ML19343B847
| ML19343B847 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 12/18/1980 |
| From: | Hussey J DAMES & MOORE |
| To: | |
| Shared Package | |
| ML19343B832 | List: |
| References | |
| NUDOCS 8012300728 | |
| Download: ML19343B847 (20) | |
Text
V i
O 2
I DIREC"2 TESTIMONY OF JAMES R. HUSSEY ON 3EHALF OF HOUSTON LIGHTING & POWER COMPA2TY RE. TEX PIRG CONTENTION 1/STP 3 VS. AC 1 l
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l
. l i
8012300"/S$
~.
DIRECT TESTIMOMY OF JAMES R. HUSSEY RE STP 3 VS. AC 1 a
Q.
Please state your name and position.
y A.
My name is James R. Hussey.
I an a partner in 2
the firm of Dames & Moore.
I have previously listed my 3
qualifications in my testimony concerning the contention 4
on the construction of the barge slip and the transpar-a tation of the reactor pressure vessel to the site.
Q.
'21at is the purpose of this testimony?-
1 A.
I am going to address that part of TexPirg Con-tention No.1 which alleges that less land would be used by construction of a th,rd unit at the STP site as compared with construction of a single unit at the Allens Creek 11 site.
For purposes of this testimony I am going to 12 assume that the amount of land saved in moving ACNGS Unit 12 1 to the STP site would be about 5,600 acres as described 14 in Section 9.2 of the FSFES.
Given this difference, the 15 question.is whether the present land use at the Allens 16 Creek site is of any unique significance.
The site has 17 two basic land uses - terrestrial habitat for certain 18 flora and fauna and agricultural production.
19 Q.
Would you please address the question of 20 terrestrial habitat first?
v
~~
A.
The impacts on terrestrial habitat were thoroughly 22 analyzed in the early 1972 Environmental Report as well 23 24
-.,.a
,n p
9-,
i as the Staff's Environmental Statement published in t
November, 1974.
These documents establish that any 2
disruption or loss of terrestrial habitat would be 3
mini==T; therefore, these impacts are not of anY significance in comparing this site with another site.
g 6
r l
Report Supplement issued in 1977.
(Section S4.1.3.2) 7 Q.
Turning to the issue of agricultural impact, the Board found in its 1975 Partial Initial Decision that 9
the amount of agricultural land taken out of production on this site would amount to an insignificant percentage 11 of the total land available for production on a state and 11 national basis.
(See PID TT 72-78).
Are you aware of 13 any information which would change the prior finriings by-14 the Board?
15 A.
No, I am not.
Updated estimates of the 16 percentage of total prime farmland in the United States 17 that will be preempted by Allens Creek are presented in 18
~
Applicant's Erhihit No.
(JRE-2).
Utilizing informa-19 tion from a national inventory conducted by the Soil 20 Conservation Service of the U.S. Department of Agriculture-21 in 1977, Dames & Moore has calculated that the entire 22 ACNGS site contains approximately.024% of the total 23 potential prime farmland in the State of ? exas and.003%
24 i. -. -..
l of the total potential prime farmland in the United States.
The amount of prime famland at the Allens Creek site therefore remains an insignificant percentage.
In making this comparison. with the Board's-1975 finding-I would like to point out, however, that any comparison of a
recent data with that available in 1975 is complicated to 6
some extent by the fact that the Soil Conservation Service 7
has adopted new criteria for soil classifications.
These 3
new classifications are explained-in Applicant Exhibit 9
(JRE-2).
Under this new classification system a large 10 portion of the land at the Allens Creek site is classified as " prime" although the Board earlier found that this 12.
land could not be-considered " prime" under definitions in
' 3-use at that time.
(See PID T 71 and n.12)
Notwithstand-1^4 ing this change in classification, quality and the actual 5
perceived uses-and productivity of this land have not
- 6 changed to any appreciable degree.
Q.
Have you done any analysis to estimate the
^8 1
impact of taking this land out of production?
1 9 A.
Yes.
Dames & Moore has done an analysis which 20 attempts to measure the loss by calculating the cost to regenerate an equivalent amount of production on other 22 land in accordance with NRC guidance set down in the 23 Clinton decision.
That analysis is contained in Applicant 24
I Exhibit No.
(JRE-3).
Using t.tiis analysis, the present value of lost agricultural production ranges from between 2
$16.3 and $21.4 million in 1979 dollars, and between 3
$27.3 and $35.a mi11 ion in 1985 dollars.
These figures.
