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Forest Service Backpedals On Prairie Dogs – Agency Rescinds 2000 Ban on Black-tailed Prairie Dog Poisoning
Black-tailed prairie dogs primarily occur on national grasslands within the Forest Service system, including the Buffalo Gap in South Dakota; Thunder Basin in Wyoming; Comanche and Pawnee in Colorado; the Cimarron in Kansas; and the Kiowa in New Mexico.
WildEarth Guardians described the Forest Service as backpedaling on black-tailed prairie dog protection and questions the federal commitment to candidate conservation.
“The federal government is now demonstrating that, unless the black-tailed prairie dog is listed under the Endangered Species Act, there is no safety net for this animal. Just when we thought we were making forward progress, the Forest Service has taken a major step back in regard to the prairie dog and the ecosystem this species sustains,” stated Dr. Nicole Rosmarino, Endangered Species Director for WildEarth Guardians.
In October 2003, WildEarth Guardians, Biodiversity Conservation Alliance (Laramie, WY), the Center for Biological Diversity (Denver, CO), and Center for Native Ecosystems (Boulder, CO), filed their intent to sue the U.S. Fish and Wildlife Service for failing to list the black-tailed prairie dog. For more information see our Black-tailed prairie dog issue page.
Letter from Forest Service rescinding ban:
United States Forest Service Washington Office 14th & Independence SW Department of Agriculture P.O. Box 96090 Washington, DC 20090-6090
Caring for the Land and Serving People Printed on Recycled Paper
File 2600 Route| (1900), (2200)
Date: February 12, 2004
Subject: Black-tailed Prairie Dog Management
To: Regional Forester, R-1, Regional Forester, R-2, Regional Forester, R-3
We have reviewed our July 26, 2000 policy letter regarding control of the black-tailed prairie dog under certain circumstances on National Forest System (NFS) lands. A purpose of the letter was to support conservation of this newly-designated candidate and sensitive species. Along with efforts by states to develop and implement state conservation plans for this species, and other private, organization and federal efforts, these actions also were intended to help prevent a need to list this species under the Endangered Species Act (ESA).
As you know, in 2000 the Fish and Wildlife Service (FWS) determined that listing this species as threatened under the Endangered Species Act was warranted, but precluded by other, higher listing priorities. Since then it has remained a candidate species under the ESA.
The prairie dog’s status on NFS land has not significantly changed since the warranted finding, and much close resource coordination and prairie dog habitat protection and management is being done, including support for black-footed ferret recovery efforts. With July 2002 Records of Decision, most of the prairie dog control restriction direction given in the July 26, 2000 letter was incorporated as standards into the revised Land and Resource Management Plans (LRMP’s) for the Nebraska NF, Thunder Basin NG and Dakota Prairie NG. These LRMP’s govern management of lands that support over 70% of the prairie dog colonies on NFS lands, and represent a much higher “regulatory mechanism” than does the 2000 letter. Many of the LRMP’s also emphasize the importance of considering the various state prairie dog management plans, which some states currently are developing.
We are eliminating the need and practice of establishing direction by letter, and encourage using Forest Plans and the agency’s Directives System instead. Because the restrictions on prairie dog control are now in LRMP’s for most prairie dog habitat on NFS lands, and because of established conservation direction that continues to apply, including the National Environmental Policy Act, the National Forest Management Act, the Forest Service Manual, and the required Forest Service review and approval of any proposed use of pesticides on NFS lands, we no longer believe the July 26, 2000 letter is necessary.
I hereby rescind that letter, and encourage all field units to use agency authorities, goals and objectives to continue to manage for the conservation of this candidate and sensitive species, in coordination with other land and resource management. Any future control proposals are to be carefully reviewed and coordinated with any approved state prairie dog management plans and with public input.
This policy rescission should not be interpreted as encouragement for poisoning of prairie dogs, but rather a means to ensure that any such decisions are considered and made at appropriate administrative levels, and are based on relevant resource considerations. I encourage a strategic and integrated approach to prairie dog management that also includes land ownership adjustments and livestock grazing management through allotment management plans and annual operating plans.
TOM L. THOMPSON Deputy Chief for National Forest System