How Much Are We Willing to Pay to Save the Oregon Spotted Frog?

Foley Hoag LLP - Environmental Law
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Foley Hoag LLP - Environmental Law

Greenwire (subscription required) reported this week that the Fish & Wildlife Service Recovery Plan for the Oregon spotted frog estimates that the cost to achieve recovery of the frog will be roughly $2.7 billion over 40 years.  This post isn’t about the Oregon spotted frog or even about the Endangered Species Act as a whole.  (I’ve blogged multiple times about how flawed the NAAQS-setting process is from a cost-benefit point of view.) 

It’s not about whether $2.7 billion is a lot of money to spend on species recovery or whether it will be “worth it” to save the Oregon spotted frog.

It’s about the fact that we don’t even have a way of evaluating whether $2.7 is the right about to spend or whether it’s too little or too much.  I will go out on a limb and say it’s a heck of a lot of money to spend when we don’t know and can’t evaluate whether it’s the right amount.

As regular readers will know, I’m a big believer in cost-benefit analysis.  I acknowledge that the ESA is the poster child for the limitations of cost-benefit analysis.  It’s wicked hard to put a value on saving the Oregon spotted frog.  But nonetheless, if we list it as endangered and we implement a recovery plan that costs $2.7 billion, then we’ve made an implicit decision that it’s worth it to do so.

I sure wish I had a way of knowing whether that’s the right decision or not.  Goldilocks had it easy.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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