4 compare favorably with the 534 million. in 1985 dollars 5
computed in the Environmental Report Supplement.
(See ER 6
Supp Sec. S8.2.3.1).
7 Q.
What conclusions do you draw from your findings 8
with respect to TexPirg's contention?
9 A.
I would conclude that in comparing the two
'^O sites, very little weight should be given to the incre-1i
~~
mental loss of land at the ACNGS site versus location of 12 a third unit at STP.
The Allens Creek, site is of no 3
particular significance as a. terrestrial habitat. More-14 over the amount of land that will be taken out of agri-13 cultural production is a very insignificant portion of 16 the total amount of comparable land available on a national 17 and statewide basis. for production.
18 Q.
Does-this conclude your testimony?
19 A.
Yes, it does.
20 21 22 23 24
. ~
J Applicant Exhibit No.
(JRH-2)
December 1980 ANALYSIS OF PRIME FARMLAND SOILS ACNGS - 1980 INTRODUCTION The purpose of this document is to update the original soils and agricultural analyses cone for the Allens Creek Project in 1972 and 1974.
This update discusses prime and unique farmlands, as defined on Table 1.
The locations and acreage of prime farmlands are addressed.
Baseline data utilized in this analyois were obtained from the Soil Conservation Service (SCS) and represent the most up-to-date information available on soils in the area.
SOILS CLASSIFICATION The original soils and agricultural analyses done in 1972 and 1974 utilized soil associations for the primary soils classification system onsite. Soil association maps are very general in nature and represent a landscape that has a distinctive pattern of soils in defined proportions.
Soil association maps are made up of several different soils series.
A soil series is composed of soils having profiles and characteristics similt' 2._
4 that these soils may be categorized under one series name, such as Midland, Lake Charles, Brazoria, etc.
These soil series are further divided into soil phases, which are determined by additional characteristics, such as slope, stoniness, wetness, or other character-istics that affect use of the soils. Thus, a soil series such as Midisud might have two phases:
Midland clay with a O to 1 percent slopet rnd Midland clay with a 1 to 3 percent slope.
When these soil phases are mapped by the SCS on aerial photographs, they are known as soil mapping units. Since present SCS prime and unique farmland definitions are based en soil mapping units rather than soils associations, additional infor-mation on soils mapping units in the Allens Creek area has been compiled.
The use of soils mapping units will permit a more detailed analysis of
TABLE 1 ENVIRONMENTALLY SIGNIFICANT AGRICULTURAL LANDS AS DEFINED BY THE U.S. DEPARTMENT OF AGRICULTURE IN 7 CFR PART 657 1.
Prime farmland is land that has the best combination of physical and chemical characteristics for producing food, feed, forage, fiber, and oilseed crops, and is also available for these uses (the land could be cropland, pastureirond, rangeland, forest land, or other land, but not developed land or under water).
It has the soil quality, growing season, and moisture supply needed to economically produce sustained high yields of crops when treated and managed.
2.
Unique farmland is land other than prime farmland that is used for the production of specific high value food and fiber crops.
It has the special combination of soil quality, location, growing season, and moisture supply needed to economically produce sustained high quality and/or high yields of a specific crop when treated and managed according to acceptable farming methods.
3.
Additional f Whnd of statewide ir portance is, in addition to prime and unique ra'rmlands, significant for the production of food, feed, fiber, forage, ornamental, and oilseed crops.
Criteria for defining and delineating this land is to be determined by the appropriate state agency or agencies.
4.
Additional farmland of local importance is not identified as having national or statewide importance.
In some local areas, however, it is economically important and environmentally sound for certain additional farmlands for the production of food, feed, fiber, forage, ornamental, and oilseed crops. Where appropriate, these lands may be identified by the local agencies concerned.
e
the site's characteristics, specifically in regard to prime or unique farmland on the site.
Since the original agricultural analyses in 1972 and 1974 were done, a detailed soil survey of the site has been completed.
During this detailed survey, some of the soils names onsite were changed; thus, the data presented herein may not dir,ectly correlate with previous studies, especially where names of the soils are involved. The perceived uses and productivity of the soils have not changed any appreciable degree.
PRIME FARMLAND SOILS Although the original agricultural data in the Environmental Report utilized capability groupings in their analysis of agricultural land, this report will deal primarily with prime and unique farmland categories as defined in Table 1.
Although capability groupings are still utilized in soil surveys, the prime and unique farmland classifications are generally required for use in environmental impact analysis.
l i
The classification and designation of soils as prime farmland is conducted by the U.S. Department of Agriculture, SCS.
