Prairie dog hearing

I am writing concerning an initiative that U.S. Fish and Wildlife Service is trying to put in place through Natural Resources Conservation Service. Within this initiative, they are planning to compensate landowners to "conserve" prairie dogs on their properties. In other words, they are planning to pay landowners to maintain prairie dog infestations. The plan clearly states no lethal control will occur on the conservation (infestation) areas. The control will be done on what they have termed the "management area" or, in other words, on the neighbors' land after the damage already has been done. In Logan County, USFWS has attempted to control prairie dogs for 3 miles out and that has not worked, yet this plan will control less than one-eighth of a mile around the infestations.

If USFWS is not stopped, they will issue themselves a 50-year permit for the entire area that makes up the historic range of the prairie dog. That area encompasses most of 12 states (see tinyurl.com/cu86mhs) and consists of an estimated billion acres. In exchange for compensating landowners for leaving prairie dog infestations on their land, the landowners have to agree to let USFWS release black-footed ferrets on the infested areas for 10 to 40 years.

Within the plan, they admit plague is now present in all 12 states, and they will just deal with it as it develops. Therefore, this plan is a health and safety risk to any area in which they place ferrets. Additionally, as Logan County has found, with prairie dog infestations come rattlesnakes. An 8-year-old boy was nearly lost to a rattlesnake bite a little over a year ago on land, which abuts the Haverfield complex. Last year, the common statement was there was a rattlesnake at every third yucca plant. Therefore, this plan endangers the health and safety of everyone in its path, not to mention the enormous economic impact that comes with the prairie dog infestations due to the repeated treatment costs and loss of grazing and crops to burrowing and clipping done by prairie dogs.

USFWS says it will address dispersal of prairie dogs with structural and vegetative barriers, both of which have been proven completely ineffective in Logan County. KSU conducted a study of the vegetative barrier in Logan County and the conclusion stated, "All research suggested the barrier, as constructed, was not effective at slowing or stopping dispersal away from the ferret reintroduction site." Yet, the Draft Black-footed Ferret Safe Harbor Agreement states, "At one reintroduction site in Kansas, management of prairie dogs by Wildlife Services at the property boundary, to minimize the expansion of prairie dog colonies onto adjacent properties, has addressed this issue." This is an unmitigated misstatement of the facts.

The SHA states that the "conservation areas," which are to be a minimum of 1,500 acres, can be comprised of two or more adjacent landowners in order to attain the 1,500 acres necessary. When they say "adjacent," by actual definition it does not mean the properties share a common border; it means they are near each other. USFWS has not defined "near." In Logan County, they left one ferret 4.5 miles away on a non-enrolled property. The two release areas in Logan Count are near (adjacent) enough by USFWS definition at 8 to 10 miles between areas where ferrets are released that USFWS, Dan Mulhern, stated in a recorded meeting they consider the two separate areas as one release site. He also stated a ferret traveling 10 miles is "doable." Therefore, this statement and the locations of the two sites in Logan County clearly establishes USFWS considers 8 to 10 miles apart as "adjacent." Adjacent is not abutting, it does not have to touch, only be near. By USFWS definition of adjacent, they could checkerboard prairie dog infestation all across the majority of 12 states. A minimum of the western 62 counties in Kansas are within the historic range of the prairie dog.

The comment period closes on this initiative on Feb. 22. If you would like to read any of the documents associated with the plan, they can be found at tinyurl.com/d4fecej. The press release contains minimal information; the actual details of the plan are located in the draft environmental assessment and the Safe Harbor Agreement. This plan will have disastrous effects for any area unfortunate enough to be chosen for a "conservation" area.

If USFWS puts this initiative in place, the two release areas in Logan County will become part of this compensation plan at the further expense of not only neighboring landowners but also Logan County as a whole. If you would like to comment, you can submit a comment via email to ferretsha@fws.gov; via fax to (970) 897-2732; or via mail to Kimberly Tamkun, U.S. Fish and Wildlife Service, National Black-footed Ferret Conservation Center, P.O. Box 190, Wellington, CO 80549-0190.

Sheila Ellis

Scott City