You may be aware there has been a petition submitted to the U.S. Fish and Wildlife Service to list the black-tailed prairie dog as an endangered species in El Paso County. The petition includes the state of Colorado and 10 other states.At least two of the groups responsible for submitting the petition are headquartered in Boulder, Colo., and Santa Fe, N.M. Because those groups are not from El Paso County, they do not represent our interests or understand our land.The El Paso County Board of Commissioners has unanimously signed a letter of opposition to this petition, and I am committed to actively work to oppose this action. The listing of this species as endangered, or even as threatened, is unfounded scientifically and is disastrous to the citizens of El Paso County in numerous ways.Let us begin with definitions. To be listed as endangered means a species is in imminent danger of disappearing from the face of the earth if its situation is not improved. A threatened species is at risk of extinction in the probable future.Neither of these definitions is defendable within El Paso County’s existing prairie dog population or habitat.There is no evidence of overutilization of the prairie dog for commercial, recreational, scientific or educational purposes in the county, and the high population figures support this conclusion.El Paso County has determined the following (taken from the letter of opposition from El Paso County to the U.S. Fish and Wildlife Service):Since it has been determined by the U.S. Fish and Wildlife Service the species is not in peril due to habitat loss or population decline and 68 percent of the county contains potential prairie dog habitat, the board believes the issues of plague, poisoning and poisoning regulation can be better addressed locally without federally listing the species.Since 77 percent of the potential prairie dog habitat in the county is in private ownership, listing would put a serious financial hardship on any state, federal or private project.Only one of the prairie dog-dependent and/or prairie dog-obligate species is federally listed. Since the majority of prairie dog-dependent/obligate species, as well as the prairie dog itself, is on the state list as species of concern as opposed to the state threatened or endangered species; the logical conclusion is that the Colorado Division of Wildlife’s view of this “keystone species” is that it is not in peril.Future transportation models show no effect to overall prairie dog populations in the county. Listing the prairie dog would put an economic hardship on the county.CDOT has already set aside areas for prairie dog mitigation when there is potential for transportation projects to affect prairie dogs and other grassland species, and the county has cooperated with and participated in these efforts.Real concerns exist that the county’s prairie dog population may see a significant drop immediately prior to listing as private landowners will likely try to exterminate all prairie dogs on their properties to remove a potential burden created by the Endangered Species Act regulations.Plague is a naturally occurring phenomenon and will always remain throughout the state at background levels with occasional epizootic episodes. The county believes addressing the issue of plague is not best solved by the ESA but rather through solutions developed by local and state agencies.There are an estimated 923,190 acres of prairie dog habitat in El Paso County. In 2008, the Colorado Natural Heritage Program completed a study regarding the impacts of current and future construction scenarios to evaluate whether conservation goals for various species can be met. Again, cited from the county’s letter of opposition, the CNHP’s analysis revealed prairie dog occurrences exceed the goal of 66 percent (moderate risk) under current conditions with an actual occurrence of 139 percent throughout Pueblo and El Paso Counties. What this means to the service is regardless of the future transportation construction scenario in both counties, there will be no net effect on the prairie dog, and the population will remain at 100 percent.My thanks to county staff and all those who have worked to gather real data, which debunks the attempt to list the black-tailed prairie dog as endangered in El Paso County. My colleagues and I are committed to fighting this potential listing with the cold hard facts and are committed to protecting the private property rights of El Paso County citizens.Amy LathenEl Paso County Commissioner, District 2You may contact the U.S. Fish and Wildlife Service with your thoughts at:Public Comments ProcessingAttn: FWS-R6-ES-2008-0111Division of Policy and Directives ManagementU.S. Fish and Wildlife Service4401 North Fairfax Drive, Suite 222Arlington, VA 22203
