Public Comments Processing

Attn: FWS-R6-ES-2008-0111

Division of Policy and Directives Management

U.S. Fish and Wildlife Service

4401 N. Fairfax Drive, Suite 222

Arlington, VA 22203

December 12, 2008

Fish and Wildlife Service;

Thank you for the opportunity to comment on the proposal to protect the
Black-tailed Prairie Dog under the Endangered Species Act. As a resident
of Highlands Ranch, Colorado, a large community in southern Denver, and
a natural habitat for the Black-tailed Prairie Dog, I have personally
witnessed the dramatic decline in Black-tailed Prairie Dogs populations,
and the resulting consequences of that decline on other wildlife. This
decline in my area has been primarily at the hand of Man, with specific
intent to exterminate this keystone species. For reasons partially
outlined further in the letter below, **I am in STRONG SUPPORT of
protecting the Black-tailed Prairie Dog under the Endangered Species
Act**.

Each year, our community "Land Managers" exterminate thousands of
Prairie Dogs in an effort to completely eradicate this native keystone
species. They are deemed unwanted "pests". The extermination is
typically opposed by the majority of residents that are aware of what is
actually happening, but the practice is continued none-the-less. The
public outcry has been so loud, this past summer local officials have
resorted to changing local policy to stop notifying residents of
impending exterminations, and terminate signage while the exterminations
are in progress.

Non-lethal control options have been proposed, with even volunteer
community labor offered up for one method, Reverse Dispersal
Transrelocation (RDT), and has been largely rejected. Lethal control is
STRONGLY favored by those in-charge. Common "favored" extermination is
burrow poisoning. This method of dropping toxic gas pellets into burrows
is toxic to other nearby wildlife, and residents for that matter, as the
gaseous substance used is heavier than air, and remains at ground level
until disbursed by wind.

The developers in the area, are probably the worst. They exterminate
huge parcels of viable/healthy Black-tailed Prairie Dog colonies. Both
through removal and extermination, and by simply bulldozing over live
colonies (I personally have witnessed this on a couple of separate huge
parcels in my area). They are deemed pests and trespassers, which impede
urban sprawl, and are summarily exterminated.

The nearly complete eradication of the Black-tailed Prairie Dog has
driven off many dependent wildlife, or encouraged undesirable behavior.
Birds of prey, namely falcons and hawks, were once a common sight in my
area, only 5 years ago. These birds hunted in the colonies, but with the
extermination of their prey, even the installation of "perch poles" by
the community have failed to re-attract these beautiful predators to the
area. Coyotes, while not completely driven off, have taken up
undesirable behavior. With their prey now eradicated, attacks on
domestic animals have marked a notable increase. In fact, two
neighboring communities, Centennial, Colorado, and Parker, Colorado have
now begun studying widespread lethal control of Coyotes.

The reckless and irresponsible eradication of the keystone species, the
Black-tailed Prairie Dog by cities, counties, community officials, and
developers has caused a negative ripple effect on the food-chain, and
dependent species that use the burrows (like burrowing owls). I have
noted that one bad policy (eradication of Black-tailed Prairie Dogs) has
led to proposals of other bad policies like eradicating the predators.
We seem to have forgotten our elementary school teachings on the food
chain. When you mess with one component of that chain, the cycle
collapses, or at least changes, most of the time in an undesirable
manner.

Cities, counties, community officials, and developers have justified
their behavior by citing erroneous misinformation. For instance:

1)  "Prairie Dogs carry Plague"

    a.  Not accurate. Prairie Dogs can carry fleas that carry the Plague
        (as can dogs, cats, horses). Prairie dogs are HIGHLY susceptible
        to the plague, and if infected, die very quickly (which
        incidentally has also dramatically decreased their numbers). If
        you see live prairie dogs, that means no Plague. If we are
        concerned with fleas, dust with flea powder, don't exterminate
        the Prairie Dogs (and dogs and cats for that matter).

    b.  Plague is effectively treated with antibiotics. The word carries
        doom and gloom from history, prior to modern antibiotics.

2)  "You can't keep Prairie Dogs out of your yard"

    a.  Not accurate. Prairie Dogs avoid places they can't see into.
        Effective measures to keep them away from undesirable locations
        are visual barriers 24 inches tall. Tall grass, fencing, shrubs
        etc. work.

3)  Prairie dogs multiply uncontrollably.

    a.  Not accurate. According to Zoologists and Biologists at the
        Denver Zoo, Prairie Dog females don't reproduce until their
        3^rd^ year. Then they only produce 1 litter of approximately 3
        pups annually. Their lifespan is only about 5 years.

The killing has to STOP before it is too late. Extermination of this
species, based on greed (developers), and perpetuated by misinformation
will lead to irreparable harm to the ecosystem. We have clearly seen a
glimpse of this, please, let us not be blind.

Thank you,

Lee Tompkins

Highlands Ranch, Colorado