The following was my: Oral testimony on the economic impacts of the proposed Scott River TMDL
Marcia Armstrong, Supervisor, District 5 Siskiyou County

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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.