RMAP Legislation Moving in House
From WA State Farm Bureau
Olympia, WA - The House Agriculture and Natural Resources Committee will be voting on RMAP legislation (HB 1095) next Tuesday, Feb. 18. Currently, various amendments have been incorporated into what will most likely be a substitute bill.
Farm Bureau has met with Rep. Bob Sump (R-Republic) and he went over his ideas on how to fix the legislation. “We are pleased with Rep. Sump’s amendments and believe that he is working very hard to protect the interests of small landowners from his district and across Washington,” said Hertha Lund, Farm Bureau lobbyist.
Farm Bureau will provide an update when the bill moves in committee.
During the hearing in the Senate, Rural Technology Initiative was asked to provide more information to that committee on the cost to small landowners. This information is provided below.
February 7, 2003
To: Senate Natural Resources, Energy & Water Committee
Attention: Vic Moon
RE: SB 5298
On February 5, 2003, on invitation we delivered testimony regarding the economic impact of Road Maintenance and Abandonment Plans (RMAPS). We were asked to see whether we could extend our findings and provide an assessment of the impact of SB5298 and respond in writing.
It is clear that SB5298 recognizes many of the causes of the substantial economic impacts that we identified with the existing RMAP rules. It is however difficult to assess to what degree the bill will actually alleviate financial burdens on small owners, since the amount and allocation of state shared financial resources is not known and the reaction of owners to the new legislation is still in doubt.
SB5298 more clearly establishes the 20-acre exemption (section 3-1a) which we had already assumed in our cost estimates. The need to submit only a checklist RMAP (section 3-2) will lower the cost of assessment, which we assumed was small relative to the cost of upgrades. Therefore, the cost impact from those aspects is unchanged. However, more importantly, by making this process simpler, including allowing the application for an FPA before obtaining an RMAP (section 3-3) it may encourage participation. It may also ease the cash flow burden by allowing harvest before requiring upgrades. Nevertheless, since an RMAP is still required by 2016, the cost and cash flow impacts will still be quite severe.
Perhaps the more serious unintended consequence of both the riparian buffer and RMAP requirements is their subsequent impact on the viability of sustainable forest management. We have shown that there is a wide disparity in impacts across small owners. Acknowledging that the loss of even a relatively small number of riparian acres from sustainable forest management to land conversion would be a substantial negative, directs the priorities at making sure that all small owner activities remain economically viable. SB5298 seems to recognize the importance of not allocating money to projects that will not have an important impact on fish bearing streams by requiring "a ranked inventory of fish barriers" and by establishing "an order for the funding of fish blockage removals … that ensures that funding is provided first to the known fish blockages… that cause the greatest harm…". While this inventory may well be expensive to create, it should go a long way toward directing the money where it will have the greatest impact. What is not clear is whether that means those small owners with the most negative economic consequences will receive adequate relief.
The case study analysis we completed on riparian buffers provided a number of surprising results that were not revealed in the SBEIS analysis. Looking at averages, when there is a wide disparity of impacts is very misleading. We would speculate that without a number of case studies analyzing the proposed RMAP rule changes with site specific detail, we will not really know whether the rules will be effective.
Funds made available by the Legislature for the Forest Riparian Easement Program (FREP) have been only a small fraction of the funds needed to relieve the cost burden to small forestland owners that results from riparian restrictions. Subsequently, it seems rather unlikely that the cost-share program proposed for RMAPS relief will come close to providing the funds required unless the costs are actually reduced substantially. As we read the bill, costs are not eliminated, instead, a portion of the costs for selected owners are transferred to other payers. While it is appropriate that the public pays for public benefits, there should be more concern that all of these upgrade requirements are important to fish protection and that owners, even with public cost-share, can afford to make the required upgrades and continue to manage their lands as sustainable forest lands.
Many of the concerns we have heard involve required upgrades in spite of fish blockages down stream on non-forest lands; an implied cost with no benefit. The legislation seems to deal primarily with fish blockages so cross drains and sediment delivery may still impose extensive costs on some with perhaps marginal benefits.
We were not able to collect case study information on RMAPS. As an alternative, we developed economic impact charts that display economic loss as a function of upgrade cost. With that in mind, our charts are still useful. For example, if the cost-share is 50%, it may reduce their upgrade cost from $2000 per acre to $1000 for heavily impacted landowners but a quick look at the charts will indicate that this hardly eliminates their burden.
We would suggest that more attention needs to be placed on the economic impact of regulatory changes so that potential unintended consequences can be more quickly identified and avoided.
In summary, the bill addresses many of the problems identified with the current legislation and will reduce the burden for some, but will not likely eliminate a heavy burden on an important subset of small landowners. We are well aware that the problems created by RMAPS and riparian buffers are difficult to solve. Let us know if we can be of assistance.
Bruce Lippke Kevin Zobrist
Professor and Director Economic Analyst
Rural Technology Initiative
College of Forest Resources
Box 352100, University of Washington
Seattle WA, 98195
206 - 543-8684
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