According to the criteria utilized in the classification program, soil mapping units may be designated as prime farmland soils in three conditions:
prime in their native state; prime if irrigated; and prime if drained.
If, the soils do not meet the criteria for one of these three classifications, then they are not designated as prime.
l Although soils mapping by the SCS is complete in Austin County, no published soils survey is available at this time.
Data from preliminary field sheets of the soils mapping were acquired from the Austin County SCS office and analyzed for potential prime farmland soils.
Figure 1 shows the location and distribution of soils on the site as mapped by the SCS and identifies those soils on the site designated as prime
i farmland.
The majority of the prime soils on the site occur on the bottomland portions, although small parcels are also located in some upland areas.
Table 2 indicates the soils types onsite and their signi-ficant characteristics, along with their expected productivity.
The productivity estimates by the SCS assene that the most advanced and intensive management technique will be utilized for the crops.
- Thus, utilizing average management practices, these productivity levels may not be attained.
Brazoria clay soils are the dominant prime farmland soil-type found on the site and cover the bottomland areas. The Brazoria series consists of deep, somewhat poorly drained soils that formed in thick clay sedi-l ments on the floodplains of major streams draining from West Texas to the Gulf of Mexico.
They are saturated late in the winter and early spring months.
The slope is predominantly less than 1 percent; thus, the soils are somewhat poorly drained and runoff is slow. Permeability of the soil is very slow and flooding occurs occasionally or frequently in some areas.
This soil series is used mainly for cotton, sorghum, corn, soybeans and improved pasture of bermuda grass, dallis grass and white clover. Productivity of the soil is fairly high (as is shown in Table 2) for the crops normally grown on it.
Native vegetation is pecan, elm, hackberry, oak and ash trees, and mid and tall grasses.
The Brazoria clay soils series distribution is located mainly along the lower reaches of the Brazos and Colorado Rivers in Texas and is of minor extent.
Based upon planimater methods for area measurement, the total prime i
soils on the HL&P property account for approximately 8,975 acres, or about 80.5 percent of the entire 11,152-acre tract (Figure 1).
The majority of the soils in the proposed cooling lake area are Brazoria clay (Map Unit 15) with I to 5 percent slopes and are considered prime.
The cooling lake is over 5,000 acres, of which 4,787 acres are prime soil.
Within this area, thers are some Brazoria clay depressional phase soils which are classified prime only if drained.
As a conservative measure,
. i
,... -. _. - -.,,. -,. -.. - ~,, _.., _,.,, - -, _..., _.......... _ _.. _. _... _ _ - _,......,.. _ _ - - -.......
TABLE 2 i
ALLENS CREEE NUCLEAR CENERATING STATION Soll TYPES AND CliARACTERISTICS Grain leproved Bermudaggass Soybeans Hap Cotton Lint Sorghum Corn Rice (AUN)
(bu/ac)
Unit Soll Type Slope capability Class (Ibs/ac)
(Ins /a c)
(tas/ac)
(Ima /ac )
la Hidland clay 0-11 3W 6.5 30 IB Hidland clay 1-3X 3W
- 6. 5 30 9
Lake Charles clay 0-II 2W (prime if drained) 500 90 75 130 10.0 30 95 1.ake Charles clay l-3E 2E (prise) 450 85 50 10.0 25 9C 1.ake Charles clay 3-51 3E (prise) 400 80 45
- 8. 0 20 9D
- 1. eke Charles clay 5-83 4E 6.0 15 Brazoria cisy 0-II 2W (prime) 500 90 90 110 10.0 35 i
17 Brazoria clay depressional 2W (prime if draineJ) 500 90 90 10.0 35 27 Arts fine sandy loan 0-11 3W (prime if drained) 500 60 70 130 10.0 30 37C3 Crockett fine sandy loam 2-5X eroded 4E 200 45 30 5.5 33 Couen clay loan frequently flooded 5W 6.5 40 Norwood allt loam 0-II I (prime) 875 80 100 10.0 40 43 Midland cla; depresatonal 3W 6.5 30 l
49 Norwood s tity clay 0-11 1 (prise) 600 80 9d 15.0 40 4
51 Katy fine sanJy loam 0-11 W (prime) 450 70 65 120 10.0 J
Sla Katy fine sanJy loam 1-31 W (prise) 450 70 65 120 10.0 53BC Silawa loamy fine sand I-SI 35 (prime) 350 50 45 6.0 53D Silaua loamy fine sand 5-81 6E 4.0 3.5 i
55 Sumpf clay frequently flooded 6W 80 oklared very fine sandy loan 0-13 2W (prime) 650 65
- 8. 0 82 Edna fine sandy loan 0-11 3W 400 65 40 120 8.0 25 823 Edna fine utty loam 1-31 3E 350 60 40 20 8.0 20 143 Cleaville allt loam 0-11 2W (prime) 575 90 80 9.0 153 Kenney loamy fine sand I-81 35 250 30 8.0 Source:
U.S. Department of Agriculture, Soil Conservation Service, Soil Dmocription Series, National Cooperative Soll Survey.
