Sept. 23, 2000
RMAD RELEASES REVIEW OF THE COLORADO PRAIRIE DOG CONSERVATION PLAN

On July 7, 2000, the Colorado Division of Wildlife (CDOW) announced a four-part conservation plan for the black-tailed prairie dog. The plan would entail the following:

1. A hunting season closure for black-tailed prairie dogs.
2. A permit system for poisoning of black-tailed prairie dogs.
3. Clarifying of the Division's policy regarding the relocation of prairie dogs within counties.
4. Implementation of a black-tailed prairie dog incentives program for private landowners.

RMAD believes that the CDOW black-tailed prairie dog conservation plan has some flaws and some strengths.

First, the plan's hunting season closure is very welcome indeed, and it addresses prairie dog shooting, which is increasing in popularity and consequently is a growing threat to prairie dog populations and other wildlife that use prairie dog towns. Beginning in September 2001, it will be illegal to shoot prairie dogs in the state of Colorado. We applaud the Wildlife Commission for passing this prohibition. However, the closure will not affect private landowners' ability to shoot prairie dogs on their own land. Given that the majority of prairie dogs in Colorado exist on private land, and given that the majority of those private lands are used for agriculture, RMAD believes that this loophole may allow the glaring threat to prairie dogs caused by shooting to persist. The hunting season on black-tailed prairie dogs could and should be closed by the CDOW, on private and public lands alike.
Second, a permit system for poisoning prairie dogs may do little to circumscribe the threat to prairie dogs caused by poisoning. Furthermore, RMAD believes that any poisoning of prairie dogs -- permitted or otherwise -- is a violation of the state ban on traps, poisons, and snares. Although the state ban does not protect prairie dogs, it does protect many of the animals, such as rabbits, snakes, weasels, badgers, and foxes, who use prairie dog burrows. Given that poisons used on prairie dogs, such as aluminum and zinc phosphide, are indiscriminate killers, protected species are poisoned when a prairie dog burrow is poisoned. RMAD is presently suing the CDOW over this very issue. CDOW cannot, therefore, plead ignorance of the very strong possibility that prairie dog poisoning is a violation of state law.
Third, the CDOW's move to abandon its earlier administrative directive to broaden the applicability of SB-111, the inter-county prairie dog relocation restriction law, to prairie dog transfers within a county, is a very welcome announcement. RMAD objected to the application of SB-111 to intra-county transfers, and we are pleased at this move by the CDOW. We are also pleased that CDOW is recognizing the importance of facilitating prairie dog relocation as part of the solution to the crisis of the prairie dog ecosystem along the Front Range.
Fourth, while we agree with the need to make prairie dog conservation attractive to private landowners, we also believe CDOW and other state agencies should actively educate landowners about prairie dogs. In particular, ranching interests have historically been intolerant of prairie dogs due to the myth that prairie dogs "rob" cattle of forage. However, scientific research in the past 20 years has demonstrated that this is indeed a myth, and that prairie dogs present no significant economic threat to cattle ranching. We'd like the CDOW and the State of Colorado to actively educate cattle ranchers and other agricultural interests to peacefully coexist with prairie dogs and other wildlife in the state, rather than continue to persecute that wildlife.
Those are our responses to the four prongs of the proposed black-tailed prairie dog conservation plan. We hope that the following strategies will be included in the CDOW's actual Black-Tailed Prairie Dog Conservation Strategy:

Prairie dog recovery on public lands. CDOW should advocate recovery of prairie dogs on public lands in the State of Colorado. State Wildlife Areas administered by the CDOW, state school lands administered by the State Land Board, National Grasslands administered by the U.S. Forest Service, and U.S. Bureau of Land Management holdings in the state could all serve as an extensive land base provided for full recovery of the black-tailed prairie dog ecosystem in Colorado. CDOW's plan should address this.
Protection of prairie dogs from development. The CDOW plan should address the development issue, which is the main reason for the reduction of prairie dog populations and prairie dog-occupied acreage along the Front Range. Currently, citizens seeking protection for prairie dogs from development receive no help from CDOW officials.
Pledge from the state. In addition, the plan should involve a pledge from the CDOW and the Department of Natural Resources (DNR) that they are doing this all in good faith. We are concerned that this is another move to head off listing (which CDOW officials explicitly state) rather than a genuine, sincere effort to conserve prairie dogs. If the black-tailed prairie dog continues to decline, we should ask CDOW and DNR to pledge that they will not spend a million dollars lobbying in Washington to prevent the black-tailed prairie dog from being listed (as they did the preble's meadow jumping mouse). This effort should be about honoring the spirit of the ESA -- recovering species in trouble so they won't need to be protected under the ESA. It should not be about trying to thwart/circumvent the ESA.
Again, RMAD is pleased that the CDOW appears to have changed its position in recognizing that steps need to be taken immediately to conserve black-tailed prairie dogs and their ecosystem. Now we ask that CDOW advocate measures that will accomplish that task effectively, in order to restore and protect the unique and magnificent prairie dog ecosystem that once flourished in Colorado. It can flourish again if government officials join citizens in taking a firm stand on behalf of Colorado's wildlife.

