
When ag census data was collected in the past, data indicated that small
family operations dominated agriculture in Siskiyou County: This has not
changed appreciably over the years. About 434 farmers, along with about
255 individuals with other jobs, (but some farm income,) are responsible for
the ag productivity in the county.
In 1992, there were a total of 689 farms and ranches in the county. In regard
to the size of farms ranked by the value of sales, 175 had annual sales less
than $2,500; 81 had sales between $2,500 and $4,999; 68 had sales
between $5,000 and $9,999; 105 had sales between $10,000 and $24,999;
73 had sales between $25,000 and $49,999; 80 had sales between $50,000 and
$99,000; and 107 had sales of $100,000 or more.
The size of farms and ranches, the limited financial and other resources
available to them, should be taken into consideration when applying the
standard of “technically feasible and economically practicable” to
any required pollution prevention measures.
In April of 1988, an economic impact analysis was done by Siskiyou County to
measure the impacts to agriculture if NOAA fisheries imposed a 300 foot
riparian no-activity buffer on either side of waterways. This analysis is a
useful illustration in gauging potential impacts of regulations on agriculture
in Scott Valley. Because Scott Valley is formed by a series of mountain
valleys cut by waterways, eliminating the use of riparian lands for ag
production has a significant impact. Scott Valley has approximately 32,000
irrigated acres. 300 foot buffer areas accounted for about 11,215 acres –
more than 35% of total irrigated agriculture in the Valley. Loss of productive
use or irrigation in this buffer area would have a significant economic impact
In Scott Valley, grazing losses from the buffer were determined to be about
6,635 acres of pasture, estimated at $1,074,870. Hay losses were estimated to
be $2,061,000. The total annual loss in production in 1998 due to buffer
strips in Scott Valley was estimated to be $3,135,870 in direct sales. With a
multiplier effect on circulating dollars of 7.5 the estimated impact would
have been $325,000,000.
Typically, most riparian management schemes propose no or extremely limited
grazing. This places the area at high risk for noxious weeds. Over the long
term, weeds that have a stable reservoir of seeds such as found in buffer
strips are likely to infest cropland. Assuming conservative infestation of
half the acreage in Scott valley, the dollar loss at 3 tons per acre
production is $ 785,910 annually.
Although it is not entirely clear what actions and methods of compliance will
be required of landowners under the TMDL, it is likely that the foreseeable
economic impact could be very significant. I saw no indication of any
realization of this in your economic impact report.