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2000 60,000 l 32 a,tu & Lcm trots. r sces) e
[ 4s o.oco srtr t:m o-1 l 43 "I3LmC CLAf OtP'Ess:08tAL 49 mCMCC s:L*, :LAv 31 51 p'v r:w Swv GAJe 3-1 5:2
- A*v r:w LWV Ge 13 L(GlhD l use s:u.A cA v r w sao 1-5 HOUSTON LIGHTlHG & POWER COMPANY jm s:u A car rtw sac 5-8 PRIME FARNLMD Allens Creek Nuclear Generating Station ss ser p w
gn,, 1 m :uuto een r:w sm:v om 3-1 d2 (SM 9t 5m:v L0m 0- 1 50ll TYPES AND PRIME FARMLAND m
c--r:csuo,um 1.
m
- c: t *
<rito races)
ACNGS - 1980
- 43 at%:c.t s:Lt 3-1 Source: (SC5 1980)
FIGURE 1 1 :s2
<two umvr:w smo
-s
these soils were included as prime, although no information of drainage improvements in their specific area was available.
All of the Brazoria clay depressional phase soils onsite were treated in this manner. Total area of these depressional phase soils onsite is approximately 1,270 j
acres.
The HL&P property not to be occupied by the plant, cooling lake, or appurtenances covers approximately 4,255 acres.
Of this acreage, approximately 3,594 acres, or 84 percent, are classified as prime farmland soils.
Of the 640 acres set aside as recreational areas, 319 acres are prime farmland soil, or approximately 50 percent of the area.
The onland portion of the exclusion and restricted area covers 275 acres of prime soils, or approximately 24 percent of the total onland The breakdown of prime farmland soils related to projecten use is area.
summarized in Table 3.
According to a national inventory conducted by the SCS in 1977, th re are approximately 346,498,000 acres of prime farmland soils in the United States.
Texas has approximately 37,502,000 acres, or 11 percent of the total prime farmland in the United States. Austin County has an estimated 79,600 acres of prime farmland in the native state, with an additional 8,600 acres classified as prime if drainage measures are utilized (Personal communications, SCS, December 1980).
Thus, potential prime farmland in Austin County totals 88,200 acres.
Based on these estimates, the ACNGS site contains approximately 10.2 percent of the total potential prime farmland in Austin County and 0.024 percent of the prime farmland in Texas.
The amount of prime farmland on the ACNGS site is approximately 0.003 percent of that in the United States and, thus, is considered insignificant. The amount of prime farmland to be occupied by the plant and cooling lake amounts to 5,062 acres, or only 0.013 percent of the total prime farmland in Texas. _
UNIQUE FARMLAE Unique farmland, as defined by the SCS, is a combination of soils properties and the type of crop grown on those soils.
Thus, some soils with certain characteristics may not be classified prime; but, due to a particular property (such as sandiness), they may be suitable for growing a unique crop such as rice or peanuts.
These potentially unique soils are only classified as unique if the particular crop is being grown on them.
In such a situation, they may chang their classification on a year-to year basis if crop rotation practices are maintained.
Some of these potentially unique-soils are found on the site.
They include:
Midland clays; Edna fine sandy loams; and Kenny loamy fine sand.
There are no unique crops grown on the ACNGS site nor were any growing on the site when the land was acquired by HL&P.
Thus, there is no unique farmland on the site.
, l 1
TABLE 3 PRDE FARMLAND ONSITE Total (Acres)*
Prime Farmland (Acres)
Cooling Lake 5,120 4,787 Exclusion and Restricted Area 1,137 275 (on land)
Recreational Areas 640 319 Reserve Area 4,255 3,594 TOTAL:
11,152 8,975
- ACNGS-PSAR Figure 2.1-2 l
Applicant Exhibit No.
