Randy Veach President
June 10, 2014 Re:
Comment Period Reopened for Mussels & Legislation to Improve Transparency
TO:
Fellow Southern Region Farm Bureau Presidents
I am writing to ask that you do two things: encourage your staff to submit comments on the critical habitat designation for the Neosho Mucket and Rabbitsfoot Mussels AND to contact your congressional delegations and urge them to support S2084 and HR4319. During our recent Southern Region Farm Bureau Presidents & Administrators Conference in Little Rock a presentation was given on both of these topics. Comment Period Reopened for Mussels The FWS reopened the comment period for the Neosho Mucket and Rabbitsfoot Mussels. This is unprecedented in that it is the fourth time they have done so. We urge you to prepare and submit comments voicing your concerns as it relates to the lack of transparency used in the listing process and the inadequacy of the economic analysis associated with the proposed critical habitat. Our staff can provide you copies of the comments we submitted for your use as a template and can provide additional information if needed. Legislation to Make the Listing Process More Transparent As we discussed during our recent meeting, there are two bills, both sponsored by Arkansans, that we believe would prevent the FWS and the CBD from putting an end to the protections we have enjoyed as a result of our strong private property rights laws. Senator Mark Pryor has sponsored S2084. Representative Rick Crawford has sponsored HR4319. Senator Pryor has agreed to modify his bill to match that of HR4319 and reintroduce it. This would essentially create companion bills. Since our meeting in Little Rock the FWS has proposed two new rulemakings. At the risk of sounding alarmist these rulemakings may be the single greatest threat to our way of life as we know it. These proposals would make it much easier for FWS to designate critical habitat on private property. Understanding this point is crucial. Private property has served as a significant barrier to the FWS’s ability to designate habitat in the South and Southeast and for extremist environmental groups like the Center for Biological Diversity to file third party lawsuits. These rulemakings would remove these barriers in their entirety and open the door for groups like the CBD to do to us what they have done to the West where much of the litigation focused on public lands.