Sept. 23, 2000
RMAD RELEASES REVIEW OF THE COLORADO PRAIRIE DOG CONSERVATION PLAN

On July 7, 2000, the Colorado Division of Wildlife (CDOW) announced a four-part conservation plan for the black-tailed prairie dog. The plan would entail the following:

1. A hunting season closure for black-tailed prairie dogs.
2. A permit system for poisoning of black-tailed prairie dogs.
3. Clarifying of the Division's policy regarding the relocation of prairie dogs within counties.
4. Implementation of a black-tailed prairie dog incentives program for private landowners.

RMAD believes that the CDOW black-tailed prairie dog conservation plan has some flaws and some strengths.

First, the plan's hunting season closure is very welcome indeed, and it addresses prairie dog shooting, which is increasing in popularity and consequently is a growing threat to prairie dog populations and other wildlife that use prairie dog towns. Beginning in September 2001, it will be illegal to shoot prairie dogs in the state of Colorado. We applaud the Wildlife Commission for passing this prohibition. However, the closure will not affect private landowners' ability to shoot prairie dogs on their own land. Given that the majority of prairie dogs in Colorado exist on private land, and given that the majority of those private lands are used for agriculture, RMAD believes that this loophole may allow the glaring threat to prairie dogs caused by shooting to persist. The hunting season on black-tailed prairie dogs could and should be closed by the CDOW, on private and public lands alike.
Second, a permit system for poisoning prairie dogs may do little to circumscribe the threat to prairie dogs caused by poisoning. Furthermore, RMAD believes that any poisoning of prairie dogs -- permitted or otherwise -- is a violation of the state ban on traps, poisons, and snares. Although the state ban does not protect prairie dogs, it does protect many of the animals, such as rabbits, snakes, weasels, badgers, and foxes, who use prairie dog burrows. Given that poisons used on prairie dogs, such as aluminum and zinc phosphide, are indiscriminate killers, protected species are poisoned when a prairie dog burrow is poisoned. RMAD is presently suing the CDOW over this very issue. CDOW cannot, therefore, plead ignorance of the very strong possibility that prairie dog poisoning is a violation of state law.
Third, the CDOW's move to abandon its earlier administrative directive to broaden the applicability of SB-111, the inter-county prairie dog relocation restriction law, to prairie dog transfers within a county, is a very welcome announcement. RMAD objected to the application of SB-111 to intra-county transfers, and we are pleased at this move by the CDOW. We are also pleased that CDOW is recognizing the importance of facilitating prairie dog relocation as part of the solution to the crisis of the prairie dog ecosystem along the Front Range.
Fourth, while we agree with the need to make prairie dog conservation attractive to private landowners, we also believe CDOW and other state agencies should actively educate landowners about prairie dogs. In particular, ranching interests have historically been intolerant of prairie dogs due to the myth that prairie dogs "rob" cattle of forage. However, scientific research in the past 20 years has demonstrated that this is indeed a myth, and that prairie dogs present no significant economic threat to cattle ranching. We'd like the CDOW and the State of Colorado to actively educate cattle ranchers and other agricultural interests to peacefully coexist with prairie dogs and other wildlife in the state, rather than continue to persecute that wildlife.
Those are our responses to the four prongs of the proposed black-tailed prairie dog conservation plan. We hope that the following strategies will be included in the CDOW's actual Black-Tailed Prairie Dog Conservation Strategy:

Prairie dog recovery on public lands. CDOW should advocate recovery of prairie dogs on public lands in the State of Colorado. State Wildlife Areas administered by the CDOW, state school lands administered by the State Land Board, National Grasslands administered by the U.S. Forest Service, and U.S. Bureau of Land Management holdings in the state could all serve as an extensive land base provided for full recovery of the black-tailed prairie dog ecosystem in Colorado. CDOW's plan should address this.
Protection of prairie dogs from development. The CDOW plan should address the development issue, which is the main reason for the reduction of prairie dog populations and prairie dog-occupied acreage along the Front Range. Currently, citizens seeking protection for prairie dogs from development receive no help from CDOW officials.
Pledge from the state. In addition, the plan should involve a pledge from the CDOW and the Department of Natural Resources (DNR) that they are doing this all in good faith. We are concerned that this is another move to head off listing (which CDOW officials explicitly state) rather than a genuine, sincere effort to conserve prairie dogs. If the black-tailed prairie dog continues to decline, we should ask CDOW and DNR to pledge that they will not spend a million dollars lobbying in Washington to prevent the black-tailed prairie dog from being listed (as they did the preble's meadow jumping mouse). This effort should be about honoring the spirit of the ESA -- recovering species in trouble so they won't need to be protected under the ESA. It should not be about trying to thwart/circumvent the ESA.
Again, RMAD is pleased that the CDOW appears to have changed its position in recognizing that steps need to be taken immediately to conserve black-tailed prairie dogs and their ecosystem. Now we ask that CDOW advocate measures that will accomplish that task effectively, in order to restore and protect the unique and magnificent prairie dog ecosystem that once flourished in Colorado. It can flourish again if government officials join citizens in taking a firm stand on behalf of Colorado's wildlife.


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