(JRH-3 )
December 1980 COST TO REGENERATE AGRICULTURAL PRODUCTION ON OTHER LAND DUE TO LOSS OF ALLENS CREEK PRODUCTION INTRODUCTION The NRC's Clinton decision states that the loss associated with the diversion of the ACNGS site from agricultural to nonagricultural use should be measured in terms of how much it would cost to regenerate an equivalent amount of agricultural production on other land.
This could be done either by increasing the yield on existing agricult;ral land or by producing on land not previously used for agriculture.
The enclosed analysis of the cost to generate an amount of produc-tion equivalent to that preempted by ACNGS is based on production cost data provided by the Texas Agricultural Extension Service Area Economist for District 10 (which includes Austin County).
This provides a reasonable estimate of the cost to rent sufficient land and produce the forgone production at the ACNGS site.
l The land use data for Austin County suggest that land that has been cropped in the past and is not now planted is available to replace the I
cropland lost at the ACNGS site, and that rangeland is available that l
could be upgraded to improved pasture to replace the improved pasture lost at the ACNGS. Ungra::ed land also exists in the county that could be converted to rangeland.
Based on annual data for 1979 as a reference point, we have estimated the present value of the cost of replacing the production from the ACNGS site for the life of the plant with such available land in Austin County. This is equivalent to the present worth of the gross value of production assuming-as is theoretically true-that I
i 1
(
Illinois Power Company (Clinton Power Station, Unit Nos. I and 2),
Docket Nos. 50-461 and 50-462, ALAB-340,. 4 NRC 27 (July 29, 1976).
i 1
over the long run the gross value of production equals total fixed and variable production cost.
ANALYSIS To the extent that agro-climatic and soil conditions allow, crops planted change from year-to year as the economic signals perceived by farmers change.. For instance, in Austin County, corn acreage harvested increased from 4,800 acres in 1973 to 9,800 acres in 1979, while cotton acreage dropped from 7,000 acres in 1972 to 3,300 in 1979.
During the same period, grain sorghum acreage grew from 6,500 acres in 1973 to 9,000 acres in 1978 and then dropped to 8,100 acres in 1979.
Cattle ranching had steady growth over this period. Cattle on ranches in Austin County increased from 90,000 head in 1974 to 130,000 head in 1979.
During this period of time, Austin County planted cropland dropped from 132,000 acres in 1974 to 71,000 acres in both 1978 and 1979, while improved pasture increased from 174,000 acres to 195,000 acres.
While there have been some changes in the mix of crops planced in Austin county since the early 1970's, the trend toward cattle production has been steadily up.
The 1980 Austin County Soil Conservation Service District Office Annual Report predicts this trend will continue.
Ten years from now the SCS expects Austin County cropland to be down slightly to 63,000 acres and improved pasture to be up to 216,000 acres.
This discussion of Austin County farm land uses shows that land is available in Austin County that could be shifted to crop production to replace the potential crop production lost on the ACNGS site.
The historical and projected growth in county pasture land shows that land is also available to replace that lost at the ACNGS site.
Dr. Art Gerlow and Dr. Ashley Lovell, Area Agricultural Economists for Districts 10 and 11, have estimated the 1979 production costs for co rn, sorghum, and cattle on land that would be suitable to replace the production lost on the ACNGS site.
These data are shown on Table 1.
These data represent the cost to rent, grow, and harvest an acre of corn or sorghum, or produce and sell a mix of cattle and calves.
The bottom line of the table shows:
Corn cost
$136.65/ acre Sorghum cost' 113.58/ acre Cattle cost 191.96/per cow The ACNGS site consisted of approximately 6,710 acres of range and pasture land and 4,300 acres of cropland when acquired.
The last time the land was cropped, its predominant use was sorghum.
Corn and cotton were small crops and hay was nearly 20 percent of the planted acreage.
Since corn acreage has doubled in Austin County since the early 1970's, we have assumed that this prime land on the ACNGS site would have expanded its corn acreage.
The increase in corn production has occurred because Austin corn farmers have been able to sell their corn for much more than the' prevailing Texas price due to the presence in Austin County of a feed mill.
The farmers are therefore capturing a transportation advantage.
In 1979, they received $3.25 to $3.50 per bushel compared to an average $2.45 per bushel for Texas.
Of the 4,300 acres of cropland, we have assumed 3,000 in sorghum and 1,300 in corn.
This is consistent with the 1972 use modified to account for expansion in corn since then.
If the 6,710 acres of cattle land on the ACNGS site was as produc-tive as that of Dr. Gerlow's case shown on Table 1 (4.78 acres per cow),
then the ACNGS site could product 1,404 marketable cattle.
