Dear Jonathan,
We want to convey our personal appreciation to you individually, and to the Montana Prairie Dog Working Group, collectively, for your contributions in helping draft a Prairie Dog Conservation Plan for Montana. Your participation in the October 20-21 work session was critical to Montana’s effort to forestall listing of the black-tailed prairie dog under the Endangered Species Act.
So begins a form letter from Montana Fish, Wildlife and Parks regarding our participation in the Montana prairie dog working group — a group of state and federal agency employees, environmentalists, and private landowners that meets a couple times each year to plan prairie dog research and conservation actions. The letter was sent upon completion of Montana’s statewide prairie dog conservation plan, which PCA does not support. This conservation plan is unfortunately no more than a political device to retain state control over wildlife management.
Empty promises, hollow words
If the black-tailed prairie dog receives protections under the ESA as a threatened species, primary responsibilities for management of the species would be transferred from the states to the federal U.S. Fish and Wildlife Service (FWS). Montana and the other 10 states that fall within the historic range of the black-tailed prairie dog are offering an alternative: a multi-state conservation plan, which would keep the state wildlife agencies in control. All 11 states would then develop state-specific plans that tier to this plan.
Why should we care who conserves prairie dogs, as long as the job gets done? We reported on this multi-state plan in the last Home Range (Fall 1999), and outlined several examples of how the states are neither sincere in their promises to conserve prairie dogs, nor capable of restoring this ecosystem without federal involvement. Since then, three more significant examples have emerged:
• Colorado has threatened to file a lawsuit against the federal government if the prairie dog is listed as a threatened species, clearly showing that this state cares more about its authority than the recovery of the prairie dog.
• Montana drafted a state conservation plan in haste in October, but the final plan eliminated the only significant aspect of the earlier draft version – a suggestion that Montana manage prairie dogs at 1-2 percent of the land in its historic range. In fact, all on-the-ground specifics (when, where, and how many) were ignored, and the state warned it would end all work on this issue if the species is listed as threatened.
• Colorado and North Dakota have refused to sign onto the multi-state prairie dog plan, even though it contains no enforceable requirements. If the 11 states can’t even agree on this vague plan, how can we expect them to restore prairie dog ecosystems?
Ultimately, the multi-state plan is irrelevant to our efforts to list the black-tailed prairie dog as threatened because the multi-state plan does little-to-nothing to meet the five criteria used to determine listing a species under the ESA:
1) The Present or Threatened Destruction, Modification, or Curtailment of the Species’ Habitat or Range
• The plan does not slow or reverse habitat loss or destruction.
2) Overutilization for Commercial, Recreational, Scientific, or Educational Purposes
• The plan does not regulate shooting.
3) Disease or Predation
• The plan does not slow or control sylvatic plague.
4) The Inadequacy of Existing Regulatory Mechanisms
• The plan does not reclassify the species or allow for additional protection.
5) Other Natural or Manmade Factors Affecting Its Continued Existence
• The plan does not decrease, control, or regulate poisoning.
• The plan doesn’t slow or stop fragmentation.
The state plan may identify these threats, but it does nothing about them. It avoids making the difficult decisions of specifically how many acres of prairie dogs we will attempt to maintain and restore, how we will accomplish this, and where they will be located.
PCA is not opposed to the efforts of the states to create prairie dog conservation strategies. In fact, we have been actively involved in Montana’s efforts to do just this since the first Montana prairie dog working group meeting, almost four years ago. We are opposed, however, to the attempt to replace the protection of the ESA with a strategy incapable of providing actual on-the-ground prairie dog protection and recovery. Unless the multi-state plan contains specifics that act immediately to reduce threats listed in the five criteria and show improvement on the ground, it cannot legally affect the listing process. But the political process does not always follow the rules, and the multi-state effort has tremendous potential to negatively affect ESA protection for the black-tailed prairie dog.
The final decision on protecting the black-tailed prairie dog as a threatened species is due February 15. We will report the outcome in the next issue of The Home Range.