Table 2 shows the total cost to replace this acreage with other land available in either Austin County or nearby regions, assuming equal productivity between land..
n
TABLE I 1979 PRODUCTION COSTS CRAIN g
2 3
CORN SORCliUM CATTLE Costs Per Acre Costa Per Cow Growing Costs Seed
$ 10.00
$ 2.82 Ilay Harvesting
$ 14.75 Fertilizer 31.31 20.30 Feed 40.21 Insecticide 5.99 3.10 Fertilizer 54.55 lierbicide 3.75 3.50 Machinery 1.75 Machinery, Tractors, Labor 17.48 Upkeep & Fuel 8.25 14.66 Salt & Minerals 2.62 Labor 20.08 16.32 Other 4.28 Interest on Capital @.101 3.16 2.16 Sales Commission 5.18 Inte res t 3.40 Subtotal
$ 82.54
$ 62.86 Rent 0 $10.00/ Acre 47.74 Harvest Costs Total: Pe r Cow
$191.96 Combine 15.00 8.75 Total: Per Acre
$ 40.12 llaul to Market 14.00 4.84 4.78 Acres Per Cow Subtotal
$ 29.00
$ 13.59 Subtotal: Variable costs 111.54 76.45 Fixed Costs Machinery Amortization 4.50 7.12 Tractor Amortization 5.83 8.74 Source:
Rent 43.78 21.27 Art Ge rlow, Ph.D.
Area Economist, Listrict 11, Subtotal Fixed Costs 54.11 37.13 Texas Agricultural Extension Service, Bryant, Texas TOTAL COSTS
$136.65
$113.58 713-823-8011 Estimated corn production costs for Austin County.
Estimated sorghum production costs for District 10, Texas Blackland Region including Washington County adjoining Austin County to the north.
3 Estimated beef cattle budget for 2,731 acre ranch in Austin County.
r TABLE 2 1979 REPLACEMENT COST FOR ACNGS PRODUCTION Cost Cost No.
Total Per Acre Per Cow Acreage Cattle Cost Corn
$136.65 S
1,300
$177,645 Sorghum 113.58 3,000 340,740 Cattle 191.96 1,404 269,467 TOTAL COST
$787,852 These annual costs for one year can be converted to a present value that represents the requirement to replace the ACNGS site for nn assumed 38 year plant life. Present value calculations require assumptions about discount rates and inflation rates.
We have relied on those presented previously on page 58.2-3 of the ER Supplement.
Based on that equation, which utilizes a discount rate of 9 percent, an inflation rate of 5 percent, and a 38 year project, the present value of the hypothetical 1979 production costs is $16.3 million.
This can be converted to 1985 dollars for comparison with tbe values shown in the ER Supplement.
In 1985 dollars, the cost to replace the ACNGS hypothetical productive capacity is $27.3 million.
According to Dr. Gerlow, yields on dry land crops in Austin County depend more on rainfall conditions relative to planting time than on soil characteristics.
In 1979, some Austin County farms produced 1,00 bushels per acre of corn, while the county average for the year was 42 bushels per acre.
(Sorghum productivity does not show as much variability.
Neither does cattle productivity vary greatly among the better managed enterprises within the county.) It might be argued that the prime bottom land of the ACNGS site would produce corn closer to the 100-bushel yield than to the 42-bushel county average.
If so, more corn land would be required to replace that lost at the ACNGS site and the present value replacement cost for the site would be $21.4 million in 1979 dollars or
$35.8 million in 1985 dollars.
CONCLUSION Based on this analysis, for the life of the project, replacement land could be rented, and crops produced, for between $27.3 and $35.8 million (1985 dollars). This range reflects the possibility that because the ACNGS land is largely prime farm land, it may require more than an acre-for-acre replacement in Austin County for some of the f arm produc-tion on the land.
This estimate of the opportunity costs of foregone ACNGS production compares favorably with the $34 million figure (1985 dollars) calculated in the ER Supplement and derived from revenue data (ER Supp. Sec. S8.2.3.1).
This aggregate cost can be translated to a per acre amount to suggest the opportunity valuation of transfering the ACNGS property out of agricultural production.
On this basis, the prime bottom cropland's opportunity valuation is between $4,175 and $6,152 per acre and the cattle grazing land is north about $1,400 per acre (in 1985 dollars).
For the entire 11,000-acre property, this averages out'-to between
$2,480 and $3,250 per